ASA Appreciates SAF Feedstock Eligibility Inclusion—but Concerned Strict New Pathway Prohibitive for Northern Soy States

The Department of Treasury first recognized soy as an eligible sustainable aviation fuel (SAF) feedstock in initial guidance last December through a Renewable Fuel Standard pathway. Now, additional guidance from Treasury goes a step further to sweeten the value for soy. It provides a second pathway for soybean oil-based SAF to qualify for the SAF tax credit (40B) and assigns the feedstock a better carbon intensity (CI) reduction score. Since the Dec. 15 news, ASA has implored USDA and other agencies to ensure a higher value can be achieved by using soybean oil than the baseline $1.25/gallon credit for SAF that meets a 50% greenhouse gas (GHG) reduction compared to traditional petroleum jet fuel.

Where the guidance from Treasury goes sideways for soy, however, is that for soybean oil to qualify through this new pathway, the soybeans must be grown using both no till and cover cropping. ASA is very supportive of using climate smart agriculture practices to improve CI reductions, but specifying only two practices out of a variety of sustainability measures will further restrict soybean oil use as a SAF feedstock. Adding to concerns, no till and cover cropping are feasible only for soybean farmers in certain parts of the soy growing region, which means regional disparity is likely.

Josh Gackle is the American Soybean Association's president and grows beans in Kulm, North Dakota: "For growers like me here in North Dakota, short growing seasons and unpredictable fall weather make the cover crop requirement alone next to impossible. Growers in the Northern Plains do so when possible. However, employing both no till and cover cropping is contrary to what Mother Nature will allow, no matter what the guidance specifies."

ASA appreciates USDA's work to ensure improved CI reduction scores for soybeans but asks that more be done to create an inclusive program-and one that considers sustainability practices that are feasible across all soy states. The Treasury Department and the ad hoc working group of agencies assigned to SAF and other transportation fuel tax credits will now begin work on the Clean Fuel Production Credit (45Z), which offers soybean growers additional opportunities to support the biofuels industry.

ASA looks forward to working with USDA, EPA, and other agencies involved to ensure that 45Z offers flexibility in sustainability practices so that soybean farmers can support the administration in lower carbon emissions in the transportation sector.