ICGA praises USDA Regenerative Feedstock Rule

BLOOMINGTON, Ill. — The Illinois Corn Growers Association and farmer leaders feel overwhelmingly positive after their review of the U.S. Department of Agriculture’s Regenerative Feedstock Rule.

“This rule is a clear framework that Illinois corn farmers have been waiting for, containing the important information that is critical for us to be empowered to make informed management and investment decisions. We are happy to have certainty as we plan for the 2027 crop year,” said Mark Bunselmeyer, ICGA president and Maroa farmer.

“We thank the administration for their obvious consideration of the comments provided during the rule-making process and for a rule that reflects most of the realities of farming today.”

He said there are several positive and important elements to the rule released:

• Field-level scoring is important, as farmers manage their fields independently and deserve to be recognized for the management decisions and conservation practices implemented on each acre.

• Evaluating nitrogen use using NUE, nitrogen use efficiency, is a valuable change that rewards farmers for practices that lower carbon intensity per bushel.

• Allowing grazing of cover crops and inclusion of manure are important elements that allow the integration of livestock and grain farming to continue and recognize the importance of the cycle.

• Evaluating soil health practices will transition from a focus on soil erosion to a focus on soil carbon loss. The change provides more flexibility for farmers who are lowering carbon intensity, while making decisions that improve efficiency and resilience.

Notably, the only concerning part of the rule is the mass-balance approach that ICGA believes may limit farmer participation in 45Z and leave significant value on the table for farmers.

USDA acknowledges a willingness to explore a transition to book and claim processes in the future, Bunselmeyer said.

“Mass balance may provide a practical implementation pathway, but it does limit farmer participation to those farming in certain regions,” he said.

“Many farmers who adopt practices that lower carbon intensity might not live near an ethanol plant. This process also leaves out livestock farmers who contribute emissions reductions that are within the scope of these goals. A book and claim approach is the right approach if our goal is to allow as many farmers as possible to participate.”

A second challenge is the need for a recent two-year soil test to develop a nutrient budget. Many Illinois farmers are historically on a four-year sampling cycle.

This challenge is workable — but will add costs that, in today’s farming economy, are difficult to overlook, Bunselmeyer said.

Two steps in this rule-making process remain: the USDA guidance must be considered by the U.S. Department of Energy and the U.S. Department of the Treasury.

ICGA encourages all parties to move forward as quickly as possible, thinking all the while of the goal of empowering all corn farmers to adopt new conservation practices that come with new market opportunities, regardless of geography, marketing channel, or production system.

The flexibility provided in the USDA’s rule is an excellent first step to accomplishing this goal, Bunselmeyer said.