Verdova Issues CI Calculation Comments to USDA

Thank you for the opportunity to comment on Technical Guidelines for Climate-Smart Agriculture Crops Used as Biofuel Feedstocks.

The focus of our comments is the lack of impact of fertilizer amounts, yield, and manure usage, along with ensuring that USDA FD-CIC can more closely account for growers' current practices, such that they stay engaged in the CI scoring process.

View our comments.