Accounting for soil organic carbon for section 40B eligibility is neither aligned with statute or technologically feasible

The Clean Air Task Force asserts that including soil organic carbon (SOC) in the GREET model for section 40B SAF tax credit eligibility contradicts the requirement for a methodology similar to CORSIA, which does not credit SOC. The author argues that SOC sequestration is too variable and impermanent to be reliably verified, noting that the Treasury would need to establish complex regional baselines and implement novel claw-back provisions to prevent tax credits from being awarded for emissions reductions that are later reversed.

• The use of soil organic carbon (SOC) in the GREET model for section 40B eligibility is inconsistent with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), as GREET allows SOC to be factored into lifecycle emissions while CORSIA does not.
• Accounting for SOC is technologically infeasible because carbon sequestration in soils is highly variable and depends on factors that are not yet well understood or reliably verified.
• To accurately credit soil carbon, the Treasury would be required to establish baselines for every region, soil type, and farm practice, and would need to implement novel claw-back provisions to address the uncertainty of carbon permanence.
• The impermanence of SOC creates a risk where a producer could retain tax credits even if the sequestered carbon is later released back into the atmosphere due to changes in land ownership or farming practices.

APA

Hunt, K. (2024). Accounting for soil organic carbon for section 40B eligibility is neither aligned with statute or technologically feasible. Clean Air Task Force. https://www.catf.us/2024/04/accounting-soil-organic-carbon-greet-neither-aligned-statute-technologically-feasible/

Chicago

Hunt, Kara. Accounting for soil organic carbon for section 40B eligibility is neither aligned with statute or technologically feasible. Clean Air Task Force, 2024. https://www.catf.us/2024/04/accounting-soil-organic-carbon-greet-neither-aligned-statute-technologically-feasible/.

Wikipedia

{{cite press release |last1=Hunt |first1=Kara |title=Accounting for soil organic carbon for section 40B eligibility is neither aligned with statute or technologically feasible |publisher=Clean Air Task Force |date=5 April 2024 |url=https://www.catf.us/2024/04/accounting-soil-organic-carbon-greet-neither-aligned-statute-technologically-feasible/ |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{hunt2024accounting, author = {Hunt, Kara}, title = {{Accounting for soil organic carbon for section 40B eligibility is neither aligned with statute or technologically feasible}}, publisher = {Clean Air Task Force}, year = {2024}, month = apr, url = {https://www.catf.us/2024/04/accounting-soil-organic-carbon-greet-neither-aligned-statute-technologically-feasible/}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }