Comment from Kansas Corn Growers Association

Summary: The Kansas Corn Growers Association supports the proposed 45Z clean fuel production credit but argues that the final rules must explicitly recognize and reward on-farm practices (like no-till and cover crops) as primary drivers of carbon intensity reduction. They also advocate for a flexible framework, the use of a "book-and-claim" system to attribute CI reductions, and the exclusion of foreign feedstocks to minimize administrative burdens on domestic producers.