2025-00975. Technical Guidelines for Climate-Smart Agriculture Crops Used as Biofuel Feedstocks

Table 1—Estimated Level of Effort (LOE) per Entity per Year

Category	LOE (hours per year)
Producers (1 CSA practice)	5
Producers (2 CSA practices)	6
Producers (3 CSA practices)	7
Producers (Audits only, if selected)*	8
First Point Aggregators (small)**	48
First Point Aggregators (medium)**	143
First Point Aggregators (large)**	286
Intermediary Entities**	143
Biofuel Refiners**	673
Notes:
* Farms selected for audits will have 8 extra hours of LOE. Not all farms are selected for audits in a given year.
** LOE hours do not include verification fees.

Table 2 summarizes the annual per entity costs (in 2023 dollars) per entity type. For farm producers, depending on the number of CSA practices adopted, the annual costs range from $380 to $490, which include costs associated with quantification of the carbon intensity of the crop and recordkeeping time costs and a lawyer fee for completing the farm attestation, with an addition $470 annually per entity in the event that a farm producer is audited. The verification and recordkeeping costs for First Point Aggregators is estimated to be between $3,400 to $19,400 per year per entity, depending on the size of the aggregator. These costs include any verification fees incurred for their audits and the audits of the farm producers. The verification and recordkeeping cost for intermediary entities are estimated to be $9,400 per entity per year. Finally, recordkeeping and verification costs for biofuel refiners are estimated to be $72,500 per entity per year.

Table 2—Estimated Cost Per Entity Type Per Year

[in 2023 dollars]

Category	Cost
Producer (1 practice)	$380
Producer (2 practices)	440
Producer (3 practices)	490
Producer Audits	470
First Point Aggregators (small)	3,400
First Point Aggregators (medium)	9,900
First Point Aggregators (large)	19,400
Intermediary Entities	9,400
Biofuel Refiners	72,500