Dear Mr. Under Secretary:

The Sweetener Users Association (SUA) strongly supports the use of the newly announced “Partnerships for Climate-Smart Commodities” program for use by any sugar producer or sugar producer organization that has developed an innovative project that reduces greenhouse gases or sequesters carbon. As a trade association representing companies who buy sugar in the United States, we have a keen interest in sugar sustainability.

SUA’s working group for sustainable sugar has crafted “A Framework for On-Farm Sustainability in Sugar” that establishes a number of key parameters for sustainable U.S. sugar production. We believe the sugar sector needs to have credible measurement and verification of continuous improvement efforts that include the following components:

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