The consistent undervaluation of a fuel produced from a cellulosic feedstock represents one (out of many) challenges undercutting efforts to achieve cellulosic biofuel production targets set by the RFS. If biofuel production credits are not more closely linked to actual CI reductions, biofuel producers are less incentivized to undertake measures to reduce emissions. This is particularly relevant for cellulosic biofuels, which are subject to high capital costs that cannot be recovered with low fuel selling prices. Using field-specific LCA to more accurately quantify biofuel CI reductions and allowing lower CI fuels to be sold at higher prices (because of higher priced program credits) would make more money available to low-GHG technologies (including herbaceous feedstocks) and measurement tools to facilitate field-specific LCA.