Friends of Family Farmers Issues Public Comment on USDA Notice

WASHINGTON, May 30 -- Amy Wong, policy director at Friends of Family Farmers, Walterville, Oregon, has issued a public comment on the U.S. Department of Agriculture notice entitled "Request for Comments: Executive Order on Tackling the Climate Crisis at Home and Abroad". The comment was written on April 29, 2021, and posted on May 27, 2021:

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I am submitting this comment on behalf of Friends of Family Farmers, a nonprofit organization promoting and protecting socially and ecologically responsible agriculture in Oregon for the past 15 years. Our expertise lies at the intersection of agriculture and the environment and we represent over 6000 family-scale farmers and ranchers, rural residents, and eaters across the state. Our policy advocacy is rooted in farmers' experience, which we synthesize during our bi-annual farmer listening tours across Oregon.

According to our "virtual" 2021 listening session, the most widely held concern among family-scale farmers in Oregon is climate change. Access to small-scale meat processing and access to land were also among the top three concerns. The family farms we work with are ones in which the primary producer is working toward, or obtains, the majority of their livelihood from the land, the family unit is making management and operational decisions and are involved in operations, and the operation contributes to local and regional economy, employs humane and ecologically sound practices, and provides a range of other benefits.

Friends of Family Farmers has long advocated for a level playing field for family-scale farmers and believe that industry consolidation in the vein of Earl Butz's "get big or get out" has indeed driven many small farmers off the land. A cogent example of this is the expansion of large-scale dairy operations. These mega-dairies pose increasing risks to human health and the environment and threaten a just and equitable industry.

As the industrial dairy industry grows, family-scale farms are displaced in favor of mega-dairies that house thousands of cows in confined spaces and create outsized climate impacts. Oregon is home to the largest dairy in the country, Threemile Canyon Farms, which houses over 90,000 cows. Despite Threemile Canyon Farms being celebrated as a beacon of sustainability, there are serious problems with the operation, including detrimental impacts on the local environment, health, and agricultural economy. After Threemile Canyon Farms opened in 1999, Oregon's small and mid-sized dairies have declined significantly: an average of nine family dairy farms in the state went out of business each month between 2002 and 2007, due in large part to public supports that favor the largest in the industry. Mega-dairies such as these, and the concentrated ecological and health impacts they create, should not be permitted, and USDA should under no circumstances be subsidizing these operations.

Instead of promoting factory farming schemes, we urge USDA to focus its climate-resilient agriculture efforts on the following:

1. Support family-scale regenerative farming systems and practices that improve soil health and carbon sequestration.

Friends of Family Farmers manages the Oregon Pasture Network (https://oregonpasturenetwork.org/), an alliance of 70 farmers and ranchers around the state who are committed to soil health and pasture-based management. These producers are implementing a robust suite of practices that work together to build soil health, sequester carbon, and lead to reduced need for climate-harming chemical inputs. We are concerned that many of these practices are being applied in very narrow ways in large-scale, monocultural operations, and urge USDA to acknowledge the importance of supporting whole farm, regenerative approaches to climate mitigation and resilience over "single use" practices in operations that continue to take a large toll on the climate. Oregon hopefully will soon be conducting a statewide soil health assessment and it is our hope that land that has been in chemical-intensive rotations will be compared to pasture-based systems in terms of their relative climate impact.

Leveraging existing USDA policies and programs for climate resilient farming: A handful of the farmers in our network have benefited greatly from the Sustainable Agriculture Research and Education (SARE) Program. This is a key program supporting soil health and should be amplified as the federal government takes a more aggressive approach to addressing climate change. In addition, more technical and financial support through the Natural Resources Conservation Service (NRCS) is critical. The Farming Opportunities Training and Outreach (FOTO) program, which provides assistance to socially disadvantaged and veteran farmers and ranchers (SDVFRs) and beginning farmers and ranchers (BFRs), is also critical to uplift as part of an equity-centered agricultural climate strategy. Significantly investing in these programs will meaningfully support family farmers, build climate stewardship and resilience, and address long-standing inequities in the agricultural system.

New USDA strategies for "climate-smart" farming (Question A1b): Friends of Family Farmers is currently working to increase the number of organic-focused extension agents at Oregon State University to help fill a need in the farming community. Additional federal funding for agricultural extension that focuses on expanding regenerative and organic practices would be a major additional benefit to the state, and nation's, farmers.

2. Restore the Organic Livestock and Poultry Practices (OLPP).

The integrity of organic standards is of utmost concern. The Organic Livestock and Poultry Practices rule is critical to maintain the integrity of the National Organic Program by ensuring that all organic producers are held to the same set of basic standards. The rule's removal undermines legitimate efforts to leverage organic agriculture as a climate-smart farming approach. We urge USDA to revoke the withdrawal of, and reinstate, the OLPP rule in order to maintain the integrity of the National Organic Program.

3. Encourage a shift away from factory farming and the false promises of biogas, toward regenerative, family-scale farms.

The Biden Administration cannot rightfully take a leadership stance on tackling climate change and at the same time promote factory farm gas, or biogas, support for which props up the worst climate-polluting dairy operations. The financial incentives that the largest industrial mega-dairies have received here in Oregon have clearly led to their expansion, and the worsening of human and ecological health impacts from the resulting concentration of waste and water use and the decline of rural economies.

Biogas is one of the ways in which CAFO operations "greenwash" the environmentally destructive practices inherent in its business model. Indeed, the manure digester at Threemile Canyon Farms was cited for two EPA violations in 2020, and the operation has reported ammonia emissions among the highest of any industry nationwide--even in 2005 when the herd was comprised on only 50,000 cows. Typically located in the poorest communities and in communities of color, biogas projects are nothing less than environmental justice disasters. Threemile Canyon Farms is located in what is slated to become the first majority non-white, predominantly Latinx, county in Oregon underscoring this point.

As mentioned above, the toll of mega-dairies on the rural economy is significant. Oregon dairy farmers, including Friends of Family Farmers members, have had to transition from Grade A dairy production to consumer-direct raw milk because the cost of production was too high to be able to compete in a market flooded with cheap milk from mega-dairies. Forty years ago, Oregon was home to more than 4,000 dairies, mostly small, family-owned businesses. Now, just over 200 remain. Threemile Canyon Farms advertises that they are farmer-owned and portray images of bucolic small farms in their advertising, obscuring the reality that the vast majority of the milk the operation produces comes from a factory farm in Eastern Oregon owned by an international conglomerate, R.D. Offutt, with hundreds of millions in assets.

Now more than ever, Oregon and the rest of the country need to rebuild our economy, and re-regionalize our food systems, wherein public policy prioritizes feeding our communities instead of shipping commodities like milk nationally and internationally. Putting a moratorium on mega-dairies is an essential first step in addressing these issues and leveling the playing field so that small dairy farmers have a chance again.

In the USDA's efforts to promote climate-smart agriculture, we strongly urge you to tackle head-on the complicity of public agencies with unfortunate, but expected, industry outcomes. For example, a Freedom of Information Act (FOIA) request revealed that in 2017, Oregon Department of Environmental Quality and Oregon Department of Agriculture were both aware of potential groundwater issues at Threemile Canyon Farms, including worsening nitrate concentrations, general exceeded concentration limits, and data showing that irrigation water moved ammonia past the root zone. Yet both agencies supported the opening of another mega-dairy, Lost Valley Farms, in the same critical groundwater management area.

Lost Valley Farms ended up being a true environmental nightmare and had to be shut down by the state, the costs of which were borne by Oregon taxpayers. Further complicating matters, until this month, both agencies were considering allowing the Easterday family, one of the largest agricultural operations in Washington State, to operate a mega-dairy on the same site, claiming the owner of Lost Valley Farms, Greg te Velde was simply "one bad actor" and this would be a new chapter for the troubled site. In reality, Cody Easterday, the President and CEO of Easterday Ranches, had been engaged in considerable fraudulent activity and Easterday Farms and Easterday Ranches declared bankruptcy earlier this year. Cody Easterday recently pled guilty in federal court to defrauding Tyson of more than $244 million dollars by charging the company for the purchase and feeding costs for hundreds of thousands of cattle that existed only on paper. In light of these developments, the permit for Easterday Farms Dairy is currently on hold.

Unlike these mega-dairies, independent, family-scale dairy farms allow cows to graze on pasture and do not maintain dangerous quantities of liquid waste that then must be disposed of. These operations also do not use large manure lagoons that increase methane production.

USDA should enact an immediate moratorium on new and expanding large CAFOs and require the phase-out of existing large CAFOs by 2040. USDA should authorize $100 billion over ten years for a voluntary buyout program that enables existing factory farm owners to pay down debt and/or transition to alternative agricultural systems on their land (such as pasture-based livestock or specialty crops).

4. End subsidies to chemical-intensive commodity crops.

The range of direct and indirect public supports for the largest, most intensive and environmentally destructive farming operations is a key contributor to the false dichotomy of "cheap" food that isn't actually cheap if the environmental and other externalities were accounted for. Climate-resilient agriculture efforts should serve to shift public support to biodiverse, sustainably-grown foods. USDA should look broadly at how to initiate a just transition away from pesticide-intensive monocropping and factory farming toward diversified regenerative and organic production of plant crops and a sustainable amount of pasture-based animal agriculture. USDA should pursue provisions in Senator Booker's Farm System Reform Act, including a moratorium and phase-out of CAFOs with a voluntary buyout program.

5. Level the playing field for small farmers.

Public policy and financial support for agriculture in the United States broadly and disproportionately benefit the largest, most polluting actors in the industry, accelerating the ecological and public health crises and concentrating wealth to unprecedented levels. This trend is driving family farms out of business and draining rural economies and communities of life.

Right-to-farm laws rarely help the small organic farmer. We strongly believe that a family-farm centered system, with more farmers on the land, is best suited to revitalize rural communities, produce a healthy and sustainable food supply and respond to climate change. We urge USDA's "climate-smart" farming effort to prioritize investment in sustainable farming practices and a climate resilient food system, which will spur economic growth and build the regional and local processing infrastructure that is needed to support small and mid-sized farms. Independent family farmers, including livestock producers, must be at the center of climate policy for agriculture.

Equitable implementation will require that USDA addresses baseline GHG emissions from CAFOs and large crop producers and requires them to achieve a minimum level of abatement or emissions reduction before they can receive payments for further reductions. To pay all producers for reductions without requiring a minimum baseline effort would reward bad, large-scale actors and disproportionately negatively affect renters, beginning, and specialty farmers.

Sincerely,

Amy M Wong

Amy Wong

Policy Director

Friends of Family Farmers

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The notice can be viewed at: https://www.regulations.gov/document/USDA-2021-0003-0001

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