Land Core Issues Public Comment on USDA Notice
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Land Core is an independent 501(c)3 organization with a mission to advance soil health policies and programs that create value for farmers, businesses and communities. The organization is building the missing infrastructure and market-based incentives that will make the rapid adoption and scalability of soil health possible.
Land Core works closely with the
Policy wins include building a broad coalition of support for soil health and helping to secure over
A Focus on Achievable Agency Action:
In particular, there is enormous opportunity to advance critical infrastructure for the scaled adoption of soil health practices--resulting in production agriculture that reduces risk and is more profitable, productive and ecologically-sound--through non-legislative actions that can be initiated by setting agency priorities and enacting the following concrete recommendations.
1. Climate-Smart Agriculture and Forestry Questions
A. How should
1. How can
*
* Direct USDA-RMA to recognize the role of soil health in reducing risk associated with droughts, floods, extreme temperatures, pests and disease, and incentivize adoption of relevant practices, through reduced rates and other innovative efforts.
* Direct USDA-FSA Farm Loan Programs (when assessing a producer's eligibility for a loan), to recognize the role of soil health in reducing risk associated with droughts, floods, extreme temperatures, pests and disease. Incentivize adoption of relevant soil health practices through, for example, preferential programs (with lower requirements), reduced-rate loans, longer-term loans, or better/flexible terms.
2. What new strategies should
* Develop frameworks and programs that recognize and quantify the risk mitigation value (i.e. the associated savings) of soil health practices, to unlock much of the capital needed to fund the transition to soil health practices (and future carbon markets) without overreliance on government funding, and address some of the persistent issues regarding equity and access:
- Unlike carbon and ecosystem-services markets that are "pay for performance" in nature, "risk-mitigation" is reflected in rates that are given up front (i.e. a lower payment that leaves more money in the producers pocket for implementation of soil health practices).
- Any operation big enough to apply for a loan can benefit from risk-mitigation incentives, so all sizes of operations can take advantage of these opportunities.
- The risk-mitigation benefits of soil health (for example, increased water holding capacity and water infiltration rates)/3 improve resilience across a broad range of regions and soil types (including where the carbon sequestration potential may be limited)./4
- Early soil health practice adopters can be rewarded now for the work they have already done, unlike under most current carbon markets schemes.
- This risk-reduction strategy also protects the crop insurance safety net:
(i) With increasing weather volatility, taxpayer-subsidized crop insurance costs have increased significantly over the past decade,/5,/6 with no end in sight. Soil health practices have been found to mitigate yield losses,/7 in some cases dramatically,/8 and have been shown to consistently lower crop insurance payouts under drought./9
Incentivizing a soil health mitigation strategy will keep (otherwise untenable) cost increases down as well as futureproof lender portfolios and the assets that secure those loans.
(ii) Increasing resilience is a direct way of ensuring farmer and food security in the face of a changing climate.
- Once the transition to soil health practices is incentivized and undertaken, in addition to greater on farm resilience, future pay-for-performance markets, like carbon and ecosystem services, can meaningfully increase farmer profitability.
* Create a voluntary USDA-NRCS Outcomes-Verified Soil Health Program,/10 that:
- Gives producers a simple, standardized way of showing that they have an active soil health management plan in place that is improving their land, as verified by NRCS (or an authorized third party).
- Gives companies and developing markets a trusted way of ensuring their supply chains or markets are meeting a baseline standard.
(i) Allows for a voluntary registry of all producers who are in good standing in the program to facilitate new market opportunities and assist in supply chain integration.
* Provide funds for soil health equipment that will support the rapid and scaled adoption of conservation practices, and avoid unintended consequences (such as large spikes in herbicides used to terminate cover crops if/when alternative tools are unavailable)
- Equipment that is essential to the responsible adoption of various soil health practices, such as American-made roller crimpers and no-till drills, should be eligible for cost-share or subsidy through programs like EQIP. This will have the added benefit of supporting job creation through US manufacturing of such equipment.
* Direct USDA-RMA to work with private sector crop insurance providers to develop products that acknowledge and reward the implementation of risk-mitigating soil health practices.
* Recognize when traditional indigenous conservation practices on tribal land are substantively equivalent to NRCS Conservation Practice Standards and thus are eligible for funding from federal programs.
* Expand training for land grants and universities, including Historically Black and Tribal colleges and universities, to focus on soil health, soil carbon sequestration, regional application of soil health practices, and seed breeding/saving for climate adaptation, resilience and nutrition.
* Work cooperatively with other federal agencies including
* Establish and implement a consistent set of soil health indicators, in-field sampling methodology, lab calibration protocols and recommendations for the use of satellite observations, and other complementary, remote-sensing, real-time monitoring technologies, to support scaling new markets (like carbon and ecosystem services etc) in the
D. What data, tools, and research are needed for
* Direct USDA-ARS, ERS, to quantify the risk mitigation benefits of soil health practice adoption generally, but with specific attention to "de-risking" lending and insurance,/11,12 and support this work in the private sector through public-private research partnerships.
- Direct USDA-RMA to provide available field-level yield data to support the connection between soil health practices and yield stabilization
* Direct USDA-NRCS to revitalize the National Resources Inventory's Soil Monitoring Network, a national-scale network of sites sampled and analyzed periodically to track changes in soil properties (in conjunction with the
* Direct USDA-NRCS to update the existing Conservation Practice Standards for "Rotational Grazing" to reflect best practices in Planned Grazing. i.e. "Adaptive multi-paddock grazing"./14
* Direct USDA-NRCS to widely implement the "Soil Carbon Amendment" interim Conservation Practice Standard, Code 808, for organic amendments (specifically compost, biochar and mulch) to allow and encourage this soil carbon-enhancing practice in production agriculture and in research.
* Recognize soil health as a de-risking tool for FSA lending and RMA crop insurance, and pass on the savings these practices will net the agency in the form of better rates, terms, expanded access, technical support in implementation, etc, in order to efficiently encourage practice adoption and give upfront benefits to producers.
* Restore USDA-NRCS's historical role in providing on-farm technical assistance to producers, with a strong focus on building soil health and soil carbon, including providing and prioritizing training for ranchers to create a holistic management plan / healthy soils plan. These are needed tools to encourage adoption and will give producers access to new markets and incentives.
* Provide incentives for producers to apply soil health practices, including through expanded funding for
2. Biofuels, Wood and Other Bioproducts, and Renewable Energy Questions
A. How should
* Biofuels are currently an important market for US agriculture and when the commodities grown to produce the fuel are implementing soil health practices, this lowers the overall carbon footprint of those fuels, while increasing producer profitability.
- We encourage the agency to develop mechanisms that allow for lower emissions-producing farmers to have priority funding, greater visibility in the supply chain (such as voluntary registries and subsidized soil health/SOC/SOM testing) and increased marketing opportunities to capture incentives and increase profitability.
* It is broadly acknowledged that soil health practices lead to greater on farm profitability, by reducing reliance on expensive inputs, reducing water usage and providing resiliency; however in circumstances where critics point out the possibility of reduced yield, and the associated challenges of maintaining a stable US food supply (and the broader need of "feeding the world"), we encourage the agency to:
- Adopt a consistent stance that acknowledges that biofuels are using over a third of US Corn yields and over a quarter of Corn acreage and therefore view this acreage as "available/surplus" for food production.
- Develop language acknowledging this "available/surplus" acreage for food production when facing resistance to more profitable soil health practices for producers.
* Prioritize programs, funding and financing capacities for farmers and ranchers who are producing renewable energy alongside food, fiber and fuel that is managed with good soil health practices (with a specific emphasis on planned grazing) in order to increase the capacity of our nation's land and reduce conflicts surrounding land use.
3. Addressing Catastrophic Wildfire Questions
A. How should
* Recognize the risk-reduction impacts of soil health and conservation practices, and increase efforts to conduct soil health-based restoration and resilience projects on public land, including through use of planned grazing to control and reduce wildfire risk.
- S.1248 - the Outdoor Restoration Partnership Act of 2021, S.866 - the REPLANT Act, and H.R.803 - Protecting America's Wilderness and Public Lands Act, could be supportive to these efforts.
4. Environmental Justice and Disadvantaged Communities Questions
A. How can
* Develop frameworks and programs that recognize and quantify the risk mitigation value (i.e. the associated savings) of soil health practices, since risk-based incentives are accessible to all sizes of operations across a broad range of regions and soil types, and can include early practice adopters (thus addressing issues of equity and access with carbon and ecosystem services markets).
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This is a non-exhaustive set of policies and actions that can yield vital returns towards the
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Citations
1.
2.
3. USDA-NRCS, "Soil Health
4. "
5.
6.
7. Jillian M Deines et al, "Satellites reveal a small positive yield effect from conservation tillage across the US Corn Belt," Environmental Research Letters, 2019, https://iopscience.iop.org/article/10.1088/1748-9326/ab503b
8.
9. Daniel A Kane et al, "Soil organic matter protects US maize yields and lowers crop insurance payouts under drought,"
10. Land Core. "Language to
11. Land Core, "Building a Predictive Model of Risk",
12.
13. USDA-NRCS, "
14. Dr.
Additional References
Land Core's Soil Health Policy Recommendations to
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The notice can be viewed at: https://www.regulations.gov/document/USDA-2021-0003-0001
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