Mo. Coalition for the Environment Issues Public Comment on USDA Notice
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MCE is a member of the
Climate-Smart Agriculture and Forestry
Utilization of
Leveraging existing policies and programs
Remove Concentrated Animal Feeding Operations as eligible for EQIP funding. Use that funding to prioritize specialty crop producers and pasture-raised livestock producers through EQIP and CSP. Without stronger safeguards, conservation funding further entrenches CAFOs and their harmful environmental and public health externalities and allows them to persist at the expense of climate-friendly alternatives.
Reform internal policies regarding FSA loans to limit FSA loans to CAFOs to only one CAFO allowed per county and phase out FSA loans for CAFOs by 2025.
Give priority to all loan applicants of any FSA loan program that indicate their use of climate-smart agricultural practices, including rotational grazing, mob grazing, interplanting, silvopasture and permaculture practices, etc.
Prioritize applicants for EQIP and CSP that incorporate climate-smart agricultural and forestry practices.
Reform commodity payments and crop insurance to require use of cover crops in order to receive payments. Significantly decrease funding for the commodity and crop insurance titles in the next Farm Bill and shift that funding to the Horticulture, Miscellaneous, Forestry, and Conservation titles. This decrease in funding would be alongside forgiving loans of CAFO operators if they agree to transition to climate-smart, pasture-raised grazing animal livestock and/or climate-smart crop production. This decrease in funding would also coincide with changes to the USDA Nutrition Guidelines to inform consumers about the health and climate harms of animal agriculture and encourage consumption of plant-based proteins (that would be priorities through climate-smart practices at the same time).
Ensure all BFRDP outreach roles are filled in local offices and filled by someone who only has this outreach role responsibility, not doing this work on top of other FSA responsibilities. Individuals in this position should provide technical assistance to SDAs in adopting climate-smart agricultural and forestry practices.
Implementing new strategies to encourage voluntary adoption of climate-smart agriculture and forestry practices
Forgive government debt used to adopt non-climate smart practices or purchase equipment that supports non-climate smart practices conditioned upon the debtee illustrating a plan to implement climate smart practices. Designate FSA staff to enforce this condition on the loan forgiveness and provide support to those seeking to transition to climate-smart practices.
Collaboration between
Increase outreach to local governments and state and local organizations working with farmers to share that these stakeholders should direct farmers to
Encouragement of voluntary adoption of climate-smart agricultural and forestry practices in an efficient way, where the benefits accrue to producers
Conduct outreach and education to non-commodity producers about the programs that support farmers in developing climate-smart agricultural and forestry practices and provide direct support to these producers to complete their applications for these programs. If we want to see adoption of climate-smart agricultural and forestry practices,
Summary of Additional Recommendations for Climate-Smart Agriculture and Forestry
1. Revise the Conservation Stewardship Program (CSP) Final Rule to enable it to be a premier climate mitigation and adaptation program.
2. Establish Climate Mitigation and Resilience as a Resource Concern throughout NRCS conservation programs, a nationwide Priority Resource Concern for the Conservation Stewardship Program (CSP), a top priority throughout
3. Establish a Department-wide goal and timeframe for
4. Improve payment rates for climate-friendly conservation practices and fund projects that develop and expand market opportunities for small grains, cover crops, and forages to incentivize adoption.
5. Allow for greater economic use for the cover crop conservation practice and all of the cover crop conservation enhancements under federal conservation programs.
6. Update cover crop termination guidance for clarity and flexibility.
7. Modify the Good Farming Practices definition and handbook to clarify that all NRCS conservation practices and standards are Good Farming Practices (GFP) without exception or caveat.
8. Support advanced grazing management systems, including management-intensive rotational grazing (MIRG), through federal working lands conservation programs.
9. Stop offering payments to new or expanding concentrated animal feeding operations (CAFOs).
10. Increase
11. Create a coordinated five-year strategic plan for organic research at the
12. Establish an agency-wide priority to support the widespread adoption of resource-conserving and climate-friendly organic systems through adequate and appropriate technical assistance and nationwide access to relevant conservation activities under federal conservation programs.
13. Fund the development of farmer-ready cultivars and breeding networks for a changing climate
14. Increase research that engages farmers, ranchers, and stakeholders in perennial production systems and incentivize widespread adoption of these production systems.
15. Increase support for composting as a climate-friendly alternative to landfill and manure lagoon disposal of organic residues.
16. Improve the Interim Conservation Practice Standard (CPS) 808 Soil Carbon Amendment and make it a national and permanent practice standard as soon as possible.
17. Establish a Monitoring, Evaluation, and Reporting Initiative to create outcomes-verified data and metrics needed for tax credits, supply chain initiatives, and carbon trading.
18. Increase support for small- and mid-sized slaughter and processing capacity to build resilience and increase markets for pasture-raised livestock.
19. Include climate and agriculture-focused investments in
Biofuels, Wood and Other Bioproducts, and Renewable Energy
Utilization of programs, funding and financing capacities and other authorities to encourage greater use of biofuels for transportation, sustainable bioproducts (including wood products), and renewable energy
Increase the focus of EQIP, CSP, and the Regional Conservation Partnership Program (RCPP) on climate change mitigation, energy conservation, and renewable energy production.
Conduct a full lifecycle analysis on the utilization of plant biomass for biofuel production to evaluate net greenhouse gas footprint impacts as well as impacts on soil health, water quality, native plant communities, biodiversity, and wildlife. Do not prioritize greater use of biofuels. It puts pressure on farmers to farm marginal land in order to maximize their production. We need to be producing more fruits and vegetables to serve local and regional markets on our nation's farms, transitioning our farmland away from predominantly producing grain crops that get shipped across the country and even across the world to make processed food, livestock feed, and biofuels.
Advance renewable energy produced and used on farm (wind, solar, and on-farm use) to lower costs and improve resilience of farms. Educate farmers about the resources available to them to generate wind and solar renewable energy sources on their lands and should increase funding in the next Farm Bill to help farmers purchase such equipment and connect to the nation's electricity grids.
Many existing conservation, research, and rural development programs can be readily improved to encourage the voluntary adoption of climate-friendly agricultural and forestry practices on working farms, ranches, and forest lands. We urge
Adoption and production of other renewable energy technologies in rural America
Addressing Catastrophic Wildfire
Utilization of programs, funding and financing capacities, and other authorities to decrease wildfire risk fueled by climate change
Expand NRCS financial and technical assistance in management of woody biomass and wildfire risk for farmers, ranchers, and landowners in wildfire-prone regions.
When determining whether to approve federal actions, such as FSA loans, through an environmental impact statement or environmental assessment,
Environmental Justice and Disadvantaged Communities
Utilization of programs, funding and financing capacities, and other authorities to advance climate-smart agriculture and forestry practices by all landowners, producers, and communities
Conduct outreach and education to non-commodity producers about the programs that support farmers in developing climate-smart agricultural and forestry practices and provide direct support to these producers to complete their applications for these programs. If we want to see adoption of climate-smart agricultural and forestry practices,
Technical assistance, outreach, and other assistance to ensure that all producers, landowners, and communities can participate in
Equitable implementation of programs, funding and financing capabilities, and other authorities related to climate-smart agriculture and forestry practices
Enter into cooperative agreements in every state with local and regional organizations that work directly with landowners so that those organizations can do the outreach to farmers about the
Ensure historically underserved farmers and ranchers, including beginning, socially disadvantaged, military veteran and limited-resource farmers and ranchers, are fully supported and empowered in their climate resilience and mitigation efforts.
Specifically, MCE urges
1. Improve outreach and service delivery to farmers and ranchers of color and other historically underserved producers, including technical assistance with conservation planning and program application, and informing eligible producers about the EQIP advance payment option and about set asides in CSP and EQIP for socially disadvantaged and beginning farmers and ranchers;
2. Invest in programs such as the ATTRA Sustainable Agriculture Program whose mission specifically serves historically underserved producers and communities to build resilience and contribute to climate solutions;
3. Study and issue a report on the impact of EQIP funding of CAFOs on surrounding communities, which are often communities of color;
4. Study and issue a report on the impacts of intensified heat stress and increased pesticide use on the health and safety of farmworkers and develop recommendations for mitigating these impacts and improving the health and resilience of farmworkers and their communities;
5. Create new RCPP Critical Conservation Areas to cover significant gaps in geographic regions where many small scale farmers of color operate;
6. Ensure program eligibility rules do not exclude or pose barriers to tenant farmers who wish to participate in conservation programs, and payment structures that ensure tenants, not the cash landlords, collect the payments and other program cost shares;
7. Conduct and share transparent data collection on rates of farmers of color application and enrollment in all
8. Commit to at least doubling funding available for conservation programs and projects serving underserved communities - including farmers of color, women, urban, immigrant, and refugee farmers, as well as farmworkers and military veterans;
9. Design and implement all climate-mitigation and climate-resilience provisions within conservation programs and across mission areas so that they actively dismantle historical racism and thereby protect public health and food security, preserve natural resources, and provide environmental and climate justice for communities of color and other disproportionately impacted communities; and
10. Provide targeted technical assistance to help producers and communities of color and other historically underserved populations mitigate and adapt to the impacts of weather extremes and climate disruption through participation in conservation programs like CSP and EQIP, farmer-centered research and education through programs like SARE, and local food systems through LAMP and other local food and urban agriculture programs.
Thank you for the opportunity to present these comments on the Executive Order on Tackling the Climate Crisis at Home and Abroad. If you have any questions about the information presented above or if you would like to discuss MCE's comments further, please do not hesitate to reach out at the contact information below.
Sincerely,
Food and Farm Policy Director
314-727-0600 Ext. 111
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The notice can be viewed at: https://www.regulations.gov/document/USDA-2021-0003-0001
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