The following comments were submitted to the U.S. Department of Agriculture Natural Resource Conservation Service on September 16, 2024 in response to a request for public input about the implementation of the SUSTAINS Act, Docket ID NRCS-2024-0014.
September 16, 2024
The Institute for Agriculture and Trade Policy (IATP) welcomes the opportunity to submit comments on the implementation of the SUSTAINS Act. IATP is a 37-year-old non-profit organization based in Minnesota working for fair and sustainable food, farm and trade systems. IATP has long advocated for conservation programs that improve the environment and climate, are accessible for all farmers, and serve the public interest.
We have serious concerns about potential conflicts of interests with the active participation of private interests in the use of conservation programs designed to serve the public interest. We’re concerned about private companies using public dollars and spending for their own gain, including through potential carbon offset schemes, or influencing state conservation priorities to support private interests. And we are concerned about potential legal risks and ownership questions in projects for farmers involved in projects with public and private contributors.
Below we answer specific questions asked by NRCS. Questions by NRCS are indicated in italics, and IATP’s response is in plain text.
Should USDA actively solicit the contribution of funds, and if so, how?
No. Soliciting the contribution of funds for NRCS programs leads to the perception that NRCS is engaging in a “pay-to-play” scheme. There already exist opportunities within NRCS to engage private dollars, through avenues such as match requirements for conservation activities through the Regional Conservation Partnership Program and other programs. In these situations, private organizations demonstrate their commitment to conservation by leading or co-leading conservation projects while reducing the financial burden on NRCS.
If NRCS actively solicits the contributions of funds, it would need to show that contributors would not have undue influence on decisions such as priority resource concerns, practices eligible for federal funding, or which applications are awarded funding. Even the perception that contributors have an outsized role in decisionmaking at NRCS would hamper the Service’s ability to serve the public. It could also lead to more unwanted scrutiny of NRCS operations. This would be true for a pilot project or a permanent program. Scrutiny could be highest in the event of conditional financial support from outside entities, but even unconditional financial support could lead to questions of conflicts of interest.
To continue reading, download a PDF of the full comments here.
