The following comment was sent to Deputy Chief, Science and Technology Noller Herbert and National Climate Coordinator Dana Ashford-Kornburger of the Natural Resources Conservation Service of the United States Department of Agriculture on March 15, 2024. 

Deputy Chief Herbert and Coordinator Ashford-Kornburger,

Thank you for the work you do in service of the United States’ farmers, ranchers, and eaters, as well as our soil and water resources. On behalf of the National Sustainable Agriculture Coalition (NSAC), I am writing to share our recommendations for additions to the list of Climate Smart Agriculture and Forestry (CSAF) practices. For nearly forty years, NSAC has advocated for sustainable ways of growing our food and fiber that not only benefit the land and water used in production, but also the farmers and farmworkers tasked with stewarding these resources. We believe NRCS has been, and should continue to be, an essential partner in these goals.

Thank you for adding the following practices and enhancements during the previous round of CSAF revisions:

• 317 Composting Facility
• 336 Soil Carbon Amendment
• E528N Improved grazing management through monitoring activities (Rangeland Health Assessment).

We also thank you for adding climate as a Natural Resource Concern. This is an important step in helping farmers mitigate and adapt to climate change across the country.

Over the course of this document, we recommend several changes to the list of CSAF activities that NRCS supports through Inflation Reduction Act (IRA) conservation funding and provide detailed rationale as to why we believe these modifications should be made. For your convenience, we have provided an abridged form of our proposed changes here:

Practices to be added:

• 316: Animal mortality facility (composting scenario only)
• 331: Contour orchards and other perennial crops
• 511: Forage harvest management
• 516: Livestock water pipeline (grazing scenario only)
• 555: Rock wall terrace
• 558: Roof runoff structure (excluding concentrated animal feeding operations)
• 588: Cross wind ridges
• 589C: Cross wind trap strips
• 595: Pest management conservation system
• 600: Terrace
• 633: Waste recycling
• 635: Vegetated treatment area
• 658: Wetland Creation
• 823: Organic management system

Enhancements to be added:

• E328H: Conservation crop rotation to reduce the concentration of salts
• E328I: Forage harvest to reduce water quality impacts by utilization of excess soil nutrients
• E340E: Use of soil health assessment for development of cover crop mix to improve soil health
• E511C: Forage testing for improved harvesting methods and hay quality
• E612A: Cropland conversion to trees or shrubs for long term improvement of water quality
• E612D: Adding food-producing trees and shrubs to existing plantings
• E612E: Cultural plantings
• E643A: Restoration of sensitive coastal vegetative communities
• E643B: Restoration and management of rare or declining habitat

Bundles should be added to CSAF all promotional materials.

Create additional bundles that address:

• Multi-story agroforestry
• Crop-livestock integration
• Soil health management strategies for conventional and organic agriculture that include CPS 336, soil carbon amendment.
• Advanced soil health systems that include practices both within and beyond the cropping area
• Advanced grazing systems

Practices to be revised:

• 590: Nutrient Management
• 595 Pest Management Conservation System
• 632: Waste separation facility (to exclude concentrated animal feeding operations)
• 643: Restoration of rare and declining natural communities (to apply beyond just floodplains)

Practices to be removed:

• 366: Anaerobic digester

Over the course of this document, we will provide deeper context as to why we believe these practices, enhancements, and bundles should be added or removed from the CSAF list, or potentially revised. We also include principles for inclusion, and discussion of climate impacts, as well as impacts on farmers, citing scientific literature where possible. Lastly, some recommendations not included in this cover sheet but included in the more in-depth recommendations are a renewed focus on certain CSAF activities that have the greatest net GHG mitigation and/or climate resilience potential.

To continue reading the full document, please download a PDF.