by
The Center for Biological Diversity
Silvia Secchi, Professor, Dept. of Geographical and Sustainability Sci., University of Iowa
The following petition was sent on July 10, 2024 to USDA Secretary Tom Vilsack.
Dear Secretary Vilsack,
Pursuant to the First Amendment of the U.S. Constitution,1 5 U.S.C. § 553(e),2 and 7 C.F.R. § 1.28,3 the Center for Biological Diversity, Silvia Secchi, and the Institute for Agriculture and Trade Policy (together Petitioners) hereby submit this petition for Partnerships for Climate-Smart Commodities rules and regulations.
Petitioners request that the U.S. Department of Agriculture (USDA) promptly, or within six months, initiate a rulemaking process to: 1) define what data must be collected and reported on “climate-smart” projects financed under the Partnerships for Climate-Smart Commodities program (Partnerships), describe how data collection and reporting obligations have changed since the program was developed in February 2022, and request comments from the public on what data should be collected and made publicly available as a term of receiving funding through the program; and 2) create regulatory methodology to be used by USDA in selecting “climate-smart” projects under the program and determining their effectiveness over the short and long terms in reducing agricultural emissions.4 To inform this rulemaking process, Petitioners further request that USDA generate as a part of the administrative record a progress report detailing climate-smart funding to date, analyzing best practices and learnings emerging from the program, and explaining how the program is meeting USDA’s expressed goals, as further described in this petition for rulemaking. This rulemaking can be developed under the authority of the Commodity Credit Corporation Charter Act of 1933, 15 U.S.C. 714 Section 4(d).
Petitioners are “interested person[s]” under 5 U.S.C. § 553(e) (APA requirements) and 7 C.F.R. § 1.28 (USDA requirements) and seek issuance and amendment of certain rules to make them consistent with American values, science, and with all relevant legal authorities and policies.5
Thank you for your critical work to confront the climate chaos that threatens America’s farmers, public safety, food security, and wildlife; we hope to be partners in achieving that goal.
To continue reading the petition, download a PDF.
