To read IATP's full comment to the USDA, please download a PDF of the comment. 

The Institute for Agriculture and Trade Policy (IATP) thanks the USDA for seeking input on the climate crisis, the most critical challenge of our time. IATP is a 35-year-old non-profit 501(c)3 organization based in Minneapolis, Minnesota. IATP works to ensure fair and sustainable food, farm and trade systems. For more than a decade, we have advocated for policies at the intersection of climate, agriculture and trade policy that reduce greenhouse gas (GHG) emissions while supporting and empowering farmers and rural communities to build resilience in the face of climate change.

IATP has worked on the ground with Minnesota rural communities to develop local climate action plans. We have advocated at the national level to integrate climate goals within the Farm Bill and financial regulation. We have pushed for reforms in United States trade policy to enable climate action. IATP has been an advocate at United Nations agencies, including the Committee on World Food Security, to advance agroecology as a solution to food security and climate challenges. And IATP has actively attended most of the United Nations Framework Convention on Climate Change (UNFCCC) Conference of the Parties over the last decade.

Major disruptions to our food system from the COVID-19 crisis and recent trade fights have made clear the fragility of our agriculture economy. These disruptions come on the heels of seven straight years of low prices (although prices have risen somewhat in recent months), often below the cost of production, and rising debt and farm bankruptcies. A series of antitrust and price-fixing investigations reveal a marketplace that is controlled by a handful of global companies to the detriment of farmers and consumers.

Farmers and rural residents are already on the front lines of the climate crisis. Extreme weather events have repeatedly damaged farms over the last 10 years — from the devastating drought of 2012, to a series of significant hurricanes hitting coastal farmers in the southeast, to major flooding in the Midwest and now emerging drought conditions hitting Western states. The climate science tells us that these types of events will strike with more frequency and severity, creating enormous challenges for farmers and anyone working within a natural resource-based economy.

Those in the margins, especially communities of color, are affected disproportionately by climate change.¹ Thus, climate policies need to reflect these socioeconomic as well as agroclimatic challenges and provide a path forward that reduces emissions, strengthens resilience and spurs a just transition towards a more equitable economy.

Though the USDA seeks public comment on how to encourage the voluntary adoption of climate-smart agricultural and forestry practices, the USDA does not clearly define what it means by “climate smart.” As we have pointed out in comments to USAID previously, “climate smart” is associated primarily with reductionist and technology-centered approaches.² We suggest USDA drop its use of the term and instead adopt more appropriate terms such as “climate resilient” to mean approaches that address the whole ecosystems, with focus on agroecological approaches as well as community and environmental resilience.

Below are IATP’s recommendations for how the USDA can improve existing programs, launch new initiatives, avoid getting side-tracked by carbon market schemes and ensure equity throughout its actions responding to the climate crisis. 

Q1 – How should USDA utilize programs, funding and financing capacities and other authorities to encourage the voluntary adoption of climate-smart agricultural and forestry practices on working farms, ranches and forest lands?

1. Leverage existing programs

Expanding and improving existing conservation programs is the most immediate, farmer-friendly approach toward building climate resilience in U.S. agriculture. Farmers are familiar with these programs, and regularly over-subscribe. Demand for conservation on 13.8 million acres is denied regularly every year because of lack of funds. The suite of conservation programs, from supporting practices to whole farm plans, offer opportunities for farmers to take immediate action. These programs prioritize practices that provide climate mitigation and adaptation benefits, like incorporating cover crops, perennial crops and managed grazing of perennial pasture. They place an emphasis on building soil health, which has stacking benefits not only for climate resilience but also by increasing organic matter, improving soil fertility, reducing erosion, and improving water quality and infiltration.

Conservation programs should also be viewed as tools to help farmers access higher value markets, such as those that pay premium prices, but also are better for the climate. Such premium, climate-friendly markets, include certified organic, grass-fed, animal welfare and those focused on local food systems. Conservation programs can serve as an on-ramp for farmers interested in making changes to their operations to access these higher value markets.³

An important starting point for USDA would be to establish Climate Mitigation and Resilience as a Resource Concern throughout Natural Resource Conservation Service (NRCS) conservation programs, a nationwide Priority Resource Concern for the Conservation Stewardship Program (CSP), a top priority throughout USDA intramural (ARS) and extramural (NIFA) research programs, and an actuarial factor in RMA crop insurance programs. Beyond this step, we highlight a few more specific reforms.

Expand and improve the Conservation Stewardship Program (CSP)

CSP is the largest conservation program in the U.S. It is a voluntary working lands program that encourages producers to address natural resource concerns through conservation activities. From a climate perspective, CSP’s strengths are: (1) its whole-farm approach ensures that the net greenhouse gas footprint of the entire farm or ranch, not just a small part, is considered in determining climate-related incentives; (2) it provides rewards for both existing and new conservation practices, ensuring that “early adopters” are rewarded; (3) it is accessible for farmers of all sizes and types, making it potentially valuable for smaller-scale, beginning farmers and Black, Indigenous, Latinx and other farmers of color (suggestions on expanding access below); and (4) it was designed to foster continuous improvement in conservation systems, which will be needed for farmers as they respond to the climate crisis.

CSP’s whole farm approach supports systems that boost soil health, which improves a farm’s ability to withstand droughts and floods, reduces the need for synthetic inputs and results in carbon sequestration. Practices supported by CSP include planting cover crops, diversifying crop rotations, decreasing tillage and implementing management-intensive rotational grazing. These practices must be incentivized to reduce agriculture’s ecological footprint — including on the climate, water and biodiversity — and to make producers more resilient in the face of climate disruptions.

The USDA could strengthen CSP by restoring organic enhancements (organic systems have proven climate benefits) and addressing the low payment rates for certain climate-resilient practices under CSP, such as cover crops, resource conserving crop rotations and advanced grazing management. Additionally, farmers who implement conservation practices and enhancements in line with NRCS standards should not conflict with RMA rules as a result. Conservation is a key element of risk management and RMA rules and policies should incorporate this understanding. 

The 2014 and 2018 Farm Bills cut CSP funding nearly in half, greatly restricting both farmer access and environmental improvement. Currently, farmer demand for the program far exceeds the supply of funds, and interest in conservation programs has been steadily growing. USDA should explore administrative strategies (such as through the Commodity Credit Corporation) to increase resources for the CSP program to make it accessible to more farmers, with special focus on historically disadvantaged communities and other farmers of color.

Reform the Environmental Quality Incentives Program (EQIP) to stop subsidizing CAFOs

We must transition away from investing public resources in the damaging Concentrated Animal Feeding Operation (CAFO) system of animal production and instead invest in more climate-friendly livestock production systems. CAFOs rely on often below-cost of production feedgrains produced on large-scale row crop operations that use highly emitting synthetic fertilizers and pesticides. CAFOs liquefy animal waste and store it in manure lagoons that generate large amounts of methane.⁴ They also produce more waste than the surrounding cropland can support as fertilizer. The excess manure is often overapplied to surrounding cropland, which can result in substantial nitrous oxide emissions.⁵ CAFOs are driving the overproduction of meat and dairy, which in turn is contributing to low prices and the loss of small and medium size independent producers.

EQIP was designed to provide cost-share and incentive payments to farmers to address natural resource concerns on their farms, and it has been used by hundreds of thousands of farmers nationwide to make environmental improvements that benefit the land, family farm operations and their communities. Unfortunately, the 2002 Farm Bill revised EQIP to allow CAFOs to access the program’s funding. We must invest all EQIP funding as the program originally intended: to support small and mid-sized family farm operations as they implement conservation practices. USDA should reallocate the 50% of EQIP funding for livestock production to support more sustainable pasture-based livestock, dairy and poultry operations by providing technical assistance, outreach and more robust payments to producers seeking to initiate, improve or transition to grass-based operations. Advanced grazing systems, particularly management intensive rotational grazing, can reduce water pollution,⁶ reduce the amount of methane produced by each animal⁷ and can sequester carbon.^{8 9} 

Reform the EQIP and CSP programs to include a wider range of practices informed by traditional ecological knowledge and indigenous agriculture knowledge

Here, we support comments submitted to USDA by the Rural Coalition, which state: “These should include support for practices as well as new uses of the conservation reserve program that promote the continuous planting, saving, selecting and sorting of seeds over decades to assure they adapt to changing conditions. Set asides should be expanded to include tribal run projects and projects developed by traditional communities focused on increasing the ability of seeds and breeds to adapt to changing conditions. At the same time, USDA should consult with Tribal government and BIPOC communities to institute essential measures to protect the rights of tribal and other communities to retain control of these seeds and breeds.”

Reform FSA loans to stop backing new and expanding CAFOs

Many CAFOs around the country would not exist without Farm Service Agency (FSA) guaranteed loan support. Loans supporting CAFOs have come at the expense of support for independent farmers and ranchers who are protecting rural waterways, air and the climate. USDA should explore approaches to limit or prohibit issuance of any direct or guaranteed farm ownership or operating loans for the construction or expansion of a specialized hog or poultry production facility, as well as the issuance of direct or guaranteed loans to foreign-owned or controlled CAFO operations.

In addition, providing a full accounting of possible environmental risks, including potential climate, water and air impacts, should be a minimum standard before any public resources are invested in a project. In August 2016, FSA quietly announced it would no longer require an environmental review under the National Environmental Protection Act (NEPA) prior to the approval of loans for mid-sized CAFOs. Nor would neighboring farmers, rural residents or local government officials have notice that such an operation was being built until construction had begun. The agency gave no reasoned justification for the decision despite the increase in methane emissions and multiple harms to adjacent neighbors. The Agency’s ruling is currently the subject of a legal challenge.¹⁰ At a minimum, USDA should require a full environmental review under NEPA, including implications for the climate, for any FSA loans for new or expanding mid-sized CAFOs.

Expand the Conservation Reserve Program

U.S. agriculture has a commodity crop overproduction problem, which routinely drives prices down for farmers and has pushed production onto marginal farmland. The Conservation Reserve Program (CRP) is an important tool for protecting biodiversity, wildlife, water quality, soil health and the climate. Under the Farm Bill, CRP is capped at 25 million acres nationwide (increasing to 27 million in 2023), but it currently only has 20 million acres enrolled. That is the lowest number of acres enrolled since 1988.¹¹

We support the April 21 action by USDA to increase payments and incentives for farmers with a goal to enroll 4 million new acres in CRP and ultimate meet the cap set in the most recent Farm Bill.¹² We urge USDA to advocate through Congress to dramatically expand that cap in the next Farm Bill.   

We also strongly encourage the Farm Service Agency (FSA) to expand the role of CRP, including its Grasslands Initiative, to explicitly support climate goals. FSA could support highly effective climate-mitigating practices, such as forested riparian buffers and improved range and pasture, by using the Clean Lakes, Estuaries, and Rivers (CLEAR) initiative, the Conservation Reserve Enhancement Programs (CREP), and the Grasslands Initiative to their full and complete potential. USDA could also create and pilot a new agroforestry initiative within CRP to encourage transition to perennial production systems.

Strengthen competition rules and enforcement

There is evidence that excess corporate control over the U.S. food and agriculture system hurts our ability to respond to the climate crisis. University of Missouri Rural Sociologist Mary Hendrickson finds,¹³ “Our highly concentrated global food system has resulted from horizontal and vertical integration in food system sectors and globalization of agricultural and food markets. This system constrains farmers (and others) in making choices that can fend off likely ecological and social disruptions while limiting their ability to accommodate change. It has eliminated smaller farms and businesses that provided a redundancy of role and function, resulting in few fail-safe mechanisms for the food system. A focus on efficiency, standardization, and specialization has decreased the diversity of scale, form, and organization across the food system.”

The agriculture sector is among the most concentrated of all economic sectors, with a handful of often global corporations controlling most aspects of the industry. Only a few firms control almost all the supplies farmers buy such as seeds, fertilizer and farm equipment, raising prices and reducing their choices. Recent seed and fertilizer company mergers threaten to further raise operating costs for farmers. At the same time, farmers sell into very concentrated markets where four firms often control the market, pushing down prices farmers receive for crops and livestock. For example, the top four firms control 86% of corn processing, 85% of cattle slaughter, 71% of pork packing and 79% of soybean crushing.¹⁴

The limits of concentrated markets played out in the summer of 2019 when farmers experienced shortages in seeds for cover crops following the extreme Midwest flooding that limited the planting of conventional crops.¹⁵ A recent analysis of 89 studies found that perennials and cover crops improve the ability of soils to soak up extreme rainfalls, which is critical to withstanding floods and droughts.¹⁶ Small grain breeders and independent seed companies are trying to fill this gap left by the three global seed companies that dominate the U.S. agriculture markets – Bayer/Monsanto, Dow/DuPont and Syngenta/ChemChina. In addition to limiting seed variety options, the lack of competition in the U.S. seed market has led to higher seed prices for farmers.¹⁷

We encourage the USDA to assess the impact corporate consolidation and a loss of competition has on farmers, workers, consumers, rural communities and the climate, and consider actions that can restore competition that supports climate resilience in our food system. Some immediate actions the USDA should take include:

• Immediately reinstating the Grain Inspection Packers and Stockyards Administration (GIPSA) as a stand-alone agency within USDA. A restored GIPSA must also act to enforce and improve regulations on meat and poultry companies’ conduct.
• Immediately withdrawing the 2020 version of the Farmer Fair Practices Rules. Use the 2016 version of the Farmer Fair Practices Rules as the starting point for a new rulemaking process (based on the 2008 Farm Bill).
• Closing loopholes in the regulations for voluntary country of origin labels to require that meat displaying a U.S. label actually comes from animals that were born, raised and slaughtered in the U.S. and working with Congress to reinstate mandatory country of origin labeling for meat and expand it to include dairy products.

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