Center offers comment on climate-smart agriculture, forestry program

Environment
Farm and Food

With his administration focused on addressing climate change, President Joe Biden, as part of an executive order signed in January, requested that the U.S. Department of Agriculture (USDA) come up with a plan. In response, starting in May, USDA sought public comments on how their agency should respond. 

The agency has now proposed a climate-smart agriculture and forestry partnership initiative and recently requested comments on the approach and development of that program. 

Based on insight, experiences, and ideas gathered from across the rural areas we work in, the Center for Rural Affairs recently submitted the following letter to USDA: 

November 1, 2021

William Hohenstein
Director, Office of Energy and Environmental Policy
U.S. Department of Agriculture
1400 Independence Ave SW
Washington, DC 20250

Re: Center for Rural Affairs Response to Request for Public Comment on the Climate-Smart Agriculture and Forestry Partnership Program

The Center for Rural Affairs is a private non-profit organization that works to promote vibrant rural committees. We engage people in decisions that affect their community and the quality of their lives. This includes agriculture, climate change, and clean energy. Our comments are based on the feedback from producers, landowners, and other rural climate leaders.  

Climate-Smart Agriculture and Forestry

How would existing private sector and state compliance markets for carbon offsets be impacted from this potential federal program?

Existing private sector markets for carbon offsets would benefit from a federal program that provides guidelines and standards. In order to support and not duplicate efforts of the evolving private sector carbon market, a federal program should not facilitate transactions of carbon sequestration payments to producers. Instead, leaders of this proposed program should consult leaders and farmer participants in the private sector to identify needs and barriers to scaling up these efforts.

Producers need to feel secure and confident about the private market program they are entering. Federal guidelines on transparency, data security, and verification protocols will make significant progress in helping producers feel comfortable with the opportunity to receive financial incentives to implement additional conservation practices within their operations. 

To ensure the program supports private sector markets, USDA can provide data to ensure the verification of carbon being sequestered by individual climate-smart practices. This should be done via field trials across soil types and geographic regions. Standard data to reference no matter the program a producer enters will eliminate a current barrier to entry for many producers. 

In order to expand markets, what should the scope of the Climate-Smart Agriculture and Forestry Partnership Program be, including in terms of geography, scale, project focus, and project activities supported?

To successfully expand markets, the Climate-Smart Agriculture and Forestry Partnership Program needs to consider additional conservation practices beyond the management practices that are currently being incentivized. Cover crops and no-till are vital practices in sequestering carbon, but there are other practices of a structural nature that need to be implemented across the landscape. Extended crop rotation (also called conservation crop rotation), science-based trials of row crops integrated with prairie strips (STRIPS), wetlands, riparian buffers, and filter strips all do a tremendous job at sequestering carbon among other environmental services. Each of these practices are explained below. 

  • Extended Crop Rotation - Extending crop rotations are rotating crops past just a corn and bean rotation to 3-5 years and beyond with at least 2 years of incorporation of small grains, forages, and/or legumes. Not only are there on-farm soil health benefits to these additional crops, there is also economic vitality, resiliency, and carbon sequestration benefits to extended rotation.
     
  • Prairie STRIPS - The Science-based Trials of Row Crops Integrated with Prairie Strips (STRIPS) model from Iowa State University provides a unique opportunity for farmers to implement native vegetation along the counter or borders of their fields. STRIPS provide carbon sequestration, flood risk reduction, soil health, water quality, pollinator habitat, and wildlife habitat benefits. This practice converts less than 10% of a productive farmland field to native vegetation to receive a wide range of ecosystem benefits. 
     
  • Wetlands - Wetlands are a structural practice that are a natural part of many states’ historical landscapes. They provide many benefits to our environment, including water quality, wildlife habitat, and carbon sequestration. Locations for wetlands are considered marginal farmland and provide significant reductions in flood risk for the local watershed. 
     
  • Riparian buffers/Filter Strips - Vegetation in any form along a streambank, river bank, or drainage ditch is vital to our water quality and flood risk. This practice is implemented with a goal of protecting the streambank and the land adjacent to a waterbody with perennial vegetation, whether grasses or a mix of low-lying vegetation with trees. Practices include riparian buffers, filter strips, field borders, and others. 

In order to expand markets, what entities should be eligible to apply for funding through the Climate-Smart Agriculture and Forestry Partnership Program? Given that the administrative costs of the Climate-Smart Agriculture and Forestry Partnership Program could be high if USDA were to contract with individual producers or landowners, it makes more sense to work with groups of producers and landowners. 

Non-profit organizations that have existing relationships with producers and landowners can support the expansion of markets and provide technical support for climate initiatives. Organizations that have experience with and networks of diverse groups of producers, especially those underserved by existing programs, would ensure this proposed program reaches those groups. These organizations could utilize their existing education and outreach infrastructure, technical assistance expertise, and experience communicating with diverse groups of producers and landowners about incorporating conservation into their operations while maintaining agricultural production. 

How can USDA ensure that partnership projects are equitable and strive to include a wide range of landowners and producers?

In order to ensure small to mid-sized farms are included in this proposed program, USDA should require a certain percentage of carbon payments and other services to go to farms under the state’s average farm size. Making this requirement state-specific is important because small to mid-sized farms look different in every state. 

In addition, it is important to ensure that underserved producers and landowners have equal access to programs and services. This includes tribal, Latino, Black, young, beginning, veteran, and other populations of producers. Equal access to program services includes full translation of all materials, notices, and application materials for any funding programs in all languages. 

How can the Climate-Smart Agriculture and Forestry Partnership Program include early adopters of CSAF practices?

When designing this proposed program and the contracts involved, input from early adopters of CSAF practices should be sought. Their experience with practice implementation and management, financial incentives programs, and technical resources needed will provide program leaders with years of insight. 

By supporting producers and landowners who currently are or have used CSAF practices in the past, these producers will continue to implement these practices; and potentially increase the practices they implement in their operations. USDA’s current Conservation Stewardship Program (CSP) exists, in part, to reward existing CSAF-type practices. We recommend that information about these working lands conservation programs like CSP be shared with the early adopters as they look for additional benefits and support.