Edge's comments to USDA re: climate-smart ag program
Wednesday, November 3, 2021
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Posted by: Jamie Mara
November 1, 2021 The Honorable Thomas J. Vilsack
1400 Independence Ave, SW
Washington, D.C., 20250 Re: Climate-Smart Agriculture and Forestry Partnership Initiative: Request for Information [Docket Number USDA–2021–0010] Dear Secretary Vilsack, Edge Dairy Farmer Cooperative (Edge) is one of the top cooperatives in the country in terms of milk volume represented, with a large footprint in the Upper Midwest. We fulfill the requirements of the Federal Milk Marketing Orders as a verification cooperative for dairy farmers while also providing representation on federal policies that affect our members and collaborating with other agricultural stakeholders. We welcome the opportunity to comment on USDA’s request for information on the agency’s Climate-Smart Agriculture and Forestry strategy. Dairy farmers strive to be good neighbors and stewards of the land. They are also under increasing pressure to continuously improve and to quantify that progress. That is why Edge is actively supporting our farmer members involved in novel, voluntary sustainability projects. Our sister organization, Farmers for Sustainable Food (FSF), assists a growing number of farmer-led conservation groups in using consistent metrics to quantify environmental progress. FSF coordinates farm-level sustainability projects with key supply chain stakeholders to directly help farmers document their efforts by quantifying information that will help the supply chain meet goals. The Innovation Center for U.S. Dairy bestowed a national award for supply chain collaboration on one of our member groups, FSF and a supply chain partner for developing a first-of-its-kind Framework for Farm-Level Sustainability Projects and applying it in a pilot project in Wisconsin. We have offered our thoughts and recommendations below. 1. How would existing private sector and state compliance markets for carbon offsets be impacted from this potential federal program? No comment. 2. 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?
The scope of a Climate-Smart Agricultural and Forestry Partnership (CSAF) should be national, however its implementation should occur at a regional scale. While Farmers for Sustainable Food continues to grow in membership geographically, our member farmer-led conservation groups are currently regional. FSF has developed a framework for farm-level sustainability projects that we believe can be implemented anywhere in the nation, but the individual projects work best if they are done regionally, such as on the county level, within a watershed or a supply shed for a processor that buys the farm products. Local projects also allow farmers to communicate with their communities about the progress that is being made and how it is positively affecting residents. They provide the best opportunity to scale participation which can address regional priority resource concerns, aggregate credits, ensure the ability of small producers to participate and engage ag supply chain partners as buyers of climate smart credits. It is also important that farmers are able to work with trusted advisers, and geographically focused projects allow them to do this. FSF believes that our model of supporting these regional, individualized projects can be implemented on a large scale. We continue to grow our project numbers and move into new geographic areas. We believe project focus should be on verifiable environmental benefits, such as soil carbon levels and water quality. That being said, we believe it should be flexible. Different geographic areas require different focus. We recommend that the CSAF program be flexible enough to allow farmers and project partners the ability to determine the areas of importance to their businesses and community. We also recommend that supported activities should be limited to groups that demonstrate the ability to collect, aggregate and act upon the data. Projects should be required to use already existing tools that are credible for data collection, analysis and reporting, such as Field to Market’s FieldPrint Platform. Providing certainty around the acceptance of the methods and protocols (i.e., existing tools) is a critical role for USDA to play. This will show national and international stakeholders that generated outcomes are consistent and reliable. In the absence of this certainty, we believe the “Wild West” perception will persist. Simply put, USDA should identify and incentivize the ingredients of a successful CFSA and let farmers, NGOs and industry put those ingredients to work. Finally, we do not believe projects should be discriminated against based on size, as arbitrary limits could stifle USDA’s goal of furthering sustainability in agriculture. All farms large and small should be compensated in the same manner for implementing the same practices. 3. In order to expand markets, what types of CSAF project activities should be eligible for funding through the Climate-Smart Agriculture and Forestry Partnership Program? Projects should promote the production of climate-smart commodities and support adoption of CSAF practices. Activities eligible for funding should include a suite of items including 1) direct payments to producers, 2) technical and administrative assistance to a project sponsor, 3) protocols and standards including use of third-party entities such as Field to Market that use non-proprietary tools, 4) development or refinement of standardized metrics to assess outcomes. The program should be designed and implemented with a priority to assist farmers in data collection, analysis and understanding of outcomes. While FSF-supported farmer-led conservation groups have historically been funded by grants or local money, FSF would like to see member groups have a consistent stream of funds through our organization to allow them to focus on their mission rather than the constant need to identify funds to execute programming. With this in mind, FSF has developed an example of how groups could structure a program that funds the projects the organization is coordinating. FSF has already received one private grant for this purpose and intends to award funds to projects based on the following criteria: Tier 1: $2,500/year, available to projects that: The proposed structure above is financially responsible and allows projects to launch and continue without the constant need to apply for funding. There is great need for funding like this to increase rapidly in order to meet future need. Activities that assist in reducing the burden of grant-writing and reporting to produce a steady financing mechanism should be prioritized. It is important to emphasize that federal financial assistance is a key need for these projects to be able to scale because they often require outside expert support to assist farmers in data collection and analysis. Farmers are more likely to participate if they have the support of trusted advisers in gathering data, entering it in the appropriate tools and then providing guidance on the outputs. 4. In order to expand markets, what entities should be eligible to apply for funding through the Climate-Smart Agriculture and Forestry Partnership Program? We recommend that organizations like Farmers for Sustainable Food, a 501c3 non-profit organization with a variety of members. Individual farmers, farmer-led conservation groups and any organization that touches agriculture can join FSF and be able to apply for and receive program funding. Additionally, there is the option to join for anyone interested in FSF’s work but does not directly connect to agriculture. Individual farmers can join for $500/year, farmer-led watershed groups for $1,000/year, and all others connected to agriculture for $2,500/year (includes farmer cooperatives, dairy or other food processors, conservation groups directly supporting farmers, vendors or service providers, government agencies, universities or dairy and trade non-profits). Any individual or entity interested in agriculture and environmental stewardship that does not qualify to be a general member can join for $1,000/year as a non-voting member. Through this structure, FSF is directly connected with innovative, progressive farmers who are already focused on conservation work through their local conservation groups. Farmers who do not have a group like this in their area also join our effort in order to be connected to resources and to support the model for farmer-led sustainability work. This structure is effective for our group, and we believe organizations with this structure are well positioned to work with USDA on climate-smart initiatives. It is vital that funds are allocated to organizations that directly touch farmers in order to ensure work actually gets done on the farm. 5. In order to expand markets, what criteria should be used to evaluate project proposals for receiving funding through the Climate-Smart Agriculture and Forestry Partnership Program? We believe that the biggest barrier to farmers’ entry into these projects is the ability to provide them technical assistance. In our experience, project will not function properly unless farmers have expert help in collecting and analyzing data required for different programs to document sustainability. For example, FSF projects have required the support of environmental engineers to support project structure, data collection, analysis and reporting. There is also a need for local trusted advisers such as crop consultants, Extension agents or county conservationists to provide in-kind support to keep project costs manageable. However, those individuals are often already overcommitted and it is difficult to get free support. All funded proposals should clearly explain how farmers will receive expert support to make implementation as efficient as possible and ensue that value from the program is realized. Measuring outcomes should also be a priority to receive USDA funding. Our groups use nationally accepted metrics from Field to Market: The Alliance for Sustainable Agriculture to address on-farm sustainability indicators, such as greenhouse gas emissions and energy use. A non-proprietary tool called Prioritize, Target and Measure Application (PTMApp), is being used for measuring impact on watersheds. While environmental outcomes are important, it is also important to help farmers understand how these practices are affecting their bottom line. FSF’s pilot project incorporates a financial analysis component to help provide producers with the full picture of how these practices affect their businesses. This is another component that is vital but also requires funding for expert support, whether it is through local financial institutions, such as Farm Credit, or a technical college, for example. 6. In order to expand markets, which CSAF practices should be eligible for inclusion? Systems that have agreement from the entire ag/food value chain should be used to assess benefits of projects. For example, Field to Market’s Fieldprint Platform is a program that was created with input from the entire value chain for documenting sustainability of row crops. Systems should have national applicability with the ability to account for regional differences. Key metrics should be of value to both farmers and others in the supply chain so that farmers have something to use as a management tool on their farms and customers get information they want. Carbon and water quality are two examples. There is no need to invent a new method for quantification, monitoring, reporting and verification. Again, Field to Market can be used as an example for the entire supply chain agreeing on these methods and is a potential model for row crop assessment. Any system for all these tasks should be just that – one system – that is easy for farmers to access, use and receive help from trusted advisers to implement. The system used for quantification and reporting should also be able to document participation and potential benefits through modeling. 7. How should ownership of potential GHG benefits that may be generated be managed? Farmers should own their data and have the ability to decide who can access it through a platform. They should also get compensation for benefits they are generating in any areas that improve climate. Blockchain is a potential way to follow the benefits and ensure they are not double counted. 8. How can USDA ensure that partnership projects are equitable and strive to include a wide range of landowners and producers? Partnership projects should be pilot tested with farmers who are already engaging in sustainability work, before being launched to the general population. This would capitalize on an already-established commitment to innovation and leverage activities already under way, to expedite improvements and realization of program value. Farmers for Sustainable Food has direct connections to over 200 farmers engaged in conservation work and multiple projects taking place to document the impacts of these practices. These farmers are the early adopters in the region. The program can ensure benefits are provided to producers by allowing for funds to support projects to go directly to producer groups or the organizations that help them manage their efforts. There could also be compensation requirements from food companies/CPG. Summary Edge believes that USDA can play a role in incentivizing farmers to implement new practices that have potential to improve sustainability. In doing so, the agency should fund projects that are voluntary and farmer led. Focusing on technical assistance to farmers through trusted advisers is key. USDA should prioritize projects that demonstrate an ability to provide such assistance and can prove they are able to administer a reliable method for quantification, monitoring, reporting and verification. The agency also has a role to play in providing certainty around the acceptance of the methods and protocols, showing national and international stakeholders that generated outcomes are consistent and reliable. We believe regional and local groups of farmers voluntarily joining together to improve their communities is the most effective approach to sustainability and look forward to working with USDA to expand the adoption of such projects. Sincerely, Mykel Wedig
Associate Director of Government Affairs
Edge Dairy Farmer Cooperative
Email: mwedig@voiceofmilk.com
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