The Biden administration’s approach to the climate crisis has been all-hands-on-deck. That means all departments and agencies, including the U.S. Department of Agriculture (USDA), are supposed to report to the White House on climate action steps. Last month, the USDA asked for ideas on how existing programs and new initiatives could respond to the climate crisis, and IATP and many others in the food and agriculture community weighed in.
The climate crisis has a particular urgency for farmers and rural residents. 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.
IATP’s comment focused on three areas: 1) expanding and improving programs that already are yielding climate benefits; 2) limiting or eliminating public supports for the climate-polluting factory farm system; 3) steering clear of false solutions like agriculture-based carbon offsets that help polluters, hurt environmental justice communities and don’t benefit the climate.
Expanding and improving conservation programs
The suite of conservation programs, from supporting specific practices to whole farm plans, offer opportunities for farmers to take immediate action. These programs, like the Conservation Stewardship Program and the Environmental Quality Incentives Program, prioritize practices that provide climate mitigation and adaptation benefits, such as 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. The Conservation Reserve Program (CRP) sets aside marginal farmland to protect biodiversity, wildlife, water quality, soil health and the climate. But CRP is currently at its lowest number of enrolled acres since 1988.
Farmers are very familiar with these conservation programs and regularly over-subscribe. In fact, demand for conservation on 13.8 million acres is denied regularly every year because of lack of funds. These programs are helpful for farmers seeking to access higher value markets (such as organic, grass-fed, animal welfare-focused) that pay premium prices, but also are better for the climate. We called for the USDA to explore administrative strategies (such as through the Commodity Credit Corporation) to increase resources for existing programs to make them accessible to more farmers, with special focus on historically disadvantaged communities and farmers of color.
We also recommended that the USDA incorporate climate risk within its insurance and credit programs. Crop and livestock insurance policies could be written, according to federal standards, to reduce premiums and increase indemnification payouts for farmers and ranchers complying with practices applied to reduce these sources of greenhouse gas emissions, and to those adopting climate-resilient practices such as crop diversification that reduce climate-related risks. The Farm Credit Administration should develop rules for the Farm Credit Service to incorporate climate resilience criteria into their lending and bond issuance requirements.
We also encouraged USDA to connect the dots between concentrated agriculture markets, where a handful of global corporations control most sectors, and responding to the climate crisis. Farmers are squeezed by a handful of companies that set costs and prices that farmers sell into. For example, the top four firms control 77% of cattle slaughter, 67% of pork packing and 80% of soybean crushing. We encouraged the USDA to: reinstate the Grain Inspection Packers and Stockyards Administration (GIPSA) as a stand-alone agency within USDA to enforce and improve regulations on meat and poultry companies’ conduct, as well as reinstate mandatory country of origin labeling for meat and expand it to include dairy products.
Stop public funding for high emitting factory farms
In several ways, the USDA props up a damaging factory farm system of animal and dairy production, which the EPA has identified as a major source of rising agriculture sector emissions. Emissions related to manure management have risen 66% since 1990, and the majority of this increase is due to the shift toward larger dairy cattle and swine CAFOs, according to the EPA. These factory farms rely on heavily fertilized feed grains and the storage and application of liquified manure, while undercutting small and medium-sized producers in the market. 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. 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.
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. At a minimum, USDA should require a full environmental review under the National Environmental Policy Act, including implications for the climate, for any FSA loans for new or expanding mid-sized CAFOs.
Don’t go down the carbon market road
USDA Secretary Vilsack has proposed to establish a carbon bank funded by public dollars through the Commodity Credit Corporation to purchase and potentially sell agriculture-based carbon offset credits. Carbon markets have routinely failed to reduce greenhouse gas emissions, and many farmers suffered losses when a voluntary offset market collapsed at the Chicago Climate Exchange in 2010. As a matter of science, the short-term sequestration of biogenic carbon cannot offset the climate impacts of long-term geological carbon emissions. Carbon markets create risks for farmers and effectively shut out many farmers, particularly those of smaller scale. Loopholes due to the non-regulation of these markets, including the use of offsets, have allowed harmful air pollution to continue, often in environmental justice communities that already suffer disproportionately from air pollution. IATP recommended the USDA not use public dollars and resources to support carbon emissions offset market initiatives, and instead deepen support for existing, successful conservation programs.
IATP also expressed its opposition to public investment in methane digesters that produce biogas or what we call “factory farm gas,” as a solution to the climate crisis. A full lifecycle analysis of CAFOs (including feed-related emissions) or their other negative impacts including water pollution, air pollution, loss of independent producers and the environmental justice implications for surrounding communities, highlights the enormous costs of this approach. Large-scale biogas projects also require a buildout of natural gas infrastructure including more pipelines. IATP recommended that public resources should not prop up the highly-polluting CAFO system; instead, that public money should be invested in a transition toward scale-appropriate, well-managed, pasture-based grazing systems.
The USDA also requested ideas on how its climate plans ensure equity for all farmers. IATP strongly endorsed the comments submitted by the Rural Coalition, which details numerous steps the USDA can take to ensure greater equity within its many programs, including to address the historical and structural racism within the USDA that has historically shaped many farm programs and their implementation. Additionally, IATP pointed out that USDA’s programs, such as EQIP, guaranteed loans and methane digestor subsidies, prop up a factory farm system that is adversely affecting environmental justice communities. And that a carbon bank initiative, which allows polluters to pay to pollute, also has major environmental justice implications.
The USDA will digest the many comments submitted and ultimately submit a climate strategy to President Biden. After four years of climate denial at USDA, the development of this strategy is a major step forward. But the direction and details of that strategy will tell the story of how big of a step.