Land Core Submits Comments to Senate Agriculture Committee Hearing to Review The Growing Climate Solutions Act (GCSA) of 2020
On June 24, 2020 Land Core delivered the following written testimony to the United States Senate Committee on Agriculture, Nutrition, and Forestry: Hearing to Review The Growing Climate Solutions Act (GCSA) of 2020
Chairman Roberts, Ranking Member Stabenow, and Members of the Committee:
Thank you for the opportunity to submit written comments for today’s legislative hearing to review S. 3894, The Growing Climate Solutions Act (GCSA) of 2020. The Committee’s leadership on this topic sends an important signal to the agricultural community.
We applaud the introduction of this bill as a bipartisan effort that recognizes not only the enormous economic and environmental potential of improved land management, but also the vital role that the USDA can play in providing meaningful infrastructure to enable US farmers, ranchers and foresters to access private sector capital and empower new market development.
Land Core is an independent 501(c)3 organization with a mission to advance soil health policies and programs that create value for farmers, businesses and communities. Over the past four years, we have been working with Congress, the USDA, and other agricultural stakeholders to advance policy and programs directly related to the verification of soil carbon and soil health.
We wish to share two key issues that represent important opportunities and encourage the Committee to consider them:
1. Missing Infrastructure for Soil Carbon Sequestration Verification
Land Core strongly recommends considering language that empowers the USDA to finalize and issue baseline lab calibration standards and soil sampling protocols, based on the existing work that has been done at the USDA-NRCS Soil Health division.
Lab calibration and consistent soil sampling protocols are essential for the ground truthing of any future GCSA certification that hopes to unlock meaningful payments to US producers.
As it relates to soil carbon sequestration quantification, the ability to test and verify soil for its actual carbon content consistently all over the country is essential. Even as remote sensing, modeling and other tools and technologies evolve and emerge, we need to be able to verify outcomes if we want markets to trust the GCSA certifications and ensure the promise of this bill for US producers.
In order to quantify carbon in soils to assess value, consistent lab calibration is essential. Currently, sending the same soil sample to two different labs will yield two different results. Resolving this problem will be important in establishing a meaningful verification that markets and producers can rely on.
The same issue of consistency arises as it relates to the actual sampling of soils. If there is no consistent baseline process for the collection of samples, the resulting outcomes will not be consistent, which will also prevent a robust payment system from being developed.
Land Core has addressed the need for soil health outcomes verification previously to USDA in this 2019 Memo on the implementation of USDA-NRCS On-Farm Conservation Innovation Trials, and in report language championed by our organization in FY20 Appropriations.
These issues are acknowledged and understood at USDA-NRCS. The Soil Health division, in particular, has the solutions in place now to rectify the situation, but does not have the specific direction to prioritize this work, nor the minimal funding needed to increase bandwidth in order to implement the work.
Failing to include language prioritizing and funding the rollout of consistent calibration and sampling protocols in this bill would be a lost opportunity and unnecessary delay of the basic infrastructure that will be needed for the GCSA to be successful.
Additionally, establishing consistent calibration and sampling protocols will serve as critical infrastructure for academic, private sector and government initiatives that are working to create various forms of economic incentives for producers implementing practices that reduce greenhouse gas emissions or sequester carbon on working lands.
2. Transparency
Land Core suggests that the GCSA include language explicitly requiring that the aggregate data from all testing and certification from approved third parties be anonymized and made publicly available annually.
This will be essential not only for understanding the impact of the program and the state of US agriculture carbon sinks, but also for the future development of new research and technologies that will increase the long term success of the program.
Relying on reports to Congress, which do not specify field-level data and outcomes, would be a lost opportunity for both the development of science and technology and the market for soil carbon as a whole.
Submitted by:
Mr. Harley Cross
Co-Founder & Director of Strategy
Land Core, a 501(c)3 organization
1327 Willow St, Los Angeles CA 90013
+1-347-703-0860
www.landcore.org