Land Core Submits Comments to House Agriculture Committee Hearing to Review the Growing Climate Solutions Act (GCSA) of 2021
September 23, 2021
The Honorable David Scott, Chairman, House Agriculture Committee
The Honorable G.T. Thompson, Ranking Member, House Agriculture Committee
Chairman Scott, Ranking Member Thompson, and Members of the Committee:
Thank you for the opportunity to submit written comments for today’s legislative hearing on “Voluntary Carbon Markets in Agriculture and Forestry”, to review S.1251/H.R.2820, the Growing Climate Solutions Act (GCSA) of 2021. The Committee’s leadership on this topic sends an important signal to the agricultural community.
The reintroduction and advancement of this bill is a bipartisan effort that recognizes not only the enormous economic and environmental potential of improved land management, but also the vital role that USDA can play in providing meaningful infrastructure to enable US farmers, ranchers and foresters to access private sector capital and empower new market development.
The GCSA sets the stage to harness this massive opportunity, but as written, has the possibility of missing the mark by focusing on a reductionist approach that overemphasizes carbon, rather than addressing a broader ecosystem services market approach.
“Environmental markets” are, as described in the bill, essentially “carbon markets”. This not only focuses narrowly on one element in a complex biological system, it also limits the potential of the GCSA to facilitate just one kind of emerging market. This is an unnecessary limiting of the potential impact of the program to achieve its goal of helping producers and businesses connect and meet each other's needs and build economic opportunities.
As just one example, the significant water-related services that soil health and climate-smart agriculture provide (such as improved water quality and water infiltration that reduce the risks of flood and drought) have very tangible value and markets that could be leveraged.
There is an active need for standardization of monitoring, reporting and verification (MRV) and paths to access for all ecosystem services (including carbon) markets. All of the infrastructure that is needed to build a complex MRV system for carbon (often the most difficult element to quantify) is largely the same infrastructure that would be needed to verify soil health and water-related ecosystem services. Failing to develop this system to support all ecosystem services markets would be a missed opportunity.
This singular focus on carbon also undervalues the technical service providers outlined in the bill, by limiting their scope and potential to assist in a broader and more impactful relationship with their farmer clients.
We also note that the use of “carbon” throughout the bill must include Soil Organic Carbon (SOC) or Soil Organic Matter (SOM), to distinguish between these biological forms of carbon sequestered in soils, and carbon dioxide. This is an important distinction, because the terms inform the competencies required of the Greenhouse Gas Technical Assistance Providers. In the current articulation of this bill, there is practically no mention of biology or agroecology implied as being required among these competencies. There are serious unintended consequences that could result from pursuing a chemistry-focused approach to advancing the biological process of soil carbon sequestration.
Implementing soil health management practices is the way in which we build SOC or SOM in agricultural soils. This is not only one of the fastest, most affordable and most scalable opportunities to remove carbon dioxide from the atmosphere, but it can also help agricultural producers improve farm resilience (especially related to flood and drought mitigation), increase water infiltration and quality, increase on-farm profitability, rebuild eroding topsoil, and ensure national food security, among other benefits. It is worth remembering these additional benefits hold real value and create the opportunity for an array of markets (current and future) that can reward US producers.
We wish to outline some key recommendations for the Committee to consider to address the issues we have outlined above and to accelerate the impact of the GCSA’s goals.
Specific Recommendations for Amended Language in the GCSA (S.1251):
Change all references of “Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Certification Program” to “Greenhouse Gas and Ecosystem Services Technical Assistance Provider and Third-Party Verifier Certification Program”.
Change all references of “voluntary environmental credit market” to “voluntary environmental credit and ecosystem services market”.
Change all references of “Carbon” to “Soil Organic Carbon (SOC) and Soil Organic Matter (SOM)”.
Change all references of “prevent, reduce, or mitigate greenhouse gas emissions or sequester carbon” to “prevent, reduce, or mitigate greenhouse gas emissions or sequester carbon, or improve soil health, water infiltration or water holding capacity, water quality, and/or biodiversity”.
In Section 2(d)(1)(A), the Protocols and Qualifications, specify “lab calibration”.
In Section 2(d)(3)(A), related to requirements for covered entities to certify under the Program, add agroecology and biology.
In Section 2(f)(1), Prohibition on Claims, increase penalties limits for making false claims and perpetrating fraud to $10,000.
In Section 2(g), require the Advisory Council to be made up of equal parts scientific (with a focus on agroecology and biology), farmer, government/NGO, and business/agribusiness expertise. Prioritize non-academic participants who have relevant experience working with carbon and ecosystem services markets.
Broader Recommendations for a Viable Soil Carbon and Ecosystem Services Market
If USDA does advance climate-smart agriculture through supporting private markets or use of the Commodity Credit Corporation, as outlined above, it should support markets that take a more holistic approach and pay farmers for broader ecosystem services while foregrounding justice and equity concerns. Payment for ecosystem services can support small, minority, and underserved farmers in regenerating degraded land, protecting watersheds and supporting rural prosperity, with carbon sequestration being a co-benefit. In addition to the specific language offered above, USDA should take the following broader considerations into account:
Value carbon sequestration as a co-benefit - it is necessary to also account for holistic benefits of soil health, including ecosystem services, regeneration of degraded land, and watershed protection.
Ensure outcomes include a range of “healthy ecosystem” indicators, including soil organic matter, water infiltration, and biodiversity, and do not only focus on soil carbon.
Invest in satellite technology and monitoring to improve verification on smaller farms/acreage (this allows for continued innovation and successes across regions and diverse farming/ranching systems to become examples of how to most effectively regenerate landscape function).
Build missing infrastructure for land or soil carbon sequestration verification, and ensure that the process of measurement and verification development is robust, guided by science, and not skewed by the interests of third-parties.
Establish clear, consistent guidelines for testing, including specific (soil health) indicators, in-field sampling and lab calibration protocols.
Consider language that empowers 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 ground-truthing of any future GCSA certification that hopes to unlock meaningful payments to US producers.Currently, sending the same soil sample to two different labs will ensure two different results, and we don't see how one can establish a meaningful verification that markets and producers can rely on if this problem is not resolved.
As it relates to land or soil carbon sequestration quantification, testing and verifying the 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 these outcomes if we want markets to trust the GCSA certifications and ensure the promise of this bill for US producers.
The same issue of consistency arises as it relates to the actual sampling of the soils. If there is no consistent baseline process for the collection of the samples, the resulting outcomes will not be consistent, and again no robust payment system will be able to be developed.
Make use of NRCS “Soil Health Principles”, specifically building on the “NRCS TN-450-TCH-3 Recommended Soil Health Indicators and Associated Laboratory Procedures” to set an agency standard for “minimum viable soil health indicator set”, in-field collection sampling methodology, and lab calibration protocols, to ensure the consistency of soil health testing for those labs.
Land Core has addressed these issues previously to USDA in this 2019 Memo, and in report language championed by our organization in FY20 Appropriations.
These are all issues 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 now will serve as critical infrastructure for academic, private sector and government initiatives that are working to create other kinds of economic incentives for producers implementing practices that reduce greenhouse gas emissions or sequester carbon on working lands.
Provide substantial and unprecedented levels of technical assistance and educational support (with a focus on the biological systems that build soil health and ecosystem services) to ensure farmers’ efforts are successful, and partner with state and regional groups to help achieve this.
Participants may, but are not required to, receive technical or financial assistance via EQIP contracts or other USDA programs in order to qualify for participation in this program.
Given the continuing evolution of both technology and our understanding of soil health science, specific protocols, methodologies, and any internal standards should be reassessed biannually to ensure best practices are updated.
Ensure Transparency
We additionally suggest that the GCSA include language that explicitly makes 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 agricultural carbon sinks, but also important for the future development of new research and technologies that will increase the long-term success of the program.
Relying on reports to Congress that don’t specify access to field-level data and outcomes will be a lost opportunity for both the development of science and technology and the market for soil carbon as a whole.
Following these guidelines, developed in consultation with several other organizations, would help voluntary environmental and ecosystem services markets achieve their intended goals and help farmers build resilience and lead in addressing climate change. At the same time, Congress must support the full suite of incentives and infrastructure required for farmers to transition to climate-smart, regenerative agriculture. This includes, but is not limited to, leveraging risk markets (see our memo “Soil health to de-risk lending and insurance: a pathway to carbon markets”) and exponentially scaling up funding for existing, proven conservation programs and conservation technical assistance (see our request to double conservation funding in the current reconciliation bill).
We look forward to continuing to work with you on the successful passage and implementation of legislation to support an agriculture that builds the economic prosperity of our communities, secures our nation’s food supply, and significantly increases our resilience in the face of climate change.
Sincerely,
Aria McLauchlan
Co-Founder & Executive Director, Land Core
aria@landcore.org