Land Core Submits Comments to USDA on the Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program
Image Credit: Benjamin Davies, Unsplash
Submitted to: U.S. Department of Agriculture, Agricultural Marketing Service
Re: Request for Information on Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program (Doc. No. AMS-LP-24-0012)
Date: June 28, 2024
Land Core commends the U.S. Department of Agriculture (USDA) for building upon the Growing Climate Solutions Act (GCSA) of 2021. The Department’s leadership on this topic sends an important signal to the agricultural community. We appreciated the opportunity to provide input on the proposed framework.
OVERVIEW
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.
Implementing soil health management practices is the way in which we build Soil Organic Carbon (SOC) or Soil Organic Matter (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.
Recommendations in response to Request for Information:
Question 1: How should USDA define the terms “consistency,” “reliability,” “effectiveness,” “efficiency,” and “transparency” (see 7 U.S.C. 6712(c)(1)(A)) for use in protocol evaluation?
Consistency should be defined as science-based, accessible, and specific language centered on terminology that farmers and ranchers understand. For example, “Carbon” should be specified as “Soil Organic Carbon (SOC) and Soil Organic Matter (SOM).”
Question 4: Which protocol(s) for generating voluntary carbon credits from agriculture and forestry projects should USDA evaluate for listing through the Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program?
An effort to strengthen the public-private partnership between commercial soil test labs, land grant universities, and technical assistance providers is essential to the development and use of a national set of regionally appropriate interpretation functions used for on farm management decision making. Adherence to standardized methods is an important first step, but should incorporate the practice of cross-validating results to limit inter-laboratory variability. Any protocols listed by USDA should contain ‘lab calibration’ processes to ensure accuracy and reliability of credits generated.
Question 6: How should USDA evaluate technical assistance providers (TAP)? What should be the minimum qualifications, certifications, and/or expertise for a TAP to qualify for listing under the Program?
TAPs should have relevant certifications (e.g. Certified Crop Adviser), practical experience in agriculture or forestry, deep understanding of agroecology and biology, and demonstrated knowledge of carbon markets and environmental protocols. They should also have experience or be part of a team with a member who is proficient in balancing agronomic and environmental goals to ensure that carbon credit projects do not compromise soil health, water conservation, or crop productivity.
Question 7: Should the qualifications and/or registration process be different for entities and individuals that seek to register as a TAP?
As a trusted and impartial resource for farmers, USDA should take ownership of certifying practitioners, similar to the procedures in place for the Technical Service Providers (TSP) program and Organic Certifying Agents (OCA) program. Similar to the TSP program, USDA should ensure integrity of the TAP list by including educational and experiential qualifying criteria. We encourage USDA to create a brief certifying course, with appropriate knowledge checks, that all TAPs must complete before being added to a public database.
While we encourage USDA to build upon the existing knowledge and expertise of private sector certification programs and entities, USDA should have independent technical and ethical standards. Entities may help to streamline the verification of educational and experiential criteria. They may also facilitate training or enrollment for TAPs. For instance, an entity may hold a one-day workshop to enroll their employees on the TAP directory, but the content and certification for being added to the directory should be left to USDA.
USDA must implement guidelines that prohibit or restrict individuals listed on the TAP directory from receiving monetary gain from providing greenhouse gas technical assistance. At minimum, TAPs should disclose any business interests in a particular carbon market or any sales-based commission they may receive from helping farmers to enroll in private sector or public sector financial assistance programs.
TAPs should be either “Certified GHG Advisor” or “Certified Third Party GHG Verifier", but not both, so as to minimize potential conflicts of interests. At a minimum, if a TAP is qualified to do both, they should not be allowed to do both for the same client or clients in the same geography.
View our full comments on regulations.gov or as a PDF.
For further information, please contact Aria McLauchlan, Executive Director.
Land Core is a 501(c)3 organization with a mission to advance soil health policies and programs that create value for farmers, businesses and communities. The organization is building the missing infrastructure and market-based incentives that will make the rapid adoption and scalability of soil health possible.