Land Core Submits Comments to USDA on Proposed Federal Strategy for Agriculture and Forestry Greenhouse Gas Measurement and Monitoring
Image Credit: NRCS
Submitted to: U.S. Department of Agriculture, Office of the Chief Economist
Re: Request for Information on Federal Strategy to Advance Measurement and Monitoring Greenhouse Gas Measurement and Monitoring for the Agriculture and Forest Sectors (Doc. No. 88 FR 44251)
Date: August 11, 2023
Land Core commends the U.S. Department of Agriculture (USDA) for proposing a framework for measurement, monitoring, reporting, and verification (MMRV) of greenhouse gas (GHG) emissions for the agriculture and forest sectors. We appreciated the opportunity to provide input on the proposed framework.
OVERVIEW
Lab Calibration to Support Market-Based Incentives
We appreciate USDA’s focus on direct measurements of GHG emissions and sinks in grasslands and croplands to better support models, in situ testing protocol, and the use of Earth observation data in predictive modeling. To properly collect direct measurements, standards must be set for field collection, sample handling, lab analysis, and data management and reporting. Without this entire spectrum of standard protocol, it will be impossible to properly compare GHG data to calibrate and validate indirect measurements and models.
We recommend that a standard protocol be established for any labs that want to qualify for the testing of any soil samples associated with USDA’s climate-smart investments, and a related certification protocol. To ensure there is a minimum number of labs available, we further recommend USDA work directly with a select subset of commercial and university analytical labs (to be designated by region) to establish the proposed standards. Our comments elaborate on how and why USDA might implement a lab calibration standard to yield data across a wide variety of production types and geographies.
Longer term, it's also essential that we generate reliable data that will allow farmers to connect with a variety of market-based economic incentives, such as carbon markets and company supply chain integration. This is also of foundational importance to our research and academic stakeholders, because even the most rigorous standards at the field level will yield inconsistent conclusions if there is variability from lab to lab.
Generating consistent data is also essential in order to create a predictive model of risk for agriculture and soil, allowing for the creation of preferential financial products like lower interest bank loans or crop insurance programs with lower premiums for farmers with good soil health. We believe USDA should also take the opportunity to use the data it is collecting through the GHG MMRV framework to assess the impact of climate-smart practices on insurance loss payout.
We urge USDA to put the data it has available to use to help us all understand the impacts of different cropland practices on resilience, and to make the data it has available to allow others to make these assessments as well.
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.