Land Core Publishes Comments to NRCS Conservation Practices to Support Mitigation and Implementation
USDA-NRCS Photo by Aaron Roth: Wallowa County Farmers Embrace Soil Health
Public Comments:
Implementation of Conservation Practices to Support Mitigation and Adaptation
RE: Docket: NRCS-2024-0015
Land Core is pleased to provide input on NRCS’s commitment to improving Conservation Practice Standards (CPS). 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.
Land Core works closely with federal agencies, legislators, producers, soil scientists, NGOs and financial institutions across the country to develop federal policy recommendations that promote healthy soils, resilient, profitable farms and national food security.
The organization’s policy work includes building a broad coalition of support for soil health and helping to secure over $50M in funding for the Soil Health Demonstration Trials in the 2018 Farm Bill, providing technical recommendations to NRCS, and guiding the successful passage of language in both the House and Senate supporting soil health outcomes at USDA in the FY20 Appropriations legislation, and supporting the inclusion of funding for soil health in the Build Back Better budget reconciliation package.
These comments are also based on Land Core’s work building a predictive model of the risk-mitigating benefits of soil health practices, designed as a tool to inform and support lenders and insurers (and the private sector, more broadly) in incentivizing soil health-building conservation practices.
The comments will address the following target conservation practice standards:
● Soil Carbon Amendment
● Herbaceous Weed Treatment
● Nutrient Management
● Prescribed Burning
Risk Mitigation & Reduction
What changes are needed to CPS to add flexibility or support implementation options to provide mitigation benefits?
We believe several changes are needed to enhance the flexibility and effectiveness of Conservation Practice Standards (CPS) in providing risk mitigation benefits. To improve the overall impact of CPS, we recommend adopting a holistic approach that encourages the implementation of multiple complementary practices to maximize synergistic benefits for risk mitigation. With the entire farm business and agro-ecosystem in mind, we also advocate for practices that can maximize soil organic matter while increasing economic return and resilience for farmers.
Developing region-specific guidelines for each practice is crucial to account for variations in weather, soil types, and ecosystems. Implementing robust monitoring and verification systems will help quantify the actual mitigation impacts of these practices. Providing comprehensive training and technical assistance to farmers is also essential to ensure the maximum potential of soil health practices is realized. Additionally, aligning financial incentives through programs like EQIP and CSP with the most effective mitigation practices will further support adoption.
When evaluating conservation activities for inclusion on the Climate-Smart Mitigation Activity List, NRCS uses specific criteria to assess their potential impact. Based on these criteria and the current CPS, we propose the following changes:
Soil Carbon Amendment: To maximize the mitigation potential of this practice, we recommend:
1. Expanding eligible materials: Include a wider range of carbon-rich amendments, such as biochar and compost, to increase options for farmers.
2. Encouraging long-term application: Implement multi-year plans for carbon amendments to ensure sustained soil health benefits.
3. Integrating with other practices: Combine soil carbon amendments with cover cropping, reduced tillage, and other practices as appropriate for the context, for significant synergistic benefits.
Herbaceous Weed Treatment: To enhance this practice, we suggest:
1. Prioritizing mechanical and biological methods: Emphasize mechanical and biological weed control to reduce reliance on costly herbicides and minimize soil disturbance.
2. Promoting cover crops: Integrate cover cropping as a weed suppression strategy to improve soil health and carbon sequestration simultaneously. Increase crop rotations where possible as an additional strategy for weed life cycles.
3. Encouraging livestock integration: When possible, provide guidance to utilize managed grazing of livestock for weed control purposes.
Nutrient Management: To optimize this practice for risk mitigation, we recommend:
1. Integrating cover crops: Encourage the use of nitrogen-fixing cover crops to reduce synthetic fertilizer needs and costs.
2. Promoting livestock integration: Incentivize the use of animal manure to improve soil organic matter and reduce emissions from synthetic fertilizer production.
Prescribed Burning: To enhance the risk mitigation potential of this practice, we propose:
1. Optimizing burn timing: Develop guidelines for optimal burn timing to maximize carbon organic matter in regrowth while minimizing carbon emissions.
2. Integrating with grazing management: Combine prescribed burning with strategic grazing to enhance soil health and carbon sequestration.
3. Promoting biochar production: Explore opportunities to produce biochar from burned biomass, creating a long-term carbon storage option while reducing fuel loads.
4. Recognizing Cultural Burns: Consult and collaborate with Tribes to achieve shared conservation, ecosystem management and community goals.
What additional technical guidance should NRCS provide or develop to support planning, designing, and implementing the CPS in a way to maximize mitigation benefits?
To maximize the mitigation benefits of the Conservation Practice Standards (CPS) discussed earlier, NRCS should provide additional technical guidance in the following areas:
Soil Carbon Amendment
1. Develop region-specific guidelines for optimal amendment types and application rates based on soil types and climate conditions to maximize carbon sequestration potential.
2. Provide detailed instructions on integrating soil carbon amendments with other practices like cover cropping and reduced tillage to create synergistic effects.
3. Offer guidance on long-term monitoring and verification methods to quantify carbon sequestration results over time.
Herbaceous Weed Treatment
1. Create comprehensive guides on non-chemical weed control methods, including mechanical and biological approaches, to minimize soil disturbance and reduce emissions.
2. Develop decision support tools to help farmers select the most appropriate weed management strategies based on site-specific conditions and risk mitigation goals.
3. Provide technical guidance on integrating weed management with cover cropping and other soil health practices to maximize overall benefits.
Nutrient Management
1. Offer detailed guidance on precision agriculture technologies and techniques for nutrient application to minimize excess fertilizer use and associated emissions.
2. Develop region-specific recommendations for using cover crops and manure to reduce synthetic fertilizer needs while improving soil health.
3. Create tools to help farmers calculate and optimize the carbon footprint of their nutrient management practices.
Prescribed Burning
1. Provide detailed guidelines on optimal burn timing and frequency to maximize carbon sequestration in regrowth while minimizing emissions.
2. Develop technical guidance on integrating prescribed burning with grazing management strategies to enhance soil health and carbon storage.
3. Offer instructions on monitoring and quantifying the long-term carbon impacts of prescribed burning in different ecosystems.
What models, methods, data, literature, and tools should NRCS consider as it develops and refines its estimation of the risk mitigation benefits associated with CPS?
To enhance NRCS's estimation of risk mitigation benefits associated with Conservation Practice Standards (CPS), the agency should consider incorporating soil health practices and their role in risk mitigation for farmers. This approach aligns with the growing body of evidence supporting the link between soil health and resilience.
Soil health practices, such as minimizing disturbance, maximizing soil cover, increasing biodiversity, and maintaining living roots, can significantly reduce risks for farmers while providing risk mitigation benefits. These practices improve soil structure, water infiltration, and nutrient cycling, making farms more resilient to extreme weather events like droughts and floods.
NRCS should evaluate and potentially incorporate the following models and methods:
1. Land Core Risk Model: This model, developed by Dr Tim Bowles, Dr Frederi Viens, Dr Lawson Connor and colleagues, quantifies the risk reduction value of soil health practices. It uses a dataset spanning millions of farm fields across nine states in the US Corn Belt to illustrate the impact of crop rotation and cover cropping on yields under various weather and soil conditions.¹
2. COMET-Farm: This digital carbon and greenhouse gas accounting system can be expanded to include more soil health practices and their associated risk reduction benefits.
3. NRCS Conservation Effects Assessment Project (CEAP) Cropland Modeling: Enhance this existing framework to better capture the long-term effects of soil health practices on mitigation and risk reduction. 4. NRCS should also work in an ongoing way to assess modeling and measurement methods, which are continuously evolving and rapidly improving, and partner with non-federal stakeholders to improve its risk assessments.
NRCS should consider the following data sources and literature:
1. Long-term field trials data comparing conventional and soil health-focused management systems across different regions and crop types.
2. Peer-reviewed studies on the relationship between soil organic matter, water-holding capacity (and/or conservation practices that build soil health), and crop resilience to extreme weather events. 3. Economic analyses of risk reduction benefits associated with soil health practices, including potential impacts on crop insurance premiums and loan terms.
To support the implementation and assessment of climate-smart practices, NRCS should develop or refine the following tools:
1. Soil Health Assessment Tools: Standardized, easy-to-use tools for farmers to assess and monitor soil health indicators over time.
2. Risk Assessment Tools: Region-specific tools that help farmers evaluate risks and potential mitigation strategies based on their specific operations.
3. Economic Decision Support Tools: Tools that help farmers and advisors calculate the potential economic benefits of implementing soil health practices, including risk reduction value.
4. User-friendly interfaces for existing NRCS tools like COMET-Farm and CEAP models, with associated training programs to ensure producers can effectively use these resources.
To improve its estimation of risk mitigation benefits associated with CPS, NRCS should take several key steps.
The agency should integrate soil health principles more explicitly into CPS evaluation criteria for risk mitigation benefits and collaborate with research institutions and innovative farmers to gather more field-level data on the long-term and cumulative impacts of soil health practices on resilience and mitigation. Developing a comprehensive framework that links field-scale actions to landscape and regional outcomes is crucial, incorporating up-to-date soil and landscape properties data, assessment, monitoring, and modeling at multiple geographic and temporal scales.
NRCS should also improve its ability to quickly integrate emerging practice and science into operational definitions, procedures, and supporting documents such as handbooks, manuals, and technical guidance materials. This also includes working to review and remove any unintentional limitations that may prevent farmers from applying contextually-appropriate practices or combinations of practices. Finally, establishing a system for capturing field-level data on impacts of extreme weather events will help NRCS planners more effectively evaluate existing conditions, identify natural resource concerns, and monitor conservation practice effectiveness at the local level.
¹ https://landcore.org/news-post/2024/05/02/land-core-risk-model-manuscript-pre-print
Resilience through Soil Health
What changes are needed to CPS to add flexibility or support implementation options in a way that considers potential impacts and provides adaptation benefits, when possible?
To enhance Conservation Practice Standards (CPS) for better adaptation and mitigation, several key changes are needed:
Integrating resilience: This involves revising existing standards to explicitly include resilience criteria and practices, as well as developing new standards specifically focused on adaptation and mitigation techniques. It's essential to incorporate region-specific guidelines to account for varying impacts across different areas, ensuring that the CPS remains relevant and effective in diverse geographical contexts.
Enhancing water management: This can be achieved by expanding irrigation efficiency practices, including the promotion of micro-irrigation and subsurface drip systems. Additionally, CPS should encourage water harvesting and on-farm water retention techniques to improve water security. Promoting the use of drought-tolerant crop varieties and species will further enhance resilience to water scarcity issues.
Improving soil health: CPS should emphasize practices that increase soil organic matter and water-holding capacity, such as cover cropping and reduced tillage. Promoting the use of soil amendments that enhance carbon sequestration and soil structure will contribute to both mitigation and adaptation efforts. It's important to integrate soil health principles more explicitly into CPS evaluation criteria to ensure these practices are prioritized.
Supporting diversification and resilience: CPS should encourage agricultural diversification and the integration of trees, crops, fish, and livestock to reduce risk and enhance system resilience. Promoting practices that enhance biodiversity and ecosystem services on farms will contribute to overall system health and adaptability. Developing standards for resilient agricultural operations will provide a framework for farmers to follow in adapting their practices.
Enhancing technical assistance and education: CPS should include provisions for expanded outreach and education on climate-smart adaptation strategies. Providing more comprehensive technical assistance, including expanded peer-to-peer learning opportunities, will help farmers implement resilient practices effectively. Developing user-friendly tools and interfaces to help farmers assess and monitor risks and adaptation strategies will empower them to make informed decisions. Finally, NRCS should consider engaging in cooperative agreements with soil health-focused organizations and farmers to provide “train-the-trainer” educational opportunities to NRCS field staff.
Aligning CPS with economic incentives: This involves expanding conservation program eligibility criteria to include and prioritize resilience. Considering the integration of resilience into crop insurance rates and premium subsidies could provide additional motivation for farmers to adopt these practices. Ensuring that financial incentives through programs like EQIP and CSP align with the most effective risk mitigation practices will further support the transition to more resilient agricultural systems.
By implementing these changes, CPS can better support farmers in promoting practices that enhance community well-being and safeguard livelihoods. These modifications will help ensure that conservation practices not only address immediate environmental concerns but also build long-term resilience in agricultural systems, contributing to sustainable food production.
What additional technical guidance should NRCS provide to support planning, designing, and implementing the CPS to ensure consideration of climate change impacts and maximize adaptation?
To support planning, designing, and implementing Conservation Practice Standards (CPS) that maximize adaptation, NRCS should provide additional technical guidance in several key areas:
● Develop region-specific guidelines for resilient practices, taking into account local climate projections, soil types, and ecosystem characteristics. This will help farmers and land managers implement practices that are most effective for their specific contexts.
● Create comprehensive decision support tools that integrate weather data, soil health indicators, and economic factors. These tools should help farmers evaluate the potential impacts of different conservation practices on their operations' resilience and profitability under various climate scenarios.
● Provide detailed guidance on implementing regenerative agriculture practices, such as cover cropping, reduced tillage, and diversified crop rotations. These practices can enhance soil health, water retention, and overall farm resilience.
● Offer technical assistance on water management strategies, including efficient irrigation systems, water harvesting techniques, and drought-tolerant crop selection. This guidance should be tailored to address both water scarcity and excess water challenges.
● Develop best practices for integrating agroforestry and silvopasture systems into existing agricultural operations, emphasizing their potential for adaptation and mitigation.
● Provide guidance on monitoring and quantifying the adaptation benefits of implemented practices. This could include standardized methods for assessing soil health improvements, water use efficiency, and crop resilience to extreme weather events.
● Offer training and resources on holistic livestock management practices, such as rotational grazing and improved feed management, to enhance resilience in animal agriculture, expand the benefits of these practices to public lands, and create more mixed use opportunities on working lands.²
● Develop guidelines for implementing nature-based solutions that enhance farm resilience while providing ecosystem services, such as riparian buffers and wetland restoration.
To maximize the effectiveness of these efforts, NRCS should encourage partnerships with businesses, research institutions, and mission-driven 501(c)(3) organizations to co-develop and scale solutions that balance resilience and economic viability. These collaborations can help:
● Accelerate the development and adoption of innovative adaptive practices.
● Leverage diverse expertise and resources to address complex challenges.
● Ensure that adaptation strategies are economically viable and scalable for farmers. ● Facilitate knowledge transfer and best practice sharing across different regions and farming systems.
By providing this comprehensive technical guidance and fostering strategic partnerships, NRCS can support farmers and land managers in implementing CPS that effectively address climate impacts while maintaining productive and profitable operations.
² https://landcore.org/news-post/land-core-blm-comments-conservation-landscape-health
Soil Health & Innovation
What other innovative, economically viable ideas, technologies, or solutions are available to provide mitigation or adaptation benefits that NRCS should consider for development of a new CPS?
Land Core recognizes the critical role of soil health in supporting resilient agriculture. Building on our commitment to advancing soil health practices that benefit farmers, businesses, and communities, we propose several innovative ideas and solutions for NRCS to consider in developing a new Conservation Practice Standard (CPS).
To expand financial incentives, we advocate for incorporating data about the risk-reducing benefits of soil health practices into farm credit and crop insurance programs. This approach could lead to more favorable loan terms and reduced insurance premiums for farmers who implement soil health practices, providing a strong economic
incentive for adoption. NRCS can support this goal by promoting data collection and sharing from farmers implementing CPSs that can then be used to establish actuarily sound credit and crop insurance discounts.
Additionally, we recommend expanding the scope of tax deductions to include a wider range of soil health practices, introducing tax credits for farmers who demonstrate significant improvements in soil health metrics, and creating accelerated depreciation allowances for equipment used in implementing these practices. These financial incentives would not only encourage the adoption of soil health practices but also recognize and reward farmers for their contributions to risk mitigation and adaptation.
To leverage public-private partnerships and reduce implementation costs while increasing scalability, we propose establishing collaborative research networks between government agencies, academic institutions, and private companies. These partnerships would focus on developing and refining soil health monitoring technologies, conducting large-scale trials of innovative soil health practices, and sharing data and insights to accelerate the adoption of effective strategies.
Furthermore, we recommend creating technology transfer programs that facilitate the transfer of soil health technologies from research institutions to farmers. These programs would provide training and technical support for implementing new soil monitoring tools and offer subsidies or low-interest loans for farmers to acquire advanced soil health technologies.
We welcome questions and collaboration, and thank you for the opportunity to submit comments on this important topic.
Aria McLauchlan
Co-Founder & Executive Director, Land Core
aria@landcore.org
Land Core is a 501(c)3 organization that works closely with the USDA, legislators, producers, soil scientists, NGOs and financial institutions across the country to develop policy recommendations that build healthy soils, resilient farmers and national food security. This includes guiding the successful passage of language in both the House and Senate supporting soil health outcomes at the USDA and helping to secure over $50M in federal investment in Soil Health in the 2018 Farm Bill.
Resources: The Land Core Soil Health Bill Tracker is a comprehensive tool designed to monitor and analyze legislation related to soil health and resilience. It can be used to support bills that align with the priorities of strengthening American agriculture, promoting energy independence, and revitalizing rural communities.
Contact: Aria McLauchlan, Co-Founder & Executive Director, aria@landcore.org