Land Core Submits Comments to USDA on the Executive Order on Supply Chains for the Production of Agricultural Commodities and Food Products
Submitted to: U.S. Department of Agriculture - Agricultural Marketing Service (USDA-AMS)
Re: Request for Public Comment on the Executive Order on Supply Chains for the Production of Agricultural Commodities and Food Products
Date: June 21, 2021
Soil Health - the Foundation of the Food, Fuel and Fiber Supply Chain:
Essential to supply chain resilience is not only the processing, transportation, storage, distribution, marketing and other commonly identified “supply chain” components of critical goods and materials, but fundamentally, the resilience of producers and their farms, which are the very foundation of those supply chains.
It is essential to acknowledge that on-farm resilience is at the core of how we ensure the stability and reliability of our agricultural supply chain, and that soil health, in turn, is at the center of on-farm resilience.
We know that soil health on farms contributes significantly to lowering the risks of flood, drought,1 2 pest, fire and other shocks in agriculture (flood and drought alone accounting for over 90% of crop insurance payouts - or over $9 billion a year3 4).
Soil health practices not only bolster on-farm resilience but also lower reliance on inputs (fertilizers, pesticides, etc.) which increases resilience in the supply chain by avoiding the volatile and complicated nature of input production and distribution. Lower input costs, of course, also result in increased on-farm profitability.
Soil health practice adoption, such as cover cropping, low/no-till systems, crop rotational diversity, etc., all serve to de-risk our national food fuel and fiber supply chains, with the additional co-benefit of reducing greenhouse gas emissions and actively sequestering carbon.
We have a vested national interest in increasing the resilience of our suppliers and encouraging our growers and livestock producers to adopt soil health practices.
Recommendations:
We can incorporate soil health into supply chains by creating economic value for producers and encouraging them to adopt soil health practices – by creating new markets and risk-appropriate pricing of loans/insurance, and through other levers.
In order to identify, support and reward producers who have “good” soil health, there is a clear need for a consistent baseline of indicators and protocols as well as lab calibration that can identify that the desired resilience and ecological outcomes have been met.
Related to questions (ii), (iii), (v) and (ix):
- Create a voluntary, outcomes-verified soil health (OVSH) program at the USDA-NRCS that sets standard indicators and testing methodology, along with laboratory calibration (ensuring uniform outcomes nationally) in order to identify resilient producers and integrate them into company supply chains, and periodically verify that the participant’s soil health improvements have been achieved. See Land Core’s Explanatory Language5 for more details.
- A voluntary registry would be created in tandem allowing any verified producers in good standing to be listed and identified by businesses nationally and internationally as climate resilient, soil health farmers. This registry would enable scaled supply chain integration creating new premium market opportunities for these producers.
- This program could also serve as a baseline test for carbon credits and bolster ecosystem services markets, and be a baseline for private sector labeling initiatives.
- Given the existing infrastructure within the NRCS, such a program could easily be run at minimal cost and have a considerable impact on the scaling of supply chain adoption of soil health practices.
Related to questions (ii), (v)(H), (v)(J), (vi), (vii) and (ix):
- Recognize the risk mitigation value of soil health throughout USDA lending and insurance, including better loan pricing (USDA-FSA) and terms for producers with soil health management plans, and at USDA-RMA, by implementing pricing that incorporates soils and soil health management as a factor in risk assessment.6
Related to questions (ii), (v)(G), (v)(H) and (ix):
- Expand access to regionally appropriate soil health practice implementation training for producers through NRCS and approved third-parties:
- Create RFPs for public-private partnerships for access to relevant education that follows the Principles of Regenerative Agriculture7 and is based on creating outcomes of improving soil health, increasing biodiversity, increasing water holding capacity, reducing water usage, and reducing input costs for farmers.
- Make “train the trainer” education resources, USDA personnel and leaders in the field of soil health education available to: NRCS Field Agents, Technical Service Providers, Certified Crop Advisors, Extension Agents.
Citations:
1. Union of Concerned Scientists, “Turning Soils into Sponges: How Farmers Can Fight Floods and Droughts”, August 2017, https://www.ucsusa.org/resources/turning-soils-sponges
2. Elizabeth Creech, “Soil Health Practices for Mitigating Natural Disasters”, USDA-Natural Resources Conservation Service - Newsroom - Features, 2018, https://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/newsroom/features/?cid=nrcseprd1384891
3. U.S. Department of Agriculture, Risk Management Agency, “Crop Year Government Costs of Federal Crop Insurance Program,” March 2020, https://www.rma.usda.gov/-/media/RMA/AboutRMA/Program-Budget/19cygovcost
4. Claire O’Connor, Lara Bryant, “Covering Crops: How Federal Crop Insurance Program Reforms Can Reduce Costs, Empower Farms, and Protect Natural Resources”, Natural Resources Defense Council, December 2017, https://www.nrdc.org/sites/default/files/federal-crop-insurance-program-reforms-ip.pdf
5. Land Core. “Language to Guide Development of an Outcomes-Verified Soil Health Program,” 2020, https://drive.google.com/file/d/18a4uIrVkTm0yqbW1eeYI-b2Ruay2T1JH/view
6. USDA-Natural Resources Conservation Service (NRCS), “Soil Health: Principle 1 of 5– Soil Armor”, 2017, https://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/nd/soils/health/?cid=nrcseprd1300631
7. Land Core, “Building a Predictive Model of Risk”, March 2020, https://landcore.org/programs#risk-modeling-section
About Land Core:
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. 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 the USDA, 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.
Policy wins include 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.