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IATP submitted the following comment to the Natural Resources Conservation Service on implementation of the Inflation Reduction Act (IRA). 

The Institute for Agriculture and Trade Policy believes that the U.S. Department of Agriculture should move swiftly to ensure funds dedicated through the Inflation Reduction Act truly address the climate crisis.

IATP applauds USDA for looking into how best to help farmers mitigate climate change. There must be another leg to this stool to make it sturdier, however – climate resilience. While we too are hopeful that emissions are reduced enough to help solve the climate crisis, we are also preparing for a warming world where farmers will need to cope with increased (and more intense) droughts, floods, wildfires, and declining water quality and quantity. We hope that USDA is able to help farmers pay for practices that are resilient – that help farmers work with nature and adapt to new climate realities. This might mean planting new and more diversified crops, opting for more drought or flood-resilient varieties, or converting some land to wetland, grassland, or forested land. We applaud the inclusion of such systems approaches in your CSAF Mitigation Activities list.

What are key metrics to successful IRA implementation?

In our view, when determining whether IRA money is successful in addressing the climate crisis, the following must be addressed:

  • Practices should be available to farms of all sizes and capital flow;
  • Climate mitigation priorities should not cause or lead to other environmental harms, such as water or air pollution;
  • Prioritization for resilience, maximizing co-benefits of emissions reduction and climate adaptation;
  • Long-term benefit, ensuring benefits are not easily reversed by changes in climate.

Without these metrics, any climate benefits will be short-lived and be limited in scope in a time where widespread adoption of climate tools are necessary.  


Improving existing tools

COMET-Farm and COMET Planner are good tools to help estimate greenhouse gas emission reduction through various practices. While these are good estimating tools, there is still much we don’t understand about carbon sequestration, particularly over the long-term, so they should not be used for precise measurements for uses such as carbon offset markets/credits. As our knowledge of carbon sequestration improves, we encourage USDA to adjust the tool to reflect the latest science, especially as it relates to organic and pasture-based systems.

While the role USDA practices have with GHG reductions is still being studied, USDA should look at emissions in a holistic way – not only focusing on practices, enhancements, and bundles that capture carbon from the atmosphere, but also methods of keeping carbon from reaching the atmosphere in the first place, like conserving existing wetlands, forest lands, peat lands, and grasslands. We need a systems-based approach to help farmers, especially since they are often required to think about their operations at a systems-level.

We also encourage the continued improvement of the Conservation Assessment Ranking Tool (CART) to make ranking criteria transparent for farmers and reward projects with climate mitigation and adaptation at their core. If the process for accessing NRCS conservation programs is fair and simple, farmers will be more likely to want to enroll their land in these programs.

Opening the door for closed out farmers

We encourage USDA to take a look at the applications to CSP and EQIP that were rejected over the past few years, and help connect these growers to the programs listed in USDA’s Climate-Smart Agriculture and Forestry Mitigation Activities list (with some exceptions).1 According to USDA’s own data, between 2010 and 2020, just 31% of EQIP applicants and 42% of CSP applicants were awarded contracts, with some states approving much lower percentages.2 Turned away farmers can be low-hanging fruit when it comes to connecting climate-friendly practices to eager stewards of the land.

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