Behind the Scenes: AFT’s Federal Supply Chain Comment

In late June, the federal policy team (or “shop,” as we like to call it) submitted a comment to USDA on increasing the resiliency of the nation’s food and agricultural supply chains. The purpose of this comment was two-fold. It will inform an upcoming USDA report on “Supply Chains for the Production of Agricultural Commodities and Food Products” and help USDA determine how to use remaining Coronavirus relief funding.  

This comment was the second we had submitted in two months, as the Biden Administration calls on agencies to develop strategies to tackle pressing issues. At the end of April, we submitted 22 pages of recommendations on USDA’s climate strategy, and then began developing the comment on supply chains. Right now, we are finalizing yet another comment to USDA on advancing racial equity. Yes, it’s been a busy few months!  

So, why do we submit comments? When agencies want stakeholder input on a new initiative or rule, they formally submit a request for public comments in the Federal Register. Comments can be submitted by anyone, from a non-profit like AFT to a private citizen. Different requests get different levels of public response – while the supply chain request received about 900 public comments, the climate strategy request received over 37,000! Public comments are one of the tools that AFT and other organizations use to shape federal policy. 

The policy shop’s first step in writing a new comment is conducting interviews with AFT board members and staff to gather ideas. Many of our recommendations originate at the state level, since state programs and policies are often valuable incubators for federal policy ideas. In addition, state-level AFT staff have deep subject matter expertise, informed by their work with state and local agriculture, conservation, and food system partners and, in some cases, by their own experiences as farmers. Comments give us the opportunity to recommend the most successful and innovative policies, some of which may become a part of our 2023 Farm Bill campaign (starting in 3… 2… 1…).  

Often, AFT’s public comments are highly technical, suggesting things like adding or subtracting a few words in a program rule (our comments on the Agricultural Conservation Easement Program [ACEP] rulemaking, for example, literally required a law degree to write!). The supply chain comment, however, is one of the more holistic that we’ve written to date, connecting supply chain resiliency to everything from agricultural land protection to the procurement laws that dictate farm-to-school purchasing.  

I, personally, think that that this big picture perspective is one of the unique things that we bring to the table. AFT does not believe in silver bullets. Instead, we believe in “silver buckshot” – we need a protected agricultural land base and a new generation of farmers and accessible food system infrastructure and plentiful market opportunities… The list goes on.   

We also want to be clear that we don’t think that the goal should be achieving a stronger food  chain. Regardless of what your chain is made from, a single broken link can disrupt the whole system. What we need—to borrow a term from 9th grade biology—is a food web containing so many interwoven points that a single broken connection barely makes an impact.  

At present, our national food system is breathtakingly efficient. However, the pandemic showed us that efficiency often comes at the expense of resilience. We believe that building a resilient system requires two things: First, each individual piece of the system – whether it’s a small farm, a large ranch, or a food hub – needs to be “resilient,” defined here as being able to withstand unexpected impacts without breaking. Viability and resilience often go hand in hand – a farm with a steady, diversified income will be better prepared to deal with the unexpected than a farm already on the brink of bankruptcy.  

Second, we need to ensure—to once again make my biology teacher proud—systemic redundancies. Despite the negative connotations, redundancy is a good thing for supply chains, and can be accomplished by bolstering local and regional food systems to better complement the national food system. This means more small and midsize farms, more food hubs and aggregators, more meat processing facilities, and better transportation. It also means incentivizing purchasers of local products, especially large institutions like schools, to grow demand. By building these systems we hope to relieve some of the pressure on the national food system and give all producers stable market opportunities.  

At the risk of sounding trite, we really are at a pivotal moment. Supply chains, nutrition, climate change, carbon markets, local food, and more are all in the media, on people’s minds, and making their way into legislation as we reflect on a punishing year and prepare for the challenges ahead. Our goal is to hold on to this momentum as we begin to engage with the 2023 Farm Bill process, and use it to create something truly transformational.