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AFT Submits Comment on Implementation of IRA Funding to Advance Smart Solar 

Climate change is an existential threat that is already impacting farmers, farm viability, food security, water availability, and more. It is essential to achieve carbon neutrality in order to avert the worst consequences of climate change, and doing so will require substantial increases in renewable energy generation. Solar will be a critical part of this effort.  

The growth and expansion of solar development, however, has the potential to convert millions of acres out of farming and food production, rapidly reshaping rural landscapes and farm economies. Modeling done by AFT through our Farms Under Threat 2040: Choosing an Abundant Future analysis projected that, based on historical patterns and current policies, 83% of the approximately 7 million acres of new solar built by 2040 could be sited on agricultural lands, with almost half on our most productive land for producing food and other crops. But solar development does not have to convert all these acres out of food and crop production—with “smart solar” we can have both.  

We need thriving rural economies, robust food production, and reliable, affordable renewable energy. AFT has been working since 2018 to determine how the U.S. solar buildout can strengthen rural communities and keep land in farming across the country. Now, the implementation of funding included in the Inflation Reduction Act (IRA) provides the Biden Administration, and specifically USDA, with the opportunity to model to developers, utility companies and cooperatives, and local and state governments how to decarbonize the U.S. electric grid in ways that combat climate change and achieve USDA’s mission to support a vibrant agricultural and rural economy.  

Currently, communities across the nation are slowing or halting solar development over concerns about farmland conversion. By implementing AFT’s recommendations, USDA can ease these concerns and demonstrate how these communities can achieve a “smart solar” buildout. AFT has developed four principles designed to achieve renewable energy goals while also strengthening agriculture. This can, in turn, help smart solar projects get permitted and built more quickly. Within this comment, AFT recommended USDA Rural Development (RD) advance this work by: 

1. Requiring that all current and future applicants proposing front-of-the-meter wind and solar projects on farmland follow best available practices for construction, operation, and decommissioning that will maintain or improve soil health. In addition, RD should work with the Natural Resources Conservation Service (NRCS) to develop USDA-approved guidance and standards to be applied to future projects.  
2. Requiring utility-scale solar applicants to include data on which soil types (e.g., USDA Soil Survey Geographic Database) and how many actively farmed acres (e.g., within the last 5-10 years) are included within their proposed project and facility areas, and then publicly reporting this information. This data can also help guide USDA in determining how to apply the Farmland Protection Policy Act to these and other federal renewable funding opportunities. 
3. Developing and implementing “smart solar” scoring, ranking criteria, and program incentives (e.g., higher REAP cost share, higher loan forgiveness levels) that will encourage applicants to develop “smart solar” projects proposed on farmland. 
4. Including underutilized, low-impact applications of solar (e.g., agrivoltaics, solar on the built environment, solar on contaminated land) as eligible within the REAP funding for Underutilized Technology.

AFT will continue to work with USDA, Congress, partners, solar developers, and state and local governments to ensure a smart solar buildout that strengthens farm production and rural vitality in the future. 

To learn more, read AFT’s full comment here!