Policy Update: AFT Submits Comment on Climate-Smart Ag and Forestry Partnership Program
Yesterday, AFT submitted a public comment regarding USDA’s newly-proposed Climate-Smart Agriculture and Forestry Partnership Program (CSAFPP), which is to be funded using the Commodity Credit Corporation (CCC). USDA’s goal with CSAFPP is to help expand the market for climate-smart agricultural commodities, which are commodities “produced using farming practices that reduce greenhouse gas (GHG) emissions or sequester carbon.” USDA provided relatively little information about their vision for the program (such as whether or not it would generate agricultural carbon credits), which meant that AFT was able to provide a broad range of recommendations.
Given that the comment was capped at 10 pages, we couldn’t discuss everything that we would have liked. Our comment focused on the importance of: providing technical assistance to producers; ensuring that the program is inclusive of small-scale and diversified operations, and socially disadvantaged producers; and increasing the body of research on carbon sequestration to inform best practices and accurate modeling moving forward. We also recommended that the program pay producers for practice adoption and maintenance, rather than measured performance (AKA tons of carbon sequestered). This is due to the inefficiencies of soil testing, the fact that not all operations have similar sequestration potential, and the unpredictability of payments.
In addition to informing the development of the CSAFPP, we saw the comment as a way to position AFT as a potential partner in the program. As such, the comment includes a number of references to AFT’s on-the-ground work with farmers to increase adoption of conservation practices.
See the full outline of our recommendations to USDA below (read the full comment here)
- Engage NGOs, Other Entities, and Early Adopters in Providing Conservation Technical Assistance (CTA) to Producers
- Partner with NGOs, universities (including HBCUs), and other entities experienced in providing CTA to producers.
- Strengthen outreach to underserved communities.
- Engage early adopters in peer-to-peer outreach and education.
- Provide Incentives for Climate-Smart Agricultural Practice Adoption and Explore Innovative Incentive Models
- Provide payment based on practice adoption.
- Offer longer-term incentives.
- Explore innovative incentive approaches.
- Give Special Priority in the CSAFPP to Protected Lands
- Provide Grants, Loans, and Loan Guarantees for Equipment Directed at those with the Greatest Barriers to Entry
- Use CSAFPP to Deepen our Understanding of Practice Outcomes
- Create a Research Initiative and a National Calibration Dataset as part of CSAFPP.
- Develop Guidance to Inform GHG Mitigation and Sequestration Efforts
- Conduct analysis and issue guidance to inform the development of private carbon markets.
- Assess existing sequestration models.
- Establish an advisory board to assist in the development of guidance.
- Support Adoption of Proven Climate-Smart Systems of Practices, Especially Practices Associated with Secondary Benefits
- Prioritize synergistic bundled practices over individual practices.
- Prioritize the use of practices that have proven secondary environmental benefits.
- If the CSAFPP is used to support solar, prioritize installation on existing structures and marginal lands and advance dual-use (agrivoltaics).
- Ensure that the CSAFPP is Accessible, Equitable, and Culturally-Sensitive
- Include BIPOC-Focused Organizations in CSAFPP and Help to Build Their Capacity
- Include Equitable Access for Diversified, Small, and Mid-Size Operations in CSAFPP