Policy Update: AFT Submits Comment to USDA on Racial Equity - American Farmland Trust

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Policy Update: AFT Submits Comment to USDA on Racial Equity 

On Wednesday, August 4, AFT submitted a public comment to USDA on advancing racial equity within the Department. The request for comment, as with the previous two (on supply chains and climate-smart agriculture), was in response to a January Executive Order. This Order was titled “Advancing Racial Equity and Support for Underserved Communities Through the Federal Government,” among other things, directs all departments to assess barriers to program participation for underserved communities. 

This request for comment was more narrowly focused than others, since it asked highly specific questions. It concentrated on receiving input regarding USDA policies (as opposed to those issues under congressional authority). USDA also seemed especially focused on trying to solicit input from socially disadvantaged farmers and ranchers, asking questions like “have you applied for or accessed USDA programs and services in the past? If so, please describe your experience.”  

AFT’s comment addressed several areas. One major theme was on increasing enrollment in USDA programs such as FSA loan or conservation programs by increasing technical assistance, making the application process more accessible, and changing program rules to not disadvantage BIPOC producers. This also included providing better training to employees on issues of importance to BIPOC producers, and building up partnerships with organizations that work directly with BIPOC producers. The comment also made recommendations on data collection and sharing, addressing heirs’ property through the new relending program authorized in the 2018 Farm Bill, and providing Business Technical Assistance to socially disadvantaged producers to help build more viable businesses. 

Finally, the comment also stated that a single comment period was not going to be sufficient to address these issues, and that USDA should consider creating an open-ended mechanism for receiving additional feedback on opportunities for making the Department’s work more equitable.  

Below is an outline of our recommendations to USDA on increasing racial equity (you can read the full version here): 

  • Increase Culturally-Sensitive Technical Assistance and Ensure an Accessible Application Process
    • Offer increased assistance with completing USDA applications, especially NRCS conservation program and loan applications, to reduce the associated time burden and increase transparency regarding decision metrics.  
    • Simplify the language of program applications and materials to be more accessible and translate it into additional languages. 
    • Tailor outreach and education efforts specifically to distinct communities, and make use of diverse methods of information sharing, emphasizing community partnerships as much as possible. For instance, USDA should take into account that some communities might lack consistent access to high-speed internet, or that some communities might require in-person outreach at locations such as community centers or places of worship.  
  • Examine FSA Requirements to Increase Loan Access for Socially Disadvantaged Producers   
    • Identify alternatives to the requirement of a signed purchase and sale agreement prior to processing an application for loan funds. For instance, a version of a prequalification letter could demonstrate to a seller the financial readiness of a would-be buyer, thereby making potential FSA loan recipients more competitive in purchasing land. 
  • Establish the Commission on Farmland Transitions
    • To ensure that the findings of the Commission on Farm Transitions informs the development of the 2023 Farm Bill, USDA should immediately form the Commission.
    • The Commission should place special emphasis on identifying and addressing the unique challenges facing next-generation BIPOC farmers and ranchers in their ability to inherit or purchase agricultural assets, including land. AFT strongly encourages USDA to ensure that BIPOC farmers and ranchers are well-represented in the Commission’s membership. 
  • Create an Office of Small Farms to Represent Lower-Acreage Operations Throughout USDA 
    • Establish an Office of Small Farms to increase support to low-acreage or low-income farms. The Office would serve as a coordinating body, bringing together representation from USDA’s various agencies to identify additional needs for small farmers. The definition of small farms could be based upon acreage (e.g., less than 180 acres) or farm income. To ensure the Office is a sufficient priority, it could be overseen by senior USDA leadership, such as the Deputy Secretary of Agriculture. It would have dedicated staff, some of which should be experienced with providing on-the-ground support to small farms and ranches and diverse populations. Specifically, the Office of Small Farms could:  
      • Coordinate efforts to support small farms and ranches across all USDA agencies.
      • Advise other federal agencies on how to effectively reach and serve small farms and ranches. 
      • Analyze the development of federal rules and other policies to ensure that the interests of small farms are considered in decision-making. 
      • Make recommendations to federal agencies on tracking small farm data, including demographics and program participation rates. 
      • Propose research agendas on topics that are of special interest to small farms. 
      • Review current USDA programs and policies for their impacts on small farms. 
      • Provide or coordinate direct technical assistance to small farms to enable them to access the full complement of USDA grant and loan programs. 
      • Develop financing mechanisms and technical support for production and markets that is specific to small farms.  
  • Release the Proposed Rule for the “Relending Program to Resolve Ownership and Succession on Farmland” 
    • Release the proposed rule for the Relending Program to Resolve Ownership and Succession on Farmland to enable the program to begin serving its vital purpose. 
  • Increase Participation and Collection of Demographic Data in the Census of Agriculture 
    • Increase outreach and education about the importance and value of the Census of Agriculture, and provide free assistance for completing the Census, especially targeting socially disadvantaged producers who may face language, technical, or other barriers. This should include partnering with community-based organizations to increase awareness of, and trust in, USDA surveys. 
    • Add additional demographic options to the Census of Agriculture to better capture diverse ethnic groups (e.g., in addition to “Asian,” offer options such as Hmong, Thai, Filipino, etc.), and further disaggregate—and make publicly available—Census data, especially regarding farm and producer characteristics of socially disadvantaged farmers and ranchers. A more complete understanding of which producers are not well served by USDA will help the department to better target its efforts. 
    • USDA should increase transparency regarding the impacts that changes in statistical methods have on demographic information from survey to survey since methodological changes can create false trends, such as the change in questions between the 2012 and 2017 Censuses that resulted in more farms reporting multiple individuals involved in farm operations. Survey results should be reported with necessary caveats about the changes to the survey methods so that trends in the landscape can be interpreted accurately.
  • Maximize Use of Alternative Rules to Help Socially Disadvantaged Producers Take Advantage of NRCS Conservation Programs  
    • Increase outreach and education to socially disadvantaged producers about EQIP’s increased reimbursement and up-front payment option for socially disadvantaged producers. USDA should also explore adjusting other program rules to address barriers to entry.  
    • Increase tracking of, and make publicly available, additional data on BIPOC producers, including engagement in USDA programs, utilization of alternative rules, and percentage of set-aside funding actually used. In addition, ensure at the very least that set-asides for socially disadvantaged producers within conservation programs are fully utilized.
  • Hire Additional USDA Staff and Provide Additional Training to Them on Issues of Special Importance to Socially Disadvantaged Producers 
    • Train USDA employees, especially those who work directly with producers, on issues of special importance to BIPOC producers. This should include, but not be limited to, additional training for FSA and NRCS field staff about the challenges and opportunities associated with ownership of heirs’ property, programs tailored to socially disadvantaged communities, and up-front payments and increased reimbursement rates for the Environmental Quality Incentives Program (EQIP). 
    • USDA should consider the creation of an Equity Liaison position to serve in all state-level USDA offices to advance equity in program participation and serve as a resource for socially disadvantaged producers. The Equity Liaison could report to the Office of the Assistant Secretary for Civil Rights or the Senior Advisor for Racial Equity, and should work closely with Special Emphasis Program Managers in order to mutually enhance efforts. The Equity Liaison would be tasked with: 
    • Ensuring that program materials are translated, simplified, and made accessible to relevant socially disadvantaged groups within the state. 
    • Ensuring that program outreach and education are being conducted in a culturally-sensitive and informed manner. 
    • Building relationships with trusted community organizations that could partner with USDA to bring services to socially disadvantaged producers. 
    • Hosting regular listening sessions to gather input from socially disadvantaged communities on their interactions with USDA, and how the Department can improve. 
    • Serving as a resource for socially disadvantaged producers who would like to file a discrimination complaint, or who need access to additional support in completing a program application or USDA survey. 
    • Make permanent the position of Senior Advisor for Racial Equity to the Secretary of Agriculture. 
    • Hire sufficient USDA staff to meet the department’s analysis of need and prioritize hiring field staff and technical assistance providers who are BIPOC, women, multilingual, and who possess the relevant social knowledge, to better serve socially disadvantaged producers. To cultivate this applicant pool, USDA should consider forming partnerships with pipeline programs that target socially disadvantaged populations such as MANNRS, HEAL Food Alliance School of Political Leadership, National Black Growers Council, National Women in Agriculture Association, etc. 
    • USDA should take advantage of the knowledge and experience of its own staff (especially Special Emphasis Program Managers and staff who work directly with BIPOC producers) in working with socially disadvantaged producers, and solicit recommendations from those staff on opportunities for improving program access for socially disadvantaged producers.
  • Use Recent Relief Funding to Scale-Up Business Technical Assistance  
    • USDA should set aside $300 million from the American Rescue Plan Act, to dramatically scale up one-on-one business technical assistance for small and midsize farm and food businesses, and ensure that a significant portion of this funding goes to organizations that have a track record of providing services to socially disadvantaged producers.
  • Develop Strong Partnerships with Community Organizations and Build their Capacity 
    • Offer capacity-building grants for non-profit organizations that provide financial and technical services to socially disadvantaged farmers and ranchers. These multi-year grants would help such organizations develop internal infrastructure such as hiring finance staff, purchasing financial software, receiving skills training, hiring consultants, and more. This internal development will help these organizations be more competitive for federal grants, thereby enabling them to hire additional staff and conduct additional outreach to the communities they serve.  
    • Provide technical assistance to BIPOC-serving organizations undergoing the Request For Proposals (RFP) process, to ensure timely, complete, and successful submittal. 
About the Author
Emily Liss

Federal Policy Associate

eliss@farmland.org

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