January 10th, 2023
By Emily Liss
Policy Update: AFT Submits Comments to NRCS on Implementation of IRA Conservation Funding
On December 21, AFT submitted comments to USDA NRCS regarding implementation of $20 billion in new climate-related conservation funding from the Inflation Reduction Act (IRA), passed in August. This historic funding has the potential to reshape the face of conservation in America through heavy investments in existing NRCS conservation programs over the next four years. Because of the wide scope from USDA’s request for information (RFI), AFT’s comment was split into three documents.
One comment, focused on ACEP, was written in coordination with the AFT-led Farm Bill Agricultural Land Protection Partnership, a group of agricultural land trusts and state Purchase of Agricultural Conservation Easement (PACE) programs. Given that IRA funding for ACEP must prioritize projects with the greatest climate benefits, AFT and partners were concerned that NRCS would direct this funding toward wetland protection and grasslands of special significance, thus excluding many traditional ACEP-ALE projects. AFT spearheaded the development of comments that emphasize the many climate benefits of agricultural land protection. The comments recommend that NRCS recognize those benefits and not require additional conditions on ALE projects that will discourage landowner participation or further delay projects. The comments also urge NRCS to take a portfolio approach to funding ACEP, so that additional ALE cropland projects could be funded with the traditional ACEP funding pool if IRA funds are directed to wetlands and grasslands. A total of 33 partners signed onto the comments, including state Departments of Agriculture, county agencies, and land trusts. While NRCS may focus on wetlands and grasslands easements with the FY 2023 IRA funds, the comments provide a foundation for ongoing discussion with the Department regarding following years of ACEP funding. It is important to note that the amount of IRA funding for ACEP is relatively small for FY 2023 when compared with subsequent years.
The second part of AFT’s comments focused on the RFI’s questions regarding USDA’s use of partnerships as well as potential improvements to the efficiency and function of existing NRCS programs. This comment was heavily based on the whitepapers AFT has been developing to support its 2023 Farm Bill platform, and also reflected recommendations from other organizations on topics such as the Technical Service Provider Program.
One of AFT’s key priorities regarding IRA implementation is ensuring that funding is efficiently and effectively expended. Given this, AFT urged NRCS to take advantage of partnerships to help deliver conservation as well as deploy innovative and targeted technical assistance and other support to help farmers adopt climate-smart practices. In doing so, AFT highlighted examples of its own successful partnerships with the agency. The comment also stressed the need for NRCS to provide adequate technical assistance to producers and to ensure that all farmers – regardless of race, location, production system, size, etc. – have access to this new funding. In addition, AFT urged NRCS to simplify and expedite program applications, increase overall staffing, offer longer-term support to producers while they integrate new practices, and increase payment rates. Finally, the document recommended that NRCS broaden their list of IRA-eligible practices to include those that enable the adoption of climate-smart practices, such as irrigation.
A third AFT comment focused on the RFI’s questions regarding the quantification of climate benefits, and which specific practices to prioritize for IRA funding. AFT’s recommendations included the creation of an interoperable database for NRCS to track climate benefits across all programs and practices as well as support for long-term research sites, the addition of soil carbon amendments as an IRA-eligible practice, and prioritization of climate-smart practice bundles.