A potential “climate-smart” label for food and USDA’s authority to fund large-scale pilot projects using the Commodity Credit Corporation was among the many issues addressed in nearly 400 comments submitted on USDA’s proposed Climate-Smart Agriculture and Forestry Partnership Initiative.

.The CSAF contemplates the adoption of pilot projects “to quantify and monitor the carbon and greenhouse gas benefits associated with those practices.” USDA said when it announced the initiative in September.

While in Glasgow for the COP26 climate conference, Ag Secretary Tom Vilsack talked up the new label, which is now simply an idea for how to incentivize low-carbon systems and provide a better return for farmers to adopt them.

“I think it would be beneficial for American farmers, if we had basically a standardized approach towards what a sustainably produced or climate-smart commodity actually consists of,” he said.

“In a sense, you've got organic crops and you’ve got the rest,” Vilsack said on a recent teleconference with reporters from the COP26 climate conference. “And this is, essentially, kind of the third category.”

First, however, “I think you have to have significant data collected about practices and the cumulative result of those practices from an environmental standpoint,” Vilsack said, which means there will have to be enough pilot projects with “sufficient size … and sufficient participation by farmers of all sizes, to be able to allow us to begin collecting the kind of information and data that will allow us to establish the standard.”

Tom VilsackAg Secretary Tom Vilsack“The market is demanding sustainability. The problem is the market doesn't do a particularly good job of defining what sustainability is,” he said. “And that's the purpose of this is … to establish that standard and help to establish that value-added component to whatever is being raised through climate-smart practices.”

Vilsack said he expected USDA to start funding projects next year through its Commodity Credit Corp. authority. “That’s based on the fact that what we're doing is we're helping to create and support a commodity, a climate-smart commodity,” he told Agri-Pulse in a recent interview.

Commenters on the program generally liked the idea but had concerns. 

The National Cattlemen’s Beef Association (NCBA) and Public Lands Council (PLC), for example, said they back private efforts “to develop new brands and labels to market beef, and urge USDA to support these efforts.” However, they cautioned “against developing a federally managed marketing program that cuts against the value created by years of brand development in the private sector.”

The National Milk Producers Federation, noting that there is currently no “U.S.-recognized sustainability standard,” said the dairy industry “would support developing and implementing a ‘green labeling’ scheme as a process verified program (PVP) ‘shield’ that dairy (and other commodities) can use to market sustainable dairy products.”

The National Cotton Council said USDA should “identify criteria that would enable partnering entities to make claims of a climate-smart product,” recommending that the “US Cotton Trust Protocol continue its work meeting sustainability metrics and expand to include metrics meeting USDA Climate Smart Product qualifications.”

The Environmental Defense Fund said the program could be a boon for early adopters of climate-smart practices, "who may not qualify to sell credits through carbon markets.” Instead, they could fetch a premium through the sale of climate-smart commodities.

The American Soybean Association noted standards are already in place for its growers. 

“Most U.S. soybean farmers are already following the conservation regulations and farming practices outlined in the U.S. Soybean Sustainability Assurance Protocol (SSAP), an international marketing tool that uses a mass-balance approach to verify sustainable production at a national scale,” ASA said.

The protocol “is already supported by USDA and is positively benchmarked against international soy sourcing guidelines which include requirements for soy growers to continuously improve their sustainability performance. Soy that is verified sustainable under the SSAP allows companies to use a trademarked ‘Sustainable U.S. Soy’ logo on product packaging.”

The Organic Trade Association said climate-smart products should not be eligible for an accompanying label “based on the adoption of a single practice,” but on “a life-cycle analysis of the relevant product to ensure climate-positive outcomes of the entire soil-to-retailer process. CSAF should consider restricting climate-smart or climate-friendly labeling to producers or groups that can demonstrate net-zero carbon greenhouse gas emissions without the use of offsets.” 

And the National Sustainable Agriculture Coalition warned that “weak standards and lax enforcement” could lead to “greenwashing.”

“Changes like incorporating methane digesters or single annual cover crops should not count as climate-friendly because they will not provide the permanent, additional carbon sequestration needed,” NSAC said. “Addition of single, annual cover crops to a simple corn-soy rotation in the Midwest, for example, does not permanently sequester carbon and can offer the possibility for leakage of greenhouse gas emissions to other fields, operations, or sectors.”

In other comments on how to shape the program, digesters received a mixed reception and were sometimes criticized for incentivizing the expansion of climate-unfriendly practices. NSAC, for example, said that while they “convert an especially damaging greenhouse gas into a somewhat lower-impact greenhouse gas,” they also support “a system of agriculture that relies on high-emission inputs for its fertilizers, pesticides, transport, and its style of animal husbandry.”

On the flip side, digesters were touted by many ag groups as a way to reduce methane, a GHG at least 25 times more powerful than carbon dioxide in trapping heat. The American Biogas Council, which includes representatives from the dairy industry and anaerobic digester manufacturers, said “recycling organic material in a digester not only captures this destructive gas but also recycles the valuable nutrients needed for sustainable farming — nitrogen, phosphorus, potassium, calcium, sulfur, micronutrients, and more.”

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Some questioned the use of the CCC as the authority for the program. NCBA and PLC, for example, said they had “significant concern” with the use of the CCC funds. 

“USDA can play a valuable supporting role for producers and private markets by providing robust research and pilot projects,” the groups said. However, they added, “It is our shared concern that overinvestment in pilot projects would effectively create a new government program that directly competes with, and undercuts the value of, voluntary ecosystem service markets.”

And Food & Water Watch said USDA “may only rely on its discretionary powers to use CCC funds when it aims to expand or develop new markets for agricultural commodities. Neither ‘climate-smart’ agricultural production practices, nor industrial livestock waste or waste byproducts constitute ‘agricultural commodities’ as contemplated by the CCC’s enabling statute. Therefore, absent congressional authorization, USDA cannot lawfully move forward with this program.”

But the Natural Resources Defense Council said “scaling up investments in climate-smart agriculture and forestry, both through existing programs and new initiatives, will help farmers navigate financial, technical, and social challenges that may arise as they innovate, as well as ensure that public investments prioritize the needs of the most underserved populations and maximize benefits to public health, ecosystems, and local economies. Such investments fall squarely within the purposes and powers of the (CCC).”

Other commenters also said they were worried USDA’s program would interfere with already existing private carbon markets.

Specifically, on the question posed by USDA of whether it should “establish a consistent payment per ton of GHG generated through these partnership projects as part of the project payment structure, or evaluate a range of incentive options,” the Ecosystem Services Market Consortium said, Unless USDA is considering purchasing credits on existing markets, it is unclear why the agency would set a price on GHG.”

There is already more demand than supply “for GHG offsets and insets in markets that generate validated and high-quality credits,” ESMC said, adding it “does not believe USDA should compete with private sector buyers in these markets, and thus should not be setting prices or purchasing credits.”

There were numerous calls for increased funding for existing USDA programs. NSAC, for instance, said the Conservation Reserve Program should receive additional resources “to maximize CRP’s long-term contribution to climate mitigation by allowing the economic use of tree crops.” In addition, CCC funding should be provided for the Grazing Lands Conservation Initiative, “which has lacked funding since 2008 despite being a clearly climate-friendly initiative.”

The Savanna Institute in Wisconsin, which supports the adoption of agroforestry practices in the Midwest, pushed for an expansion of funding and staffing for USDA’s National Agroforestry Center, to “support acceleration of adoption of woody perennial agriculture and conservation.

“For example, alley cropping, windbreaks, silvopasture, and woody riparian buffers have some of the highest carbon sequestration potential of any agricultural practices. But these are not seen as adaptable and scalable by many due to lack of regional research, evaluation, and demonstration,” the institute said.

The National Association of Wheat Growers said “USDA should also support expanded research of climate-smart practices in semi-arid areas and the resulting impact on food crops.”

USDA plans to have the program up and running in “the first part of 2022,” Vilsack said. “The hope would be that we wouldn't take a very long time before we begin making decisions” about what pilots should receive support.

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