April 29, 2021

Submitted via www.regulations.gov

Attention Docket ID No.: USDA-2021-0003

William Hohenstein
Director, Office of Energy and Environmental Policy
U.S. Department of Agriculture
1400 Independence Ave SW
Washington, DC 20250
ccpooce@usda.gov

The American Farm Bureau Federation (Farm Bureau) welcomes the opportunity to provide comments on how farmers, ranchers, and forest owners can deliver natural climate solutions. Farmers, ranchers, and forest owners have been battling the effects of challenging weather and changing climatic conditions not just for generations but for millennia. One of the toughest challenges American agriculture can face is dealing with the obstacles and variability that Mother Nature often hands us.

We urge that the work of the U.S. Department of Agriculture (USDA) be open and transparent. Given that any policy changes dealing with this matter will undoubtedly affect Americans from all walks of life, in every region, it is most appropriate to engage as broad a spectrum of opinion as possible.
Our grassroots members, comprised of hard-working farmers and ranchers, have developed the following policies relating to climate change and the regulation of greenhouse gasses (GHGs).

Farm Bureau supports the following:
• Market-based incentives, such as pollutant credit trading, are preferable to government mandates;
• Voluntary market carbon credit trading system that is not detrimental to other agricultural producers;
• Compensation to farmers for planting crops or adopting farming practices that keep carbon in the soil or plant material;
• Alternative energy sources, which will minimize atmospheric pollution;
• Incentives to industries seeking to become more energy efficient or to reduce emissions of identifiable atmospheric pollution and the means of preventing it;
• Market-based solutions, rather than federal or state emission limits, being used to achieve a reduction in GHG emissions from any sources;
• EPA’s re-evaluation of burdensome emission control rules for farming practices, farm equipment, cotton gins, grain handling facilities, etc; and
• The inclusion of the agricultural community as a full partner in the development of any policy or legislation.

Farm Bureau would oppose:
• Climate change legislation that establishes mandatory cap-and-trade provisions;
• Climate change legislation that is not fair, affordable or achievable;
• Any law or regulation requiring the reporting of any GHG emissions by an agricultural entity;
• Any climate change legislation that would make America less competitive in the global marketplace and put undue costs on American agriculture, business and consumers;
• Any climate change legislation until other countries meet or exceed U.S. requirements;
• Any regulation of GHG by EPA;
• Any attempt to regulate methane emissions from livestock under the Clean Air Act or any other legislative vehicle; and
• Taxes on carbon uses or emissions.

Whether it is excessive flooding or withering drought, farmers and ranchers rise each day to meet the challenges of the weather; we have no doubt that we will continue to adapt to a changing climate. Farm Bureau believes that there are tools and solutions that will make combating inclement weather less challenging without hindering our productivity or harming the U.S. economy.

American farmers and ranchers play a leading role in promoting soil health, conserving water, enhancing wildlife, efficiently using nutrients, and caring for their animals. For decades they have pushed past the boundaries of innovation by investing in agricultural research and adopting practices with the goals of improving productivity, enhancing sustainability, and providing clean and renewable energy. In fact, the use of ethanol and biodiesel in 2018 reduced greenhouse gas emissions by an amount equivalent to taking 17 million cars off the road.

Livestock and crop production are the heart of American agriculture, providing the food we enjoy every day. Ensuring this production continues sustainably is essential for people and the planet. Farmers have embraced technologies that reduced emissions and increased efficiency. Building upon the strong foundation of voluntary stewardship investments and practices, including those in the Farm Bill, we look forward to working with the agency to further advance the successful sustainable practices used by U.S. agricultural producers. Throughout this process, USDA must ensure that any governmental analysis characterizing U.S. crop and livestock systems reflects U.S. agriculture’s leadership globally in sustainable farming practices.

All told, agriculture accounts for roughly 10% of total U.S. greenhouse gas (GHG) emissions, far less than transportation, electricity generation, and industry sectors. Farmers continue to produce more with greater efficiency. In fact, U.S. agriculture would have needed nearly 100 million more acres in 1990 to match 2018 production levels.

U.S. farmers and ranchers have long been at the forefront of climate-smart farming, utilizing scientific solutions, technology, and innovations to raise crops or care for livestock. These efforts are designed to protect soil and water, efficiently manage manure, produce clean and renewable energy, capture carbon, and improve sustainability. Over two generations, we’ve been able to increase productivity by 287 percent, while using the same resources. In essence, we’re doing more with less.

Total carbon sink efforts from forestland management, land converted to forestry, grasslands, and wetland management more than offset agriculture’s contribution to total emissions. However, many of agriculture’s carbon sequestration efforts are not directly assigned to the agriculture sector. It is certain that if the carbon sequestration efforts of U.S. farmers and ranchers were assigned to agriculture, our contributions to GHG emissions would be significantly lower. It is worth noting that U.S. farmers have enrolled more than 140 million acres in federal conservation programs, equal to the total land area of California & New York combined. Millions more acres are dedicated to nonfederal conservation programs.

More productive livestock operations allow ranchers, pork producers, and dairy farmers to maintain their total contribution to GHG emissions at less than 3%, while also leading to lower per-unit GHG emissions.

U.S. farmers and ranchers contribute significantly fewer GHG emissions than their counterparts around the world. EPA data shows agriculture’s global contribution to GHG emissions was 24% in 2010, more than double U.S. farmers’ and ranchers’ contributions to total U.S. emissions in 2019. This significant difference is largely driven by farmers’ enthusiastic adoption of technology. Farmers are the pioneers of sustainability and should be recognized for their contributions, efficiency gains, and the considerable impact of their carbon sequestration efforts.

Farm Bureau believes that adaption strategies and tools can be utilized to face the challenges of more inclement weather and a changing climate. Increased funding and emphasis should be given to agricultural research and extension. Having the technology, traits and production practices will be more beneficial than burdening the economy with additional regulations.

Agricultural research and investment has given American agriculture a firm foundation to battle the challenges of producing food in the 21st century. We will need a further commitment to technology and research for agricultural producers to be competitive into the future and tackle the challenges thrown our way. In general, we could support the development and refinement of policies and strategies that foster adaptation.

We are committed to finding solutions to the challenges of climate variability while striving to find opportunities for economic prosperity. Only in working together can we achieve common sense solutions that not only make agriculture more resilient, but our country stronger without enacting policies that hampers the competiveness and productivity of America.

In this spirit, we felt it was important to convene a wide group of stakeholders to further explore policy options for farmers, ranchers and rural communities. What came out of that effort is now known as the Food and Agriculture Climate Alliance (FACA). FACA consists of organizations representing farmers, ranchers, forest owners, agribusinesses, manufacturers, the food and innovation sector, state governments, sportsmen and sportswomen, and environmental advocates. These groups have broken through historical barriers to develop and promote shared climate policy priorities across the entire agriculture, food and forestry value chains.

As stewards of the land, we have enormous opportunities to drive solutions that reduce greenhouse gas emissions, increase carbon sequestration and storage, build resilience to the changing climate and drive sustainability across the supply chain. This shared understanding is what led members of FACA to form such an unprecedented alliance. The group first united around three principles:
1. Support voluntary, market- and incentive-based policies.
2. Advance and accelerate science-based outcomes.
3. Promote resilience and help rural economies better adapt to climate change.

Over the past year, FACA members have worked to find areas of common policy interest and formulated over 40 specific policy recommendations. The majority of these recommendations fall within the scope of questions in the Request for Information (RFI).

The recommendations and full list of members can be viewed at www.agclimatealliance.com.

Enclosed you will find FACA’s response to the RFI, as we stand behind the consensus driven recommendations developed by the group. We look forward to working with the agency to drive climate-smart solutions while also enhancing economic opportunities for our farmers, ranchers and forest owners.

Sincerely,
Sam Kieffer
Vice President
Public Affairs
Enclosures: FACA RFI Response