The Sustainable Food Policy Alliance (SFPA) submitted the following comments to the U.S. Department of Agriculture regarding the implementation of the Regional Conservation Partnership Program and other conservation measures in the 2018 Farm Bill. See the original submission in the Federal Register here.
Re: 2018 Farm Bill Implementation Listening Session, Notice, Docket No. USDA-2019-0001, 84 Fed. Reg. 4041 (February 14, 2019)
To Whom It May Concern:
Thank you for the opportunity to provide comment as USDA prepares to implement the new authorities and policies provided by the recent passage of the Agriculture Improvement Act (commonly known as the Farm Bill). While our companies have various interests in the policies enacted, we want to provide a joint comment on policies that we collectively advocated for during the Farm Bill debate. We believe Congress provided valuable new tools to promote partnerships between food companies and agricultural producers in our supply chains to scale sustainability and economic resiliency at the farm-level. We encourage USDA, for example, to implement the Regional Conservation Partnership Program (RCPP) and other tools for improved soil health management in a manner that is simple and more applicable to leverage corporate resources and scale our efforts with our farming partners for soil health improvement.
Similar to our statements made to Congress during the deliberation of the Farm Bill, we encourage you to consider the following to ensure conservation funding can assist farms in our sustainable partnerships towards improved soil health:
1. Applications—We respectfully ask that applications make it easier for partnerships to form and once they do form, the process for farms are expedited to ensure timely delivery or improved soil health practices. Additionally, it is challenging for a company to work through various Natural Resource Conservation Service (NRCS) state offices when a partnership includes a supply chain that is not confined to political boundaries.
2. Grants—The new grant authority in the RCPP is a significant opportunity to provide innovative approaches that streamline the process for partners such as food companies to contract with producers for holistic soil health management. Also, USDA should consider the opportunity for larger awards to optimize opportunities for scale such as supply chains.
3. Reporting—Investing in more sustainable supply chains means measuring and reporting outcomes. We have a strong interest in knowing that our farming partners, through improved soil health, for example, are increasing both environmental and economic impacts. We encourage NRCS to work with potential partners such as our companies on guidance so that partnerships provide credible reporting.
4. In-kind matches—We are already committing significant resources to salaries, research and partnerships for technical advice as we implement sustainable management with our farming partners. We ask that these various costs be considered if we apply with our farming partners for NRCS assistance.
We sincerely thank you for your diligence to implement these substantial opportunities for farms and people consuming our products. Please do not hesitate to reach out with any questions.