In latest request for public comment, it appears the USDA is ready to lead — here’s what we recommend

US forests and agricultural systems represent valuable carbon sinks, pulling carbon from the atmosphere to nourish trees and plants while helping to mitigate climate change. How can we scale durable and just carbon removal solutions that double as opportunities for economic growth, ecosystem restoration, and overall community resilience? The USDA asked and we answered. Last month, the agency published a request for public comment, and thousands of statements from farmworkers rights organizations, climate advocates, and nonprofits like us have been published in response. USDA seems ready to lead on forestry and soil carbon — and luckily, it’s one of our favorite topics to talk about.

For three years, we worked on the ground with farmers and ranchers in the Rocky Mountain West to understand the opportunities and challenges for land managers interested in soil carbon practices. We learned that primary barriers to scaling soil carbon storage include limited technical assistance and educational resources, a need for increased soil carbon science, and insufficient financial incentives. These challenges inform how we think about soil carbon policy today, and overcoming them will be imperative to ensure producers can access the full breadth of soil carbon benefits. The advantages of soil carbon storage extend beyond climate — while strategies like cover cropping and improved forest management can harness the carbon removal potential of working lands, co-benefits such as improved yields and healthier ecosystems are equally important.


USDA is in a position to not only support land managers in accessing the full suite of soil carbon and forest benefits but by including those who have historically been excluded. Expanding access and providing both financial and technical assistance to Black, Indigenous, People of Color, small-scale, young, and first-generation producers and forest landowners should be paramount in forthcoming policies. There is a vital and renewed commitment at the federal level to aligning climate action with environmental justice, per the USDA’s own mandate and the Biden administration.

We’re sharing an abridged version of our public comments below as we continue to work toward that common goal, guided by three core recommendations: expanding adoption of soil health and forestry practices, ensuring benefits and access for underserved ag and forestry communities, and calling for approaches that are grounded in science. Our original comments can be found published here.

Ground forest and soil practices in science

Soil and forest science is critical to the climate equation, and USDA would do well to invest accordingly. While there is a significant opportunity to further leverage forests and soils as carbon sinks, research is needed to better understand land management practices across geographies, measure and verify carbon storage, and develop the next generation of agriculture solutions. USDA can set a centralized, coordinated, and expanded research vision, working closely with Congress to ramp up RD&D funding in this area over time.

Data is the first important piece of the research puzzle. USDA should invest in social science research to equitably increase program enrollment through the Forestry Service research stations and USDA’s Economic Research. Research should be both qualitative and quantitative and include landowner recommendations for improvement. Additionally, USDA should seek to expand Forest Inventory Analysis (FIA) capacity, intensifying baseline sampling regionally.

Much has been said about the possibility of USDA supporting a voluntary carbon market — put simply, our existing measurement tools and protocols for soil carbon offsets don’t suffice. USDA should instead take leadership in developing the soil survey and inventories that could drastically improve emissions accounting practices so offset programs precisely reflect the durability of carbon storage. Existing inventories like the Natural Resources Conservation Service (NRCS) Soil Survey and Rapid Carbon Assessment and modeling tools like COMET-Farm can help with this initiative. It importantly paves the way for robust monitoring and verification for programs to come.

Embed equity and justice across program operations

Climate-smart practices must be accessible to underserved producers and forest landowners — contrary to USDA’s history of racial discrimination that has led to significant economic disparities among land managers. As USDA now seeks to redress past harms and implement policies that boost the climate resiliency of US lands, the Equity Commission should ensure that environmental justice deeply informs program design. The Government Accountability Office, too, should establish review mechanisms to root out discrimination.

USDA should collect and publicly release demographics information for all of its programs to establish baselines, and should further establish a task force, steered by Black farmers and civil rights organizations, to evaluate USDA’s civil rights offices. These initiatives can go a long way in establishing accountability, identifying barriers to programs, and redressing past harms in future policies. Following the Justice40 initiative model, USDA should ensure that a minimum 40% of benefits of all USDA programs flow to underserved communities.

We also recommend that strengthening the USDA Advisory Committee on Minority Farmers to ensure socially disadvantaged farmers have equal access to USDA programs. Meetings should be prioritized and members should represent socially disadvantaged farmers, representatives from nonprofit organizations focused on equity and justice in agriculture, civil rights professionals, and representatives from institutions for higher learning. There is a huge opportunity for USDA to co-create policies with disadvantaged communities by providing materials in other languages, openly sharing available data to promote inclusive decision-making, and involving trusted leaders within the agriculture and forestry communities to develop trust and understanding.

Boost voluntary adoption by expanding technical support and financial incentives

USDA programs that support soil carbon education and assistance are underfunded and oversubscribed. One of the most effective providers of technical assistance and education in the US, NRCS, can’t meet the significant demand for conservation planning without increased funding at the federal level. Also, SARE — which supports practice adoption-focused peer networks — can be expanded to facilitate mentorship and technical knowledge sharing between land managers. In addition to program expansion, decreasing the administrative burden for producers to access these programs would increase engagement, particularly for small land operations.

To additionally incentivize carbon storage, USDA could explore utilizing the Commodity Credit Corporation (CCC) — historically used as a safety net for the ag industry — to pilot practices that store carbon on farms and forests, providing producers with immediate financial relief in the face of COVID-19 impacts and extreme weather events while also building their long-term resilience to climate impacts with healthy soils.

The federal government can also encourage strong land management practices for private landowners, expand access to land, capital, and legal aid, and prioritize conservation program applications that focus on carbon health and storage or come from historically underrepresented groups.

Image: Immo Wegmann