On January 27, 2021, President Biden issued an Executive Order on Tackling the Climate Crisis at Home and Abroad. This Executive Order laid out a series of actions for Federal Agencies to take regarding climate change mitigation and resilience, including directing the Secretary of Agriculture to collect stakeholder input on a climate-smart agriculture and forestry strategy, including:
1. Climate-Smart Agriculture and Forestry Questions
2. Biofuels, Wood and Other Bioproducts, and Renewable Energy Questions
3. Addressing Catastrophic Wildfire Questions
4. Environmental Justice and Disadvantaged Communities Questions
Tennessee Interfaith Power & Light responded with the following:
April 28, 2021
Secretary Tom Vilsack
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250 via regulations.gov
RE: Notice of Request for Public Comment on the Executive Order on Tackling the Climate
Crisis at Home and Abroad, 86 Fed. Reg. 14403 (Mar. 16, 2021), Docket No. USDA–2021–0003
Dear Secretary Vilsack:
Tennessee Interfaith Power & Light (TIPL) is the state affiliate of a network of faith communities
working across the United States, offering a spiritual response to climate change. Our mutual
efforts will protect our climate through upholding the sacredness of life, defending those most
vulnerable to the many impacts of climate change, and advocating for effective climate
protection policies. Our mission is to spiritually respond to the challenges of the climate crisis
through upholding the sacredness of all life, protecting vulnerable communities, and caring for
the Earth. We manifest our spiritual values by reducing our carbon footprint within our daily
lives, releasing the spiritual power of our faith communities, and advocating for transformative
climate protection and justice policies.
TIPL offers the following comments on the Notice of Request for Public Comment on the
Executive Order on Tackling the Climate Crisis at Home and Abroad, Docket No.
USDA-2021-0003.
1. Climate-Smart Agriculture and Forestry
Questions
A. How should USDA utilize programs, funding and financing capacities, and other authorities,
to encourage the voluntary adoption of climate-smart agricultural and forestry practices on
working farms, ranches, and forest lands?
1. How can USDA leverage existing policies and programs to encourage voluntary
adoption of agricultural practices that sequester carbon, reduce greenhouse gas
emissions, and ensure resiliency to climate change?
USDA administers numerous programs to guide the nation’s agricultural practices and
economies. Many of these programs have been successful in conserving our country’s
natural resources, including soils, water quality and wildlife habitat. Examples of some of
these successful programs include the Conservation Reserve Program, Wetland Reserve
Program and Forest Legacy Program, which have been popular with landowner/
producers, and have stood the test of time.
Unfortunately, not all USDA programs have achieved their hoped for conservation
outcomes, and in some cases, have adversely impacted our country’s natural resources.
One such example is the program to promote corn ethanol as a preferred biofuel
alternative. While we understand the rationale for promoting biofuel alternatives for
automobiles, TIPL believes that the corn ethanol program has been conducted in an
unsustainable way, resulting in the conversion of millions of acres of natural lands to
agriculture, reduced wildlife and pollinator habitats, increased pollution in our
waterways, and ultimately may have resulted in increased carbon emissions.
The USDA should examine each of its existing agriculture and forestry policies and
programs, and conduct an assessment of their sustainability. At a minimum, that
assessment should include their collective impacts on people and the environment,
cost-benefit analyses to assess their effectiveness and economic soundness, and
should determine whether they are likely to reduce carbon emissions. It is estimated
that agriculture and forestry activities are responsible for approximately 24% of global
greenhouse gas emissions, so USDA has an important role, and many tools that it can
employ to reduce these emissions. TIPL recommends that a comprehensive review of all
programs administered by USDA; programs that are not achieving the Biden
Administration’s goals of reducing carbon emissions should be revised to meet the
Administration’s goals, or eliminated if they cannot be re-formulated satisfactorily.
2. What new strategies should USDA explore to encourage voluntary adoption of climate-smart
agriculture and forestry practices?
USDA should look into re-forestation and forest carbon sequestration as tools to reduce
emissions from agricultural lands. One area that should be explored is providing financial
assistance to landowners who would like to participate in carbon credit markets. These
markets are expected to grow over the next several years as more corporations look for
ways to effectively reduce their carbon emissions. However, the costs of enrolling
forestlands into these markets can be prohibitive for many landowners, and many
landowners lack the technical expertise needed to effectively participate in carbon credit
markets, which can be complex. Expertise is needed to understand how carbon offset
markets work, what kinds of data and inventories need to be compiled and tabulated,
and how to develop effective forest management plans in order to make their lands
eligible for these programs. TIPL recommends that USDA explore opportunities to
provide landowner assistance program(s) to encourage and assist private forest lands to
enroll in carbon credit markets.
USDA should also look into strengthening its programs and outreach to small farmers,
especially to assist the growing market for local food sources. In many cases, our
nation’s industrialized agricultural systems have resulted in agricultural crops being
transported across the country to meet the demands of consumers. However, these
operations in heavily agricultural regions (for example, central California) can result in the
depletion of aquifers, and increased emissions from the transportation and storage of
these crops. USDA should conduct a comprehensive review of its policies regarding
these agricultural systems, and explore new strategies to encourage more locally grown
foods, and encourage small farmers to supply the food needs of local communities.
Another area that USDA should explore is the promotion and development of tools and
outreach materials to enhance the growth of residential and community gardens.
Climate Victory gardens have been inspired by the Victory Gardens that were grown in
the US after World War 2. These gardens produced almost half of fruits and vegetable
consumed by the country. Today thousands are now growing regenerative climate
victory gardens. These include practices to help reverse global warming. Simple
practices which include growing without pesticides, using cover crops, and composting
help build healthy soil to help draw down carbon overload and eliminate transportation
emissions from transporting food. Already over 8,000 gardens across the country are
drawing down over 4,000 tons of carbon per year and are eliminating over 40,000,000
miles of transporting emissions. It can be easy for anyone to participate in this effort,
and TIPL recommends that USDA explore the development of online tools and other
promotional materials that will encourage everyone across the land to grow a Climate
victory garden or join in a community garden.
B. How can partners and stakeholders, including State, local and Tribal governments and the
private sector, work with USDA in advancing climate-smart agricultural and forestry practices?
N/A
C. How can USDA help support emerging markets for carbon and greenhouse gases where
agriculture and forestry can supply carbon benefits?
As noted above, many landowners do not know where to start when it comes to
participating in the emerging carbon credit markets. These can be very complex, and
require long-term commitments (40-100 years) from landowners to enroll their lands and
generate credits. USDA should look into providing financial and technical assistance to
landowners who desire to participate in these programs.
D. What data, tools, and research are needed for USDA to effectively carry out climate-smart
agriculture and forestry strategies?
There are numerous databases, tools, and research reports that are already available to
implement robust climate-smart agriculture and forestry strategies. Many of these
scientific assets have been produced by USDA scientists. One example is the online
carbon estimator tool, COLE, which was developed by US Forest Service scientists.
There are a number of other tools that are publicly available to assist landowners in
developing climate-smart strategies for their agricultural and forestry operations. TIPL
recommends that USDA conduct a comprehensive review of these publicly available
datasets, tools, and research products, to assess where there might be gaps in our
current knowledge. TIPL also recommends that USDA partner with universities and
other scientifically oriented non-profit organizations to develop any new databases, tools
or research that will advance our knowledge and ability to reduce agricultural and
forestry related carbon emissions and mitigate climate change impacts.
One area USDA where should increase its scientific efforts is the impacts of agriculture
and forestry related activities on the sustainability of our nation’s ecosystems and
biodiversity. USDA should look for opportunities to target their climate-smart strategies
in landscapes and regions where agriculture (and to some extent, forestry) has adversely
impacted ecosystem integrity and sustainability, reduced pollinator habitats, disrupted
aquifers, and increased pollution into our rivers and streams through excessive fertilizer
applications and sediment runoff. There are many examples across our country where
these impacts have occurred; two examples include the mid-western corn/soybean
system, and the lower Mississippi Valley where wetlands have been lost to agricultural
conversion. USDA should continue to look for opportunities to restore these ecosystems
through targeted conservation programs. These targeted approaches will have the
mutual benefits of not only reducing greenhouse gas emissions, but also helping to
restore these ecosystems to a more sustainable state.
E. How can USDA encourage the voluntary adoption of climate-smart agricultural and forestry
practices in an efficient way, where the benefits accrue to producers?
One area that USDA should explore to encourage more participation and adoption of
climate-smart practices is to allow landowners and producers to aggregate their lands
into multi-landowner projects. This approach is already being used for some forest
carbon credit projects through the American Carbon Registry (and others), and has the
benefits of reducing landowner costs (for forest and carbon inventories) and improved
efficiencies.
2. Biofuels, Wood and Other Bioproducts, and Renewable Energy Questions
A. How should USDA utilize programs, funding and financing capacities, and other authorities
to encourage greater use of biofuels for transportation, sustainable bioproducts (including
wood products), and renewable energy?
Unfortunately, the Renewable Fuel Standards program has resulted in much damage to
our ecosystems, especially in the midwest where millions of acres of natural lands were
converted into monoculture corn systems. The impacts have been devastating for
ecosystems and many wildlife species and pollinators, while producing questionable
benefits for reducing our nation’s greenhouse gas emissions. The number of acres of
corn grown on an annual basis in our country is higher than it’s been since the 1930’s,
approximately 90-100 million acres, but corn production is higher than it’s ever been
due to increased fertilization and improved farming practices. Indeed, the majority of
corn grown in the United States is not grown for human consumption, but is instead
grown for ethanol or feedstock for beef production and other livestock. These uses do
not constitute sustainability by any metric, and are likely to increase greenhouse gas
emissions, not reduce them.
The adverse impacts of the corn ethanol program have been well documented, and are
summarized in a number of reports. One such report was published by the National
Wildlife Federation in 2016 (DeGennaro, D. 2016. Fueling Destruction: The Unintended
Consequences of the Renewable Fuel Standard on Land, Water, and Wildlife.
Washington, DC: National Wildlife Federation). It details 1) the loss of millions of acres of
natural lands, primarily in the midwest; 2) the adverse impacts on numerous wildlife
species, including grassland birds and waterfowl, Monarch butterflies and other
pollinator species; 3) the decline of water quality in many areas, “in large part due to
agricultural runoff, killing aquatic life and promoting toxic algal blooms that threaten
human health and render water supplies undrinkable”; 4) and notes that “Intensive row
crop agriculture is expanding into more arid lands requiring heavy irrigation, while
ethanol refineries consume very large volumes of water, adding additional stress to areas
already burdened with declining aquifers and water storage.”
Clearly, the corn ethanol system has been devastating to the natural world in our
country, and it is debatable whether farmers have benefited from such reliance on a
monoculture system that has resulted in tens of millions of acres planted to one crop,
corn. USDA should re-evaluate its programs that drive this system, and look for ways to
wean farmers away from unsustainable monoculture farming systems, and provide
incentives for more holistic and sustainable farming practices. As our nation weans
itself away from fossil fuels for our energy needs, the need for biofuels in general, and
corn ethanol in particular, will likely decline. USDA should begin the process of
transforming its agricultural systems to understand that emerging reality, and to meet
the future needs of feeding our country.
B. How can incorporating climate-smart agriculture and forestry into biofuel and bioproducts
feedstock production systems support rural economies and green jobs?
N/A
C. How can USDA support adoption and production of other renewable energy technologies in
rural America, such as renewable natural gas from livestock, biomass power, solar, and wind?
TIPL strongly supports the transformation of America’s energy needs from fossil-based
fuels to sustainable and renewable sources. We believe that the technologies needed to
accomplish that transformation already exist in large part, especially with the solar and
wind energy sectors. Therefore, we support the use of these technologies to transform
agricultural energy needs and production in ways that are sustainable, and not injurious
to ecosystems or the species that inhabit those systems.
The technologies to support renewable natural gas (RNG) from livestock are less
advanced than solar and wind power, and according to a research report by the World
Resources Institute (Renewable Natural Gas as a Climate Strategy: Guidance for State
Policymakers), some challenges still exist to make RNG from livestock a truly viable
strategy for de-carbonization. That said, RNG can help reduce methane emissions,
which would be an important benefit in terms of mitigating greenhouse gas emissions.
To the extent that RNG can help reduce methane emissions, TIPL is supportive of USDA
promoting the adoption of these technologies.
Regarding biomass power, we have already provided comments on our concerns about
the corn ethanol alternative fuel system. We refer you to those aforementioned
comments, and recommend that biomass power systems be especially mindful of their
sustainability, and impacts on ecosystems and species that inhabit those systems.
3. Addressing Catastrophic Wildfire Questions
A. How should USDA utilize programs, funding and financing capacities, and other authorities
to decrease wildfire risk fueled by climate change?
N/A
B. How can the various USDA agencies work more cohesively across programs to advance
climate-smart forestry practices and reduce the risk of wildfire on all lands?
N/A
C. What additional data, tools and research are needed for USDA to effectively reduce wildfire
risk and manage Federal lands for carbon?
N/A
D. What role should partners and stakeholders play, including State, local and Tribal
governments, related to addressing wildfires?
N/A
4. Environmental Justice and Disadvantaged Communities Questions
A. How can USDA ensure that programs, funding and financing capacities, and other
authorities used to advance climate-smart agriculture and forestry practices are available to
all landowners, producers, and communities?
It appears that USDA developed an Environmental Justice Strategic Plan in 2016, which
was intended to guide the Department’s Environmental Justice efforts through 2020.
However, there is little information on efforts by the Department to implement that
Strategic Plan since its release in 2016. Hence, it is unclear whether the Trump
Administration did anything to advance the goals and objectives of that plan. A first step
for USDA under the Biden Administration would be to re-visit the 2016 Strategic Plan,
and assess progress or lack thereof since that plan was released. In reviewing the
Strategic Plan, it seems that the goals and objectives that were drafted at that time are
still relevant. Below are the 6 goals of the plan:
Goal 1: Ensure USDA programs provide opportunities for environmental justice
communities.
Goal 2: Increase capacity-building within environmental justice communities.
Goal 3: Expand public participation in program operations, planning activities, and
decision-making processes to benefit environmental justice communities.
Goal 4: Ensure USDA!s activities do not have disproportionately high and adverse
human health impacts on environmental justice communities and resolve
environmental justice issues and complaints.
Goal 5: Increase the awareness, skills, and abilities of USDA employees regarding
environmental justice.
Goal 6: Review, Update and/or Develop Departmental and Agency Policies and/or
Regulations to Address Environmental Justice
TIPL believes that the USDA Environmental Justice Strategic Plan: 2016-2020 is a great
place lo start in addressing the persistent inequities that environmental justice
communities have suffered over the decades. The Plan provides many objectives and
and metrics by which to measure progress toward the 6 goals above. TIPL recommends
that USDA use this plan as a starting point, re-evaluate its goals, objectives and
measures, and revise to meet the current status of environmental justice in 2021.
B. How can USDA provide technical assistance, outreach, and other assistance necessary to
ensure that all producers, landowners, and communities can participate in USDA programs,
funding, and other authorities related to climate-smart agriculture and forestry practices?
See above answer for question 4.A.
C. How can USDA ensure that programs, funding and financing capabilities, and other
authorities related to climate-smart agriculture and forestry practices are implemented
equitably?
See above answer for question 4.A.
Thank you for the opportunity to comment on this Notice of Request.
Sincerely,
Greg Wathen, on behalf of Betsy Garber, President,
Tennessee Interfaith Power & Light
