NFFC Comments on Farm Bill Implementation

The US Department of Agriculture (USDA) is holding a series of listening sessions on implementation of the 2018 farm bill. NFFC submitted the following comments in conjunction with these sessions.

USDA Farm Bill Implementation Listening Session, March 21, 2019
Comments submitted March 29, 2019

Session hosted by USDA’s Research, Education, and Economics mission area, regarding new programs and changes to existing programs implemented by the Agricultural Research Service (ARS), Economic Research Service (ERS), National Agricultural Statistics Service (NASS), National Institute of Food and Agriculture (NIFA), and the Office of the Chief Scientist (OCS).

Established in 1986, National Family Farm Coalition is a coalition of grassroots organizations representing the rights and interests of family farmers, ranchers, and fishermen. On behalf of our 32 member organizations in 42 states, we urge USDA to consider the following provisions in the implementation of H.R. 2 (115), the 2018 Farm Bill:

Strengthening the Farming Opportunities Training and Outreach (FOTO) Program

In Section 12301 of the Farm Bill, Congress merged the authorizations of the US Department of Agriculture’s (USDA) Outreach and Assistance for Socially Disadvantaged Farmers and Ranchers and Veteran Farmers and Ranchers Program (OASDVFR) and the Beginning Farmers and Ranchers Development Program (BFRDP) and provided permanent direct baseline funding of $50 million annually to the two programs. Linking these two complementary programs strengthens them both, with OASDVFR supporting hands-on technical assistance and outreach to historically underserved farmers and BFRDP focusing on education and training for new entry farmers and ranchers.

Stakeholder engagement is critical to the success of FOTO. As USDA develops processes and procedures for this new landmark FOTO program, it should seek input and guidance from key stakeholders, including but not limited to the Minority Advisory Board and Beginning Farm Advisory Board. Both BFRDP and OASDVFR have much to benefit from working together, and it is important to recognize that each program supports specific groups of producers and prioritizes different areas of support for farmers in education and training.

NFFC is encouraged to see that USDA will establish a peer-review process to ensure that the FOTO program is accessible and accountable to those serving our nation’s vulnerable farming communities. We urge the agency to ensure that development of this peer-review process is objective and transparent and to invite stakeholder input on its development. In particular, we suggest the following processes:

  • Both agencies implementing FOTO should review each other’s existing grants review process and assess best practices. The National Institute of Food and Agriculture (NIFA), on behalf of BFRDP application review, hires several regional coordinators to vet individuals interested in sitting on the peer review panel, and ultimately “hires” them, according to a rubric. NIFA would benefit from assessing this process, and should consider implementing a term limit on the regional coordinator position to ensure rotating expertise in the area of peer recruitment.
  • The Office of Partnerships and Public Engagement (OPPE), on behalf of OASDVFR application review, has a ranking system in place whereby Universities, NGOs, and Land Grant Universities are ranked only among each other, not as one complete pool of applicants, and have pre-set allowances for what percent of grants are awarded in which category. This process, depending on how it is constructed, can help ensure that applications of non-profits and underserved groups are weighed against their peers, and not against projects of more academic nature.
  • The USDA Secretary should take into account the statutory requirement to prioritize community-based organizations, and to abide with requirements for demonstrated service with respect to the populations the programs ultimately serve.

Furthermore, NFFC encourages USDA to ensure that the application process of FOTO is accessible to farmers and community-based farmer support organizations with limited technical capacity. USDA should implement a three-year grant cycle for OASDVFR grants, with a funding maximum, in order to assure best investment of the funds for real impact, to remain consistent with the current process for BFRDP grants, and to adhere to the requirements of the FOTO Farm Bill language.

The Farm Bill also requires the USDA Secretary to establish a waiver of matching funds protocol for certain BFRDP grant applicants. This is an important provision in the FOTO Farm Bill language but must be executed with guidance from stakeholders who secured the language. Use of this waiver needs to be restricted to Non-Profit applicants and ranked to assist those most in need of a waived match, prioritizing majority-led “socially disadvantaged” organizations and projects.

Finally, NFFC urges USDA to allow a minimum 60-day application period for FOTO to ensure those under-resourced communities and organizations with limited technical capacity have a fair opportunity to apply.

 

Federal Investment in Agricultural Research

Family farmers depend on the reliable production of timely, accurate and objective food, agricultural, rural economic and resource statistics and market information. USDA’s Economic Research Service (ERS), National Agricultural Statistics Service (NASS), and National Institute of Food and Agriculture (NIFA) produce this valuable data, which directly informs farmers’ business decisions. NFFC supports federal investment in objective agricultural research through the 2018 Farm Bill, and is concerned by recent proposals to cut this federal funding. NFFC supports continued funding, at historic levels, for these services and programs, with clear transparency provisions to ensure the integrity and objectivity of federal research is not impacted by political interference.

Relocation of Economic Research Service and the National Institute of Food and Agriculture

USDA’s research mission area is a critical service for diversified family farming. NFFC has serious concerns regarding USDA’s proposed relocation of ERS and NIFA and the reorganization of ERS. These proposals are likely to have significant negative impact on U.S. farmers, ranchers, consumers, and researchers. The rationale provided by the USDA for the relocation also fails to identify problems substantive enough to justify such a disruption of ERS’s and NIFA’s operations, and jeopardizes the much-needed growth in funding for both agencies’ programs. Equally concerning is that USDA made its decision last summer without stakeholder or congressional input. We urge USDA to not use any funding allocated by Congress for agricultural research for relocation or reorganization of ERS and that no funding be used for NIFA relocation outside of the Washington D.C. area.

Support for the Farmer and Rancher Stress Assistance Network

The 2018 Farm Bill recognizes that farmers and individuals who work in agriculture face highly stressful working conditions, which can contribute to serious behavioral health concerns, especially during downturns in the farming economy. The Farmer and Rancher Stress Assistance Network is a critical service to address this challenge that NFFC is encouraged to see funded through Section 7412 of the 2018 Farm Bill. NFFC urges the USDA Secretary to solicit input from organizations with demonstrated experience in assisting farmers in crisis to initiate discussion on the data, program narratives and statements of work that can be used to prepare for Farmer and Rancher Stress Assistance grants. The Secretary should assure that organizations and advocates with demonstrated experience working with Tribes and Historically Underserved Populations are included in these discussions and in assuring organizations qualified to address these needs in historically underserved populations have access to these grants and contracts.

Support for Sustainable Agriculture Research

NFFC strongly supports the following sustainable agriculture research initiatives and programs:

  • The Sustainable Agriculture Research and Education Program (SARE): As the only federal farmer-oriented competitive research and outreach program, SARE is critical for advancing regionally-based and farmer-led research. This kind of participatory research is important for identifying and strengthening farmer adaptation and innovation to a wide range of economic, social, and environmental challenges facing the family farming sector. NFFC applauds Congress’s reauthorization of SARE through in the 2018 Farm Bill and encourages USDA to ensure and document expanding access of vulnerable and historically underserved communities to this program.
  • The Organic Agriculture Research and Extension Initiative (OREI): OREI is an important initiative supporting family farmers’ investment in organic and sustainable agriculture practices through research, education, and farmer technical assistance. NFFC applauds Congress’s expanded funding of OREI through Section 7210. of the 2018 Farm Bill and encourages USDA to ensure and document expanding access of vulnerable and historically underserved communities to this initiative.
  • Public Plant Breeding: Public plant breeding that provides diverse, open-access and regionally-adapted seeds is a critical service for family farmers. NFFC was disappointed that the 2018 Farm Bill did not establish dedicated funding for public plant breeding research. We encourage Congress and USDA to ensure adequate funding is provided for this important area of work.

 

USDA Farm Bill Implementation Listening Session, March 14, 2019
Comments submitted March 29, 2019
Session hosted by USDA’s Rural Development mission area.

 

Established in 1986, National Family Farm Coalition is a coalition of grassroots organizations representing the rights and interests of family farmers, ranchers, and fishermen. On behalf of our 32 member organizations in 42 states, we urge USDA to consider the following provisions in the implementation of H.R. 2 (115), the 2018 Farm Bill:

Support for the Local Agricultural Market Program (LAMP)

Strengthening local and diversified agricultural markets and community-based food systems is central to the family farming sector and critical for addressing a number of economic, social, environmental, and public health challenges. NFFC was encouraged to see LAMP authorized and funded through Section 10102 of the 2018 Farm Bill. NFFC urges USDA to implement LAMP in accordance with the intent of Congress, as demonstrated by the 2018 Farm Bill language, in a transparent and equitable manner.

Conclusion

We thank USDA for the opportunity to submit these written comments and urge USDA to incorporate this input into the Farm Bill implementation process. We are willing to work in partnership with the Department to achieve these common goals if given the opportunity to do so.

 

For further information:
Jordan Treakle, NFFC policy coordinator (jordan@nffc.net; 202-543-5675)

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