NSAC's Blog

USDA Climate Report Misses Sustainable Systems

August 1, 2014

On Thursday, July 31, the United States Department of Agriculture (USDA) released a report, Quantifying Greenhouse Gas Fluxes in Agriculture and Forestry: Methods for Entity-Scale Inventory, which provides scientific methods for quantifying the changes in greenhouse gas emissions (GHG) and carbon storage from various land management and conservation activities.

The report is designed to aid USDA in evaluating current and future greenhouse gas conservation programs, as well as to develop new tools and update existing ones that may help farmers, ranchers, and forest landowners participate in emerging carbon markets.

It is expected to influence standards and computer-based tools that farmers can utilize when making decisions and improvements to their conservation and management practices.  USDA Undersecretary for Natural Resources and Environment Robert Bonnie explained, “America’s farm, ranch, and forest managers are stewards of the land, and have long recognized the significance of managing soil health, plant productivity and animal nutrition.  Conservation practices and other management changes can reduce GHG emissions and increase carbon storage while improving soil health, productivity, and resilience to drought and other extreme weather.”

Report Overlooks Sustainable Systems

While access to such tools is much needed for farmers to contribute to critical climate change mitigation, the analysis misses the opportunity to highlight and incorporate the value of a whole-farm, systems-approach that considers the benefits of sustainable agriculture systems.  Not only do these systems have a role to play in any future efforts to support on-farm mitigation, but they offer existing solutions to help farmers build resilience into their farming operations.

Just last year, USDA’s Climate Change Program Office issued a report that found that adaptation measures such as “diversifying crop rotations, integrating livestock with crop production systems, improving soil quality, minimizing off-farm flow of nutrients and pesticides, and other practices typically associated with sustainable agriculture are actions that may increase the capacity of the agricultural system to minimize the effects of climate change on productivity.”

Yet, in this report, USDA summarily dismisses the benefits of sustainable practices systems as outside the scope of this project:

Finally, the methods in this report are not intended as a sustainability assessment.  Other environmental services and cobenefits are not addressed by these methods.  Nor are potential tradeoffs or detriments to other environmental concerns addressed here.  The methods are specific to GHG emissions only, and sustainable farm, ranch, or forest management should consider the GHG implications of management in tandem with other environmental concerns such as water quality, soil health, and ecosystem health.

We appreciate that there may be instances where it is appropriate to narrow the focus of a report, but to imply that informing producers about farm “sustainability” is somehow separate from climate change mitigation and adaptation is disappointingly myopic.  Such a narrow focus turns the discussion away from a whole systems approach, ultimately suggesting that the agricultural community must go elsewhere if they are seeking an integrated approach to combat climate change.

As a result, it’s hard to envision how any measurement tools or programmatic changes based on this report will work for all kinds of agricultural systems, or truly result in maximized on-farm GHG emissions reduction.  Not only will be they be unable to comprehend and measure the multiple benefits of sustainable agriculture, but they also will not provide producers interested in maximizing mitigation and resiliency on their farms through advanced conservation with information on the relative benefits of various production practices and systems.

NSAC Comments

The National Sustainable Agriculture Coalition (NSAC) submitted comments on the USDA’s draft report, specifically regarding the importance of taking a systems-based approach to GHG emissions mitigation and sequestration and enabling farmers to improve upon and expand their conservation practices.

NSAC’s recommendations coincide with USDA’s own directives to consider sustainable agriculture systems, including organic agriculture, in the Department’s climate-related programs, policies, and research.  We are disappointed  that the final report leaves out the critical role that sustainable, low-input farming systems can play in mitigating climate change through decreased emissions and increased carbon sequestration.

Life Cycle Assessment Not Included 

In commenting on the draft report, NSAC strongly urged USDA to go beyond the few sentences that dismissed performing a life cycle assessment (LCA) on agricultural production practices.  An LCA is a tool to address the environmental aspects and potential environmental impacts throughout the product or material’s entire lifecycle.  LCAs can provide unbiased comparisons across various production practices and systems.

For example, as the report points out, an LCA for a grain product wouldn’t only include emissions from fertilizer application, but it would also include emissions from synthetic fertilizer production, as well as emissions resulting from grain transportation and storage, processing, use, and disposal.  An LCA would also consider “upstream” practices such as feed production, which should be an inherent consideration when comparing emissions from different livestock practices.

USDA’s final report does expand upon the draft’s few sentences that were dismissive of performing an LCA, but ultimately still concludes that the use of such a tool extends beyond the boundary of the methodologies presented in this report.  The report provides several samples of LCAs but fails to utilize or explain their findings in the report.  One such LCA comparing organic and conventional farming systems is described using agricultural production data, but the report does not include these findings in its recommendations.

Indirect Emissions Should Be Included 

The report specifies that it only provides tools for estimation that are based on the direct emissions resulting from management decisions, such as harvesting or tillage practices.  By failing to consider emissions from direct machinery fuel consumption or indirect emissions from fertilizer and pesticide production, USDA is thus not proposing to comprehensively access actual emissions associated with a varying production practices.  The report does not consider the energy that is required to produce synthetic fertilizer or to heat livestock confinement buildings, nor does it consider emissions from tractor fuel or fuel used for crop drying.  While these may be beyond the scope of this particular report, these are nonetheless critical components of food production that should be considered by USDA in future iterations.

Translating Formulas to Farms

The 600+ page report is an important first step, but not easily accessible to farmers who are interested in mitigating climate change on their farms.  However, the plan is for the data to be used in the future to develop or improve tools for farmers, such as USDA’s COMET-FARM, a farm carbon and greenhouse gas accounting system.  Nonetheless, without an emphasis on sustainable systems, the report or tools will be unable to convey innovative and comprehensive ways for farmers to partake in climate change mitigation and adaptation.

Working lands conservation programs, such as the Conservation Stewardship Program (CSP) and the Environmental Quality Incentives Program (EQIP), offer farmers assistance with conservation practices and activities many of which are particularly well orientated for aid farmers in building healthy soil to help farmers mitigate and adapt to climate change.  Further linking climate strategies to these farm bill programs to drive agricultural resiliency and climate change mitigation is also a critical next step.  NSAC recently submitted recommendations to USDA on ways to use existing farm bill conservation programs to promote climate mitigation and adaptation.

The full USDA report is available for download here.

Categories: Conservation, Energy & Environment, Organic, Sustainable Livestock

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