The USDA recently opened a public comment period to receive input on Executive Order 13985, “Identifying Barriers in USDA Programs and Services; Advancing Racial Justice and Equity and Support for Underserved Communities at USDA.” 

This represents a marked shift in USDA’s historic approach – alternating between settlement and denial – to dealing with the issue of structural racism in agricultural policy, programs, and staffing that have caused so much harm to Black, Indigenous, and other People of Color (BIPOC) who farm and ranch. It is the first public opportunity in this new Administration to provide feedback on where USDA has fallen short and recommend reforms across the agency to help them “Build Back Better.” 

The deadline to submit a comment is Thursday, July 15th. 

NSAC has requested a 90 day extension to allow farmers and ranchers more time to provide their experience because of the gravity of the issue, the extensive number of questions offered, and the current high seasonal demand of agricultural work during the peak growing season. 

The Request for Information puts forward twenty one specific questions. The first seven address the ‘customer experience’ of individual farmers, ranchers, and foresters who have direct experience with USDA programs or staff. The questions (below) are concerned not only with accessibility of information, programs, and credit, but also with the personal experience of BIPOC producers interacting with USDA staff. 

1. Have you applied for or accessed USDA programs and services in the past? If so, please describe your experience.

2. If you have not applied for or accessed USDA programs and services in the past, why not? What would have made it easier for you to apply or access USDA programs and services?

3. How can USDA, its cooperators, grantees, and partners, better share information with underserved stakeholders about our programs and services? What are the best ways to notify and engage underserved stakeholders about new programs and services or changes to existing services?

4. Describe your experience(s) interacting with USDA staff when trying to access USDA programs and services. How were they helpful? Are local USDA offices staffed sufficiently and do they provide good customer service? What are areas for improvement?

5. Are USDA agency websites helpful in providing useful information on programs and services, explaining how specific programs and services work, and explaining how applications for participation are considered? What are areas for improvement?

6. What are the barriers to applying for loan and grant programs? How can USDA make loan and grant processes easier to understand and more accessible to underserved groups?

7. Have you attended stakeholder meetings and informational sessions in the past? Describe when and how helpful and useful the information was, including follow-up by USDA.

The remaining fourteen questions (below) are broader and more general in scope and touch on personal experience, program barriers, policy, data, metrics, community perception, and technology. They are likely to be of interest to BIPOC led and/or serving farm and rural organizations that have knowledge of programs, even if the author is not a farmer with direct personal experience with USDA programs. 

1. Have you experienced injustice, inequity or unfairness in one or more USDA programs? If so, which ones? Please explain the situation(s).

2. Have you had difficulty accessing one or more USDA programs? If so, which ones? Please explain the difficulty.

3. Did you experience problems with required USDA paperwork, the USDA internet sites, the attitudes of USDA workers, or the locations of USDA offices?

4. Are there USDA policies, practices, or programs that perpetuate systemic barriers to opportunities and benefits for people of color or other underserved groups? How can those programs be modified, expanded, or made less complicated or streamlined, to deliver resources and benefits more equitably?

5. How can USDA establish and maintain connections to a wider and more diverse set of stakeholders representing underserved communities?

6. Please describe USDA programs or interactions that have worked well for underserved communities. What successful approaches to advancing justice and equity have been undertaken by USDA that you recommend be used as a model for other programs or areas?

7. Does USDA currently collect information, use forms, or require documentation that impede access to USDA programs or are not effective to achieve program objectives? If so, what are they and how can USDA revise them to reduce confusion or frustration, and increase equity in access to USDA programs?

8. Is there information you believe USDA currently collects that it does not need to achieve statutory or regulatory objectives?

9. Are there data-sharing activities in which USDA agencies should engage, so that repetitive collections of the same data do not occur from one USDA component to the next?

10. How can USDA use technology to improve customer service? Do you have suggestions on how technology or online services can help streamline and reduce regulatory or policy requirements? What are those technological programs or processes and how can USDA use them to achieve equity for all?

11. Are there sources of external data and metrics that USDA can use to evaluate the effects on underserved communities of USDA policies or regulations? If so, please identify or describe them.

12. What suggestions do you have for how USDA can effectively assess and measure its outreach and inclusion of underserved groups and individuals?

13. How can USDA remove or reduce barriers that underserved communities and individuals face when they participate or attempt to participate in agency procurement and contracting opportunities?

14. Have you made recommendations for improvement in the past to USDA? If so, please list or attach those recommendations.

NSAC will be submitting comments developed with the support of its members and allied organizations to help USDA leadership begin the long overdue process of addressing a legacy of discrimination and begin the process of creating policies, programs, staffing, and organizational safeguards to ensure that everyone that works hard to provide our food is treated with equity, respect, and decency.