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Letter will be updated before larger distribution with the final content in this doc: https://docs.google.com/document/d/1_fzpdrqvKqEeBvzGvSOIZ0jfDrC5OnHxAV4YyZ5PzvU/edit?usp=sharing
March ##, 2021
Dear Members of Congress:
We, the undersigned organizations, encourage you to oppose the Growing Climate Solutions Act of 2021. While agriculture and land management can play key roles in addressing the warming climate, this legislation will allow greenhouse gas emissions to continue unchecked and will undermine efforts to build a healthy, sustainable, and resilient food system.
The Growing Climate Solutions Act will require the U.S. Department of Agriculture (USDA) to help agricultural entities generate carbon credits by certifying third-party verifiers and creating a “one stop shop” to educate and enroll farmers in third-party carbon markets. Power plants, refineries, and other polluters can purchase these carbon credits to offset their emissions, or even increase them, instead of actually reducing and eliminating them. Third party verifiers have inherent conflicts of interest that create a system ripe for fraud.
This legislation aims to build a framework for broad-scale development of carbon markets and pave the way for a national cap and trade program. We oppose these carbon schemes for the reasons discussed below. Instead Congress should invest in existing conservation programs to help transition farmers to more ecologically regenerative and resilient agricultural practices and systems that don’t facilitate consolidation, while relying on expensive and harmful chemical inputs, many of which are fossil fuel derivatives.Congress must also enact policies that require polluters to reduce and eliminate pollution by stopping the expansion of oil and gas production and infrastructure, while investing resources to ensure environmental justice and a just transition to more sustainable communities.
Carbon credit programs are incompatible with sustainable agriculture and may drive further consolidation of farms and agribusinesses
Differences between carbon reservoirs, lack of leverage for farmers, and potential for disproportionate benefits demonstrate that a carbon bank is not good for agriculture:
Methods for measuring soil carbon sequestration remain underdeveloped, inconsistent, and influenced by specific climates and geographies. There is simply no way to accurately estimate carbon sequestration and establish a price for offsets consistent with integrity principles, including permanent and quantifiable.
The majority of the earth’s carbon is stored in geological formations in the form of fossil fuels. Carbon locked in these “slow-exchange” reservoirs take tens of thousands to millions of years to cycle back into the atmosphere — unless interrupted by volcanic eruptions or fossil fuel extraction and combustion.
“Fast-exchange” reservoirs like soil and biomass have limited storage capacity and may re-release carbon in a matter of decades — or sooner from land conversion, unmitigated erosion due to flood episodes, or wildfires. Therefore, agricultural offsets are incompatible for industries using them to continue their reliance on fossil fuels.
Market-based carbon credit programs would yield additional leverage to already powerful corporations, including agribusinesses that have long squeezed farm income and drained rural economies. Companies may continue to capture the majority of profits and valuable on-farm data at the expense of farmers.
Carbon credit programs will likely be most feasible on larger operations, potentially leaving out smaller farms, farmers of color, including Black and indigenous farmers, who are already underserved by USDA programs and Commodity Credit Corporation payments.
Benefits of carbon payments would not extend to organic and other operations that have already invested in regenerative and/or agroecological practices.
Carbon credit programs are ineffective at reducing emissions and pollute environmental justice communities
Due to issues of impermanence, additionality, corruption, and market forces, carbon offset programs can actually increase emissions — not just of greenhouse gases, but also harmful co-pollutants like hazardous air pollutants, PM 2.5, and ozone precursors, particularly in environmental justice communities. Below are a few examples of these failures:
A Stockholm Environment Institute report found that around 75 percent of offsets issued under the Kyoto Protocol were non-additional, meaning they would have occurred even without the program in place. Similarly, a USDA study looking at conservation tillage practices found that only about 50 percent were additional.
A California Air Resources Board’s US Forest analysis found 82 percent of the credits reviewed “likely do not represent true emissions reductions” due to lenient accounting rules for leakage, resulting in an additional 80 million tons of CO2 emissions from over-crediting. And States in the Regional Greenhouse Gas Initiative, a multistate carbon offset program increased gas generation by 11.2%, during the first 7 years of the program, while renewables only increased by 2.1% over the same time period.
Emissions increases disproportionately impact environmental justice communities. A Food & Water Watch analysis found that US States with carbon credit programs saw emissions of CO2 and PM 2.5 increase in environmental justice communities, while emissions went down in more affluent communities. And when carbon offsets subsidize manure digesters at factory farms, they incentivize the creation of methane, a much more powerful greenhouse gas, along with other harmful pollutants including ozone-forming volatile organic compounds, nitrates, ammonia, hydrogen sulfide, and harmful air pollutants emitted when the factory farm gas is combusted, all of which disproportionately impact environmental justice communities.
Carbon markets are open to fraud. A study in Nature identifies hundreds of millions of dollars in profits made by Ukranian and Russian companies selling fraudulent credits into the EU Emissions Trading System.
Building Back Better in agriculture builds a healthier food system and rural communities
USDA already has the tools for incentivizing soil carbon sequestration while boosting farm income. Existing conservation programs pay farmers for the same practices being floated for a carbon bank yet are woefully underfunded:
The Environmental Quality Incentives Program (EQIP) pays farmers for practices that can sequester carbon, build soil, and make farmland more resilient to a changing climate. Yet up to 85 percent of farmers vying for EQIP funding are turned away in a given year.
Other programs target restoration and conservation of private land such as the Grassland Reserve Program and Farmable Wetlands Program. Increasing funding for these programs will generate income for farmers while preventing conversion of these important carbon sinks into cropland.
We also urge USDA to close loopholes that enable unsustainable factory farms to capture conservation funding for use in other false solutions such as building manure lagoons and creating factory farm biogas operations.
Additionally, incentives should not simply fund ad-hoc practices but promote the shift to organic, regenerative, and agroecological farming systems. Simply encouraging farmers to practice no-till agriculture, dependent upon fossil-fuel derived herbicides like glyphosate, for example, will not meaningfully reduce emissions or build healthy, resilient soil.
Instead of continuing the legacy of pollution through carbon markets, we encourage policies that eliminate pollution at the source and support local food economies, better living wages for farmers and farmworkers, and pathways for sustainable practices of food and energy production.
Congress needs to transition away from pass a ban on factory farming, increase funding for existing conservation programs, and support farms in adopting regenerative practices that enhance soil health, protect biodiversity, and help make our food system more resilient to the climate crisis. Family farmers need structural reforms that ensure fair markets and prices, and infrastructure supporting transitions to and sustainable continuance of regenerative farming. Ecologically regenerative farming should be incentivized in addition to, and not instead of, carbon reductions in the energy sector. We urge you to oppose the Growing Climate Solutions Act of 2021 and support policies that will help transition to a more sustainable future for all.
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