A Deep Dive on the Senate’s Farm Bill Proposal: the Rural Prosperity and Food Security Act of 2024

On May 1, 2024 – after months of stalled farm bill negotiations on both sides of Capitol Hill – Senate Agriculture Committee Chairwoman Debbie Stabenow (D-MI) released a detailed section-by-section summary of her farm bill proposal. NSAC welcomed the pragmatic Senate bill, the Rural Prosperity and Food Security Act of 2024 (RPFSA), as an important step toward completing a bipartisan farm bill reauthorization this year.

The RPFSA protects conservation and climate funding included in the Inflation Reduction Act (IRA), strengthens access to the farm safety net, invests in local and regional food systems, fully protects nutrition assistance, and takes meaningful steps toward a more racially just food and farm system, all while rejecting harmful policies that would undercut local and state authority and restrict the Secretary of Agriculture’s authority to respond to emergent agricultural needs. In this post, NSAC analyzes the following issue areas of RPFSA:

• Building a More Equitable Food and Agriculture System
• Conservation and Climate
• Research and Organics
• Local Food: Markets, Supply Chains and Access
• Commodities and Crop Insurance
• Credit and Land Access

The proposal – which includes numerous bipartisan priorities but has not yet been sanctioned by Senate Agriculture Committee Republicans – does not include full legislative text and thus offers only a detailed sketch of what an eventual Senate farm bill could look like. NSAC will reserve final assessment until the full legislative text becomes available. Nonetheless, a tremendous amount of information can be gleaned from the initial proposal.

Building a More Equitable Food and Agriculture System

Longstanding structural and institutional racism has excluded Black, Indigenous, and people of color (BIPOC) from access to land, financial resources, information, political standing, and educational and professional trajectories, which limits their ability to shape the food system. As the primary vehicle for federal food and agriculture policy, the next farm bill must meaningfully advance racial equity through a wide array of policies, including by improving equitable access for underserved individuals and communities to US Department of Agriculture (USDA) funding and programs, enhancing program analysis and data collection to inform racial equity-driven decision making, and increasing funding for programs and policies that support underserved individuals and communities.

Throughout the RPFSA, numerous provisions take consequential steps toward a more equitable food and farm system. While equity-centric provisions are highlighted throughout this entire post, some notable provisions include:

• Broad inclusion of Tribal-specific provisions that promote parity, eliminate unnecessary barriers to nutrition assistance programs, and increase access to critical USDA programs.
• Heirs Property and Fractionated Land Legal Clinics (Section 7502).
• Underserved Producers Report (Sec. 11206).
• USDA Ombudsperson (Sec. 12203).
• Civil Rights Accountability for USDA Employees (Sec. 12205).
• Strengthening the Farm and Food System Workforce (Sec. 12210).
• Grocery, Farm, and Food Worker Stabilization Grant Program (Sec. 12211).
• Expanded language translation services (Secs. 11205, 12201).

For additional context and perspective on these and other provisions, see these statements from the Native Farm Bill Coalition, the National Young Farmers Coalition, and the HEAL Food Alliance.

Conservation and Climate

The benefits of on-farm conservation programs are widespread. They help farmers and ranchers keep drinking water clean for our urban and rural communities, build soil resilience and limit the impacts of severe drought and flooding, provide healthy habitats for wildlife, mitigate agriculture’s greenhouse gas (GHG) emissions, and support farm operations that are productive and sustainable long-term. Yet today, funding shortages, insufficient emphasis on high-impact practices, and a lack of program coordination keep tens of thousands of farmers from achieving their resource conservation goals every year. Furthermore, historically underserved producers,

including many BIPOC farmers and ranchers, have experienced systemic and institutional racism that has further hindered their access to conservation programs.

NSAC is thrilled that RPFSA protects all unobligated IRA funding and moves it into the farm bill’s baseline funding for the Conservation Stewardship Program (CSP), the Environmental Quality Incentives Program (EQIP), the Agricultural Conservation Easement Program (ACEP), and the Regional Conservation Partnership Program (RCPP) while maintaining a requirement that funds be spent addressing climate change. NSAC applauds Chairwoman Stabenow’s leadership in fighting for this massive, enduring investment.

Beyond protecting IRA investments, the RPFSA also includes dozens of additional reforms to existing conservation programs important to NSAC members.

Conservation Stewardship Program (CSP)

CSP provides comprehensive conservation assistance for farmers and ranchers who enroll their entire operations in the program to achieve higher levels of stewardship through continued improvements. NSAC is pleased to see the following provisions to enhance CSP:

• Major investments via IRA funding.
• Permanent climate change targeting of program funds.
• New language on ranking applications that plan to reduce GHG on farms.
• Expanded definition of “conservation activities” to include mitigating GHG emissions.
• Improved cost-share accounting for income forgone when farmers experience losses in revenue due to production changes, anticipated reductions in yield, transitioning to an organic resource-conserving system, or acreage converted to conservation uses.
• A statutory minimum payment of $4,000 per year.
• Authorization for payments for conservation activities related to organic production systems and transitioning to organic production.
• Stronger support for soil testing as part of a CSP contract.
• Extended alternative funding arrangement authority for tribal governments.

However, despite these improvements, RPFSA does include one distressing provision and several concerning omissions:

• No increase in program set-asides for Beginning Farmers and Ranchers as well as Socially Disadvantaged Producers.
• Excessive proposed cost-share payments for livestock feed management.
• No supplemental payments for agroforestry practices and enhancements.
• No language to prevent payment limitation abuse.
• No language clarifying existing and planned conservation must be weighted equally when ranking CSP applications.

As with all programs, NSAC will continue to analyze the RPFSA’s CSP provisions, including a proposed one-time CSP subprogram focused on enrollment of up to 500,000 acres of native or improved pasture land used for livestock grazing in the Lower Mississippi River Valley to address water quality issues leading to hypoxia in the Gulf of Mexico.

Environmental Quality Incentives Program (EQIP)

EQIP is a voluntary conservation program that provides farmers and ranchers with financial cost-share assistance and technical assistance to implement conservation practices on working agricultural land. Conservation practices eligible for EQIP include structural, vegetative, and management practices (e.g., improving irrigation efficiency, restoring pasture, cover cropping, or nutrient and pest management). Payments for conservation improvements and activities include income forgone, as well as costs associated with planning, design, materials, equipment, installation, labor, management, maintenance, and training. NSAC is pleased to see the following improvements to EQIP:

• Major investments via IRA funding.
• Permanent climate change targeting of program funds.
• Expansion of EQIP purposes to include: 1) promoting environmental quality and climate change adaptation and mitigation; 2) assisting producers with complying with local, State, and national regulatory requirements concerning climate change adaptation, mitigation, and resilience; and 3) assistance to producers to install and maintain conservation practices that sustain food and fiber production while sequestering carbon, increasing drought resilience, reducing GHG emissions, and conserving energy.
• Amends the definition of “practice” to include native habitat restoration and planning for reducing GHG emissions.
• Creates streamlined and coordinated procedures between EQIP and CSP.
• Authorizes State technical committees to select high-priority practices that further efforts to implement a State, Tribe, or locality’s climate adaptation and resilience plan.
• Directs State technical committees to consult with Tribal conservation advisory councils for Tribal land when selecting state high-priority practices that receive an increased cost-share under EQIP.
• Continues the 10% wildlife habitat set-aside and the wildlife habitat incentive program.
• Creates a 10% set-aside of EQIP funds for payments for practices implemented on small farms.
• Raises the payment cap for organic producers to $450,000.
• Requires producers with confined livestock feeding operations to submit a GHG emissions reduction plan, in addition to the currently required comprehensive nutrient management plan, to be eligible to receive payments under the program.
• Expands the calculation of payments for foregone income to allow the Secretary to accord greater significance to practices that promote GHG emissions reductions as part of air quality improvement.
• Requires an annual report describing the amount of funding obligated with respect to each category of practice by state and the amount obligated under the program in each state, categorized by the size of operation.
• Extends alternative funding arrangement authority for tribal governments.

However, NSAC is disappointed to see that the following EQIP provisions were not included:

• Increase in program set-asides for Beginning Farmers and Ranchers and Socially Disadvantaged Producers.
• Retargeting two-thirds of the 50 percent EQIP set-aside for livestock practices towards advanced grazing management.

NSAC will continue to analyze the RPFSA’s EQIP provisions, including the 75% cost-share for livestock management practices that reduce enteric methane emissions, and the waiver authority for the limitations in sections 1001D(b) and 1240G for water management entities to ensure they are eligible to participate in EQIP.

EQIP – Conservation Innovation Grants (CIG)

NSAC is pleased to see the following improvements to CIG:

• Doubles the funding for On-Farm Conservation Innovation Trials from $25 million to $50 million for each fiscal year (FY) and directs that 50% of the funding be used for Soil Health Demonstration Trials.
• Expands the types of “new or innovative conservation approaches” funded through On-Farm Conservation Innovation Trials to include on-farm nutrient recycling, perennial production systems including agroforestry and perennial forages and grain crops, and livestock-related practices that reduce GHG emissions including enteric methane emissions.
• Directs the Secretary to expand the current report on On-Farm Conservation Innovation Trials to include any barriers to or best practices for the adoption of new and innovative conservation approaches.
• Requires the Secretary to publish public-facing reports submitted by partners that contain the results of the On-Farm Conservation Innovation Trials conducted under this program.
• Directs the Secretary to conduct one or more studies on the changes in methane emissions and economic outcomes generated as a result of livestock-related practices that reduce GHG emissions, including enteric methane emissions, and report on the results.

However, NSAC is disappointed that the following CIG provisions were not included:

• Addition of GHG emission reduction to the purposes for CIG Air Quality grants.
• Increase CIG Air Quality annual funding from $37.5 million to $50 million.

EQIP – Conservation Incentive Contracts (CIC)

NSAC is pleased to see two specific CIC provisions:

• Allows participants in conservation incentive contracts to reduce the term of their contract in order to enroll in the CSP.
• Amends the definition of “priority resource concern” to include natural resource concerns or problems identified by Tribal governments and that represent significant concerns on Tribal land.

Conservation Reserve Program (CRP)

NSAC is pleased to see the following CRP provisions:

• Gradually increases the total CRP acreage cap from 27 million to 29 million acres.
• Increases the minimum CRP Grasslands acreage from 2 million to 10 million acres.
• Raises rental rates for General and Continuous sign-ups.
• Fully authorizes the Conservation Reserve Enhancement Program (CREP), Farmable Wetlands Program, Clean Lakes Estuaries and Rivers (CLEAR), CLEAR30, Soil Health and Income Protection Program (SHIPP), and State Acres for Wildlife (SAFE) Program.
• Increases the percentage of program acres to be enrolled in the CLEAR Initiative from 40% to 45% of acres.
• Allows CLEAR contracts to transition to CLEAR30.
• Establishes an Agroforestry Pilot Project.
• Extends the Transition Incentive Program.
• Establishes a Conservation Reserve Easement program and requires the Secretary to offer to enroll land subject to an expired covered contract into a conservation reserve easement.

Regional Conservation Partnership Program (RCPP)

NSAC is pleased to see the following RCPP provisions:

• Major investments via IRA funding.
• Permanent climate change targeting of program funds.
• Expands the purposes of the program to include (1) encouraging the reduction of GHG emissions and adaptation to climate change; (2) establishing or implementing the soil health plan or program of a State or Tribal government; and (3) facilitating the conversion from concentrated animal feeding operations to climate-friendly agricultural production (including regenerative grazing, agroforestry, organic, and diversified crop and livestock production systems).
• Authorizes indirect cost-share to cover administrative expenses of the eligible partner up to 20% of the total project cost, and up to 30% for projects primarily serving historically underserved producers.
• Clarifies the contribution requirement on partners under the program to no longer require a 50% cost-share and instead establish a flexible contribution amount that may differ among partnership agreements.
• Extends alternative funding arrangement authority for Tribal governments
• Expands the definition of “eligible partner” to include Tribal organizations, Native Hawaiian organizations, and not-for-profit conservation organizations.
• Amends the definition of “priority resource concern” under RCPP Critical Conservation Areas to include the restoration and enhancement of wildlife habitat connectivity and wildlife migration corridors.
• Establishes timelines for the Secretary to implement partnership agreements, finalize renewal and extension agreements, and reimburse partners.
• Requires the Secretary to publish the report submitted by partners on the implementation and outcomes of projects in a public-facing manner.
• Revises the criteria that the Secretary may use to prioritize applications to include a priority for projects that demonstrate that a significant number of historically underserved producers will benefit from a project.
• Authorizes the Secretary and Indian Tribes to develop projects under the Alternative Funding Arrangement authority to address eligible resource concerns on Tribal lands and allow for flexibility in conservation implementation and administration.

State and Tribal Assistance for Soil Health Program

While the RPFSA does not create the State and Tribal Assistance for Soil Health Program as envisioned in the Agriculture Resilience Act (ARA), NSAC is glad to see the same purpose included in the RCPP program. This opens the door for ground truthing the concept at NRCS, should this provision of RPFSA become law. To be sure such ground truthing occurs, NSAC advocates dedicating a minimum amount or percentage of RCPP funds for the purpose of supporting State and Tribal Soil Health Programs.

Alternative Manure Management Program (AMMP)

The RPFSA does not contain a proposal to support AMMP technologies as envisioned in the ARA or the COWS Act. NSAC is disappointed to see this omission, as shifting the technologies used to handle manure on midsized livestock operations is critical to addressing agriculture’s contributions to climate change. However, we are heartened to see some of the intent of this proposal included in a new purpose in RCPP, “facilitating the conversion from concentrated animal feeding operations to climate-friendly agricultural production (including regenerative grazing, agroforestry, organic, and diversified crop and livestock production systems).” NSAC sees this as a commendable use of RCPP and we fully support the inclusion of this purpose in a final farm bill. As many portions of the country cannot transition fully to year-round, grass-based livestock systems, we believe it is vital for funding to be dedicated to AMMP technologies to ensure instances where confinement is likely to continue are as ecologically friendly as they can be. We hope the House and Senate will continue to consider the bipartisan COWS Act provisions.

Grazing Lands Conservation Initiative (GLCI)

The RPFSA maintains the current appropriations authority of $60 million per year for GLCI and adds language to ensure the program can assist grazers planning agri-voltaics projects within their operations. Both are positive proposals, though NSAC believes strongly that grazers need dependable access to technical assistance. Therefore GLCI needs a minimum of $50 million per year in mandatory funding to ensure such assistance is provided without interruption.

Conservation Practice Standards

Across the conservation proposals in the RPFSA, many provisions work to build NRCS’ knowledge of conservation practices and incorporate that knowledge into new and existing practice standards. NSAC supports such provisions, as technically sound practice standards are foundational to federal conservation programs. Language around streamlining the process for establishing interim practice standards, assessing the potential for mitigating emissions, and allowing for greater regional variability is especially appreciated. However, NSAC is disheartened to see no reference to establishing composting as a national practice standard in the RPFSA. On-farm composting is foundational to many operations’ approach to climate mitigation and broader operational sustainability. Failing to provide a practice standard, and subsequently cost-share, fails to recognize the responsible resource management that composting represents. NSAC hopes both chambers will be open to adding language to create a national composting practice standard in a final Farm Bill.

The RPFSA provides explicit authority for cooperative agreements that build capacity for farmer mentoring networks that support conservation objectives. NSAC sees this as promising – farmer-to-farmer mentoring is one of the most powerful forms of conservation technical assistance and nuanced solutions to on-farm problem-solving. However, NSAC is disheartened to see no mention of a special technical assistance initiative dedicating 1 percent of the total farm bill conservation program mandatory funding each year for a major new conservation technical assistance (CTA) initiative to assist producers in mitigating and adapting to climate change, as proposed in the ARA. With as much language as has been added to base programs to help them better address the climate crisis, NSAC believes Congress should dedicate a set portion of technical assistance funding to serve the same purpose.

Measurement, Monitoring, Reporting, and Verification (MMRV) of Greenhouse Gas Emissions

The ARA and the Advancing Research on Agricultural Climate Impacts Act (ARACI) called for a robust assessment of NRCS’ approach to evaluating the performance of conservation practices with relation to the climate crisis. We applaud the RFPSA for providing just that. Specific provisions include:

• $50 million to carry out MMRV activities, with at least 30% supporting culturally appropriate technical assistance and guidance to historically underserved farmers, ranchers, and forest landowners.
• Establishment of a program to inventory, monitor, and analyze soil carbon changes to analyze soil properties and the impact of land management strategies, on soil carbon sequestration.
• Requires the Secretary to develop a standardized methodology to measure soil carbon consistently over time for research and conservation purposes.
• Directs the Secretary to develop and maintain a modeling tool to predict the impacts of different land management practices, including implementing conservation activities, on greenhouse gas emissions and soil carbon sequestration across the United States.

Renewable Energy For America Program (REAP)

NSAC is pleased to see the following REAP provisions in RPFSA:

• Extends the authorization of appropriations through fiscal year 2029 and continues the existing mandatory funding level of $50 million for each fiscal year.
• Adds the reduction of greenhouse gas emissions as a consideration for energy efficiency improvement loan guarantees and grants.
• Designates agricultural producer cooperatives as eligible entities for the newly titled “Project Development Assistance Grants.”
• Amends energy efficiency improvements and renewable energy systems grants by Increasing the federal cost-share to 50% of the cost of the project funded by a grant.
• Improves program outreach to limited resource producers.
• Simplifying the application process for renewable energy systems grants by 1) striking the tiered application system and instead directing the Secretary to create a simplified application for projects under $50,000, and 2) allowing for a single application for loan guarantees and grants for energy efficiency improvements and renewable energy system projects
• Creates a new Regional Demonstration Project initiative to demonstrate on-farm carbon emission reduction projects through energy efficiency improvements and renewable energy systems.

Research and Organics

Farmers are at the forefront of climate change, and agriculture has a role in mitigating its impacts. Addressing this challenge will require a comprehensive approach that includes focusing on reducing major sources of GHG emissions and investing in solutions that will increase carbon sequestration and help communities, especially frontline communities, adapt to a changing climate. This includes major funding increases for sustainable and organic agriculture systems that sequester carbon, improve nutrient cycling, and lower fossil fuel energy inputs.

With this in mind, there are many positive provisions included in RPFSA such as:

• Increases investments in 1890 institutions, including mandatory funding for the 1890s Scholarship Program and the addition of four new 1890s Centers of Excellence focusing on climate change; forestry resilience and conservation; food safety, bioprocessing, and value-added agriculture; and food and agricultural sciences and the social sciences (Sec. 7110, 7113, 7213).
• Creates an Organic Agriculture Research Coordinator within the Office of the Chief Scientist (Sec. 7210).
• Reauthorizes the Sustainable Agriculture Research & Education (SARE) program (Sec. 7201, 7202, 7203).
• Reauthorizes the Organic Agriculture Research and Extension Initiative (OREI) (Sec. 7209).
• Specialty Crop Research Initiative (SCRI) mandatory funding is increased from $80 million to $130 million per year. In addition, the proposal allows the Secretary to waive the matching funds requirement for SCRI grants, which can help make the program more accessible to a wider range of applicants.(Sec. 7305).
• Invests in public cultivar development and seed competition, including:
  • The addition of regionally adapted cultivar and breed development for priority areas in the Agriculture & Food Research Initiative (AFRI) (Sec. 7509).
  • Requiring the Secretary of Agriculture to submit a report to Congress on the public cultivar and animal germplasm research funded by USDA and any research gaps in these areas (Sec. 7509).
  • Creating a Farmer Seed Liaison position in the Agricultural Marketing Service (AMS), whose responsibilities include strengthening competition and choice in the seed marketplace (Sec. 12511).
  • Formally authorizes and provides $50 million annually for the Organic Market Development Grant (OMDG) program. OMDG is a key element of USDA’s historic Organic Transition Initiative announced in 2022, and this important investment will continue to expand organic opportunities for farmers, national and regional food systems, and consumers (Sec. 10005).
  • Provides $5 million in mandatory funding for Organic Production and Market Data Initiatives, to remain available until expended (Sec. 10006).
  • Broader authorization of the USDA’s National Organic Program (NOP) to allow the program to provide technical assistance, education, and outreach to certified organic farmers and farmers transitioning to organic certification, though NOP’s ability to carry out its new authority will be limited without a commensurate funding increase (Sec. 10005, 10006, 10007).
  • NSAC is also disappointed to see that other organic priorities were not included in RPFSA, including those that would have removed the arbitrary limit to insuring a crop at a price secured in a contract, created a later or second final planting date for organic producers, and created an enterprise unit of insurance based on organic status.
  • While NSAC is glad to see increased investments in portions of the research title, we are nonetheless disappointed to see that effective, popular, and climate-oriented research programs like SARE, OREI, and ORG received no additional funding despite tens of millions in discretionary and mandatory funding increases disbursed elsewhere in the title.

  Local Food: Markets, Supply Chains and Access

  The farm bill plays an important role in supporting the health and prosperity of our rural and urban communities. The next farm bill can build toward healthy rural and urban communities by strengthening the resilience of local and regional supply chains, increasing market opportunities for small and mid-sized farms and processors, enhancing job growth and local economic development through workforce development and training, and ensuring the most vulnerable have ample access to nutritious, culturally-relevant, locally-produced foods.

  The RPFSA includes a number of provisions that advance these goals:

  • RPFSA sustains the multi-layered food systems investment opportunities needed to support the growth of a more resilient food system, from microgrants to larger grants and loans to the technical assistance needed to access them.
    • Specific to meat supply chains, it provides grants and resources for small- to medium-sized meat and poultry processors, focusing on expanding processing capacity through equipment upgrades and worker training (Sec. 12103, 7124). This includes short-term staff training and workforce development grants directed towards community colleges.
    • It also offers a new flexible financial product for food supply chains by expanding the Food Supply Chain Guaranteed Loans to offer complimentary grants. This new program offers guaranteed loans to finance real estate and infrastructure investments and provide working capital for commercial supply chain development.
      • The grant program will support essential employee training and certification, food safety training and certification that has the potential to greatly impact workforce development for small meat processing, among broader food safety topic areas.
      • Businesses, cooperatives, and other eligible entities could apply for a blend of loans and grants to finance their overall projects and offer specific workforce training (Sec. 6503).
      • RPFSA also provides the technical assistance critical to supporting farmers’ and ranchers’ access to new and emerging market opportunities.
        • It reauthorizes the Food Safety Outreach Program, an increasingly critical training program, as the Food & Drug Administration and the Food Safety & Inspection Service continue to finalize new rules, which – even when well designed – tend to place disproportionate burdens on small and very small producers and processors. (Sec. 7301)
        • RPFSA codifies the Regional Food Business Centers, designed to ensure small-scale producers and mid-tier food businesses can adequately compete for new funding opportunities. In addition to grant writing resources, these Centers offer broader capacity-building, training, and investments. The proposal would maintain the existing approach for at least twelve centers, with a requirement of dedicated centers to serve producers and businesses in Tribal nations, Hawaii, Alaska, the colonias, US territories, and other remote areas (Sec. 12308).
        • There are several dedicated rural partnership investments with the potential to dramatically increase support for regional food enterprises. The Rural Partnership Program Grants will support coordinating and pursuing federal and non-federal investment opportunities for community and economic development projects The Rural Partnership Technical Assistance Grants will support planning, specialized training, grant writing activities, and technical assessments.
          • These grants will build the capacity of organizations to compete for funding opportunities and foster networks of technical assistance providers. They would specifically target those communities who have been historically left out or underfunded by USDA.
          • While the applicants do not necessarily have to be based in rural areas, the program efforts must benefit rural communities (Sec. Sec 6202, Sec 6203).
          • There are numerous provisions in the Senate proposal that will strengthen markets for direct marketing farmers and those growing for regional institutional markets while ensuring affordable access to fresh locally grown products.
            • RPFSA codifies the popular and transformative local food purchase assistance program that empowers states and Tribes to sustain and grow the newly developed markets for their farmers while ensuring Tribal nations have equitable access to funding opportunities with set-asides. The program is intended to develop new wholesale markets for small and mid-scale local farmers, but the program design allows for innovative delivery and distribution of high quality local food into food insecure communities (Sec. 10004).
            • It responds to long-time requests to increase mandatory funding for the Senior Farmers Market Nutrition Program, which will finally provide enough funding for the program so all interested States and Tribes can participate (Sec. 4401).
            • The proposal improves access to highly effective local food market development programs such as the Farmers Market and Local Food Promotion programs by removing match requirements arbitrarily added in the 2018 Farm Bill. The bill also responds to the needs of underserved farmers and reduces barriers to participation by removing the match for Value-Added Producer Grants (Sec. 10003).
            • Several RPFSA provisions promote accessibility of local foods to families utilizing SNAP benefits or other community food access programming, while simultaneously offering a new market opportunity for farmers.
              • One example is the Office of Urban Agriculture and Innovative Production, which has a dual mission to support the development and success of urban, indoor, and other emerging agricultural practices while improving access in food insecure areas. NSAC is thrilled to see the extensive list of provisions to grow and improve the services offered under the Office of Urban Agriculture and Innovative Production, many of which came from the Supporting Urban and Innovative Farming Act. The Senate proposal provides annual mandatory funding of $10 million in addition to the increased appropriations levels. This is a significant win for the Office, as stakeholders have had to work diligently to secure funding each year, and the office is currently only able to fund approximately 20% of eligible grant applications. The bill also clarifies additional office responsibilities, such as leveraging USDA Service Centers to provide tailored business and conservation technical assistance to urban and innovative growers. It also offers flexibility to implement these activities through cooperative agreements with community partners. It clarifies the intentions and responsibilities of the newly developed Urban County Committees to ensure that the committees adequately represent the unique needs of the growers (Sec. 12208).
              • While the Gus Schumacher Nutrition Incentive Program no longer exclusively serves direct-marketing farmers, the majority of nutrition incentive programs still operate programs in farmers market settings, driving more revenue to local and regional farmers. The Senate proposal recognizes the substantial growth and effectiveness of the program, scaling funding over ten years, increasing the federal cost-share, and offering pathways for cooperative agreements with partners who have the capacity to implement state-wide programs (Sec. 4403).
              • NSAC is extremely pleased to see the directive to streamline the vendor application process for direct marketing to farmers across all federal nutrition benefits (Sec. 4408). This has the potential to increase the number of farmers benefiting from these programs, improving revenues, and the accessibility of local products for families.

              While we celebrate these many wins, there are also places where RPFSA falls short of what is needed to ensure resilient local and regional food systems:

              • We cannot understate our excitement to see a permanent local food purchase assistance program proposed in the Senate bill. However, a $200 million total between FY25-FY29 may inadvertently hamper the program’s effectiveness. Unprecedented funding levels provided through one-time investments were designed to respond to the immediate impacts of COVID-19; yet, the program demonstrates the capacity and interest of local farmers to scale their businesses to larger wholesale markets. Proposed funding levels may leave some states receiving as little as $40,000 annually, well below what is necessary to operate a successful program.
              • NSAC also continues to advocate for more opportunities for small meat and poultry producers in localized and federal-based procurement, including specific federal set-asides and studies on the barriers to entry for meat and poultry producers and processors.
              • NSAC believes the next farm bill should include a broader set of processor workforce development opportunities that directly fund meat processors to offer training or collaborate with community colleges, universities, or other worker training programs.
              • Finally, while in the proposal the Regional Food Business Centers are authorized to coordinate investments and provide technical assistance for essential elements of the food supply chain, it lacks any funding authorizations. Many of the current cooperative agreements will expire in FY28 or FY29. This may produce an otherwise avoidable gap in funding for programs that will be fully underway.

              Commodities and Crop Insurance

              Farming is a uniquely risky business. The federal government must play a role in helping farmers mitigate financial loss from unforeseeable risks to maintain a reliable food supply chain and support family farms and the economic security of the communities in which they live. But farm safety net programs that should keep farmers farming – including commodity programs, crop insurance, and disaster assistance – tend to leave behind many small, beginning, and diversified farmers and ranchers. The next farm bill must strengthen the farm safety net to expand access to underserved producers and invest in on-farm resilience to improve farmers’ bottom lines and reduce program costs long-term.

              The RPFSA takes several important steps toward that goal by:

              • Making much-needed improvements to Whole-Farm Revenue Protection (WFRP) and Micro Farm, as well as the Noninsured Crop Disaster Assistance Program (NAP), which will streamline access to the farm safety net and enhance the quality of coverage for beginning, small to mid-sized, specialty crop, and diversified farmers (Sec. 1601,11203, 11405).
              • Addressing the gap in coverage for new and transitioning farmers by creating a pathway for NAP participants to graduate into WFRP enrollment once three years of revenue history – a condition for WFRP eligibility – is established (Sec. 1601).
              • Establishing a weather index-based insurance pilot based on the WEATHER Act as a new, responsive coverage option for small and diversified farmers (Sec. 11204).
              • Creating more regular opportunities for the Federal Crop Insurance Corporation to review current data and apply that to methodologies used to measure risk, including risk from crop genetics and worsening weather, to improve long-term program integrity (Sec. 11502).
              • Supporting natural resource stewardship by expanding sodsaver nationwide and codifying that NRCS conservation practices are Good Farming Practices (Sec. 11207, 11601).
              • Expanding the Risk Management Agency’s definition of a beginning farmer to one farming up to ten years, rather than only five, and increasing the maximum beginning farmer discount in line with the bipartisan Crop Insurance for Future Farmers Act (Sec. 11101).

              While we celebrate the preceding proposed improvements to the farm safety net, some aspects of the proposal require further examination, for example:

              • While several provisions are aimed at increasing the responsiveness of crop insurance agents to sell WFRP and area-based plans to smaller operators, because finding willing agents is a pervasive and significant barrier to insurance access, RPFSA should have gone further by codifying the comprehensive Insuring Fairness for Family Farmers Act (Sec. 11202, 11203, 11301, 11302, 11303, 11505).
              • NSAC generally supports the authorization for USDA to consider premium discounts and match state programs tied to the voluntary adoption of certain conservation practices. However, the inclusion of “precision irrigation and fertilization” broadly as an example of practices that may be eligible for a discount is concerning. We urge caution against the implementation of such a program without strict payment limits to mitigate further concentration of resources among the largest producers (Sec. 11103, 11208).
              • NSAC heartily welcomes a reduced $700,000 Adjusted-Gross Income (AGI) means test to Title I program eligibility and a payment band on maximum Price Loss Coverage (PLC) program payouts as steps toward responsible spending that supports working farmers. However, these provisions are not nearly enough. The $150,000 AGI carve-out for the largest specialty crop operations might make sense if AGI did not, by definition, only reflect profits and already account for expenses.
              • NSAC cautiously views the unspecified authorization of a permanent disaster program to supplement record farm safety net spending. This bandage would not be necessary if risk management programs actually helped farmers build resilience against loss. If it is established, any permanent disaster program must incorporate eligibility for producers without prior insurance coverage through a revenue-based approach (introduced in the Emergency Relief Program) as well as guardrails for payments to be equitably distributed to producers who need assistance the most (Sec. 1502).

              There are several places where RPFSA falls short of building a truly functional, fair, and informed farm safety net:

              • Following a period of record net-farm income, RPFSA raises subsidies primarily known to benefit the largest, industrial commodity operations. PLC reference prices will be increased by five percent for rice, cotton, and peanuts, which might cost up to $10 billion, despite benefiting less than 0.3 percent of farms. Meanwhile, revenue-guarantees under the Agriculture Risk Coverage (ARC) program will increase from 86 to 88 percent, to the comparable benefit of corn and soybean operations. It also expands highly subsidized supplemental insurance options for commodity producers. The Chairwoman’s outline for farm safety net reform earlier this year would have raised subsidies, but in a more balanced and responsible way by prompting commodity farms to choose between the sweetened insurance or Title I benefits. This should be placed on the table once again as a condition for higher subsidies for the highest-earning commodity farms (Sec. 1101, 1107, 11102).
              • The RPFSA reflects a missed opportunity to incorporate the bipartisan Farm Program Integrity Act to close Title I loopholes that allow absent landowners and relatives to receive annual subsidies rather than farmers actively engaged on the farm (Sec. 1104, 1106, 1703).
              • Farm bill negotiations must evolve to incorporate historically bipartisan proposals, including the AFFIRM Act and the Crop Insurance Transparency Act, that introduce common-sense payment limits, means tests, and data transparency to the federal crop insurance program that similarly apply to other farm programs. These proposals would save tens of billions of dollars while impacting as few as three percent of farms.

              Credit and Land Access

              For all farmers and ranchers, starting and managing a successful farming operation is fraught with great challenges. For beginning, BIPOC, and other historically underserved farmers, rising costs and limited availability of farmland, access to markets and infrastructure, limited or no built capital, discrimination, and the worsening impacts of the climate crisis and natural disasters are just some of the challenges these farmers face. The next farm bill must take a comprehensive approach to addressing these inequities, including through increased access to land and capital.

              The RPFSA advances this goal in several key ways, by:

              • Improving existing programs to help farmers access land, including reducing experience needed as eligibility for farm ownership loans to one year, increasing the limitation and authorization of direct and guaranteed farm ownership loans, and increasing the limit for the Down Payment Loan Program (Sec. 5101, 5103, 5015, 5106).
              • Increasing the limits and authorizations for direct operating loans, farm ownership loans, and microloans to keep pace with the rising cost of assets and equipment (Sec. 5201, 5203, 5302).
              • Removing barriers to underserved farmers’ ability to access credit from USDA, including the removal of graduation requirements, and the restoration of loan eligibility after a write-down or forgiveness (Sec. 5202, 5303, 5305).
              • Extending authorization of the Farming Opportunities Training and Outreach (FOTO) program, which includes 2501 and the Beginning Farmer and Rancher Development Program (BFRDP), through 2029 (Sec. 12201).

              While we celebrate these reforms, we also see some missed opportunities, for example:

              • The extension of the Commission on Farm Transitions and its expanded scope is a welcome acknowledgment of the pressing challenges that beginning, small, and socially disadvantaged farmers and ranchers face to access land amid a historic generational transfer of farmland; however, proposals already exist to begin addressing some of these challenges, such as the Land Access, Security, and Opportunities Act, which would invest in community-driven projects to help producers secure land and should be considered in the final farm bill (Sec. 12521).

              In some places, the RPFSA falls short of what is needed to increase equitable access to land and capital. For example:

              • NSAC is opposed to increasing the authorization level for guaranteed operating loans without placing guardrails to prevent or reduce capital infusions to concentrated animal feeding operations (CAFOs), which are missing from the proposal (Sec. 5302).
              • The proposal does not address several of the most common issues for underserved farmers trying to access credit from USDA which are addressed in the Fair Credit for Farmers Act, including over-collateralization and an imbalanced appeals process.
              • The proposal does not authorize new programs or initiatives to fulfill unmet capital needs, such as the creation of a multiyear loan pilot for beginning farmers to invest in start-up expenditures and at least a study on the feasibility for USDA to offer pre-approvals or pre-qualifications for loans.

              NSAC will continue to provide coverage of the pathway to a new farm bill on our blog, including detailed analysis of the Senate and House proposals as legislative text emerges.