January 6, 2023

Implementing Inflation Reduction Act Funding


Request for Public Input About Implementation of the Inflation Reduction Act Funding: Comments of Regrow Ag

On behalf of Regrow Ag (Regrow), we welcome the opportunity to respond to the Natural Resource Conservation Service’s (NRCS) request for public input regarding implementation of the Inflation Reduction Act (IRA) Funding, 87 FR 70770.

About Regrow

Regrow Ag is on a mission to transform the global food system for a more sustainable future. Transitioning to precision agriculture and regenerative farming practices will be essential for the nation’s farmers to adapt to changes in the environment and build future resilience for our food production.

Farmers can't make this shift alone; they need incentives and support from the companies they supply. Regrow’s technology enables producers to scale the adoption of climate-smart, regenerative practices by providing the foundational measurement and monitoring data that companies need in order to manage and reduce their supply shed emissions. Regrow’s partners include Cargill, General Mills, Kellogg’s, and Nutrien. Regrow was also recently named a partner on two USDA Climate Smart Commodities grants with AgriCapture and USA Rice.

Our comments below highlight the critical importance of the recent IRA funding to both the agricultural sector and Regrow. We look forward to working with the administration to help advance a more sustainable sector for the nation’s farmers as well as the environment. We appreciate your time, and we thank you for the opportunity to weigh in on this instrumental program.

1) What systems of quantification should NRCS use to measure the carbon sequestration and carbon dioxide, methane, and nitrous oxide emissions outcomes associated with activities funded through IRA?

How should NRCS design a scientifically-based framework for field-based quantification and analysis that can integrate into USDA's Greenhouse Gas Inventory and Assessment Program?

The NRCS should utilize Findable, Accessible, Interoperable, Reproducible (FAIR) & OPEN (i.e. free access) data principles that provide observed data (with management information and covariates needed to allow modeling) for free community use to further develop the science and work with industry in implementing markets based on the science.

A good starting point for building out this scientifically-based framework would be to leverage existing and future research funded by the federal government. The government has provided numerous grants to universities and private companies for the research and implementation of climate smart/conservation agriculture practices, and the data generated from these grants could help to improve the science, increase accuracy, and reduce uncertainty in calculations.

We strongly advocate for making all relevant, non-confidential government-funded data freely available through FAIR standards, as most government-funded research is already required to be made public. This would save producers and project partners time and allow researchers to base their modeling on the same standard set of data.

Without this data being accessible through FAIR principles, the entire soil carbon and GHG field will continue to be severely limited and resource constrained.

What methods should NRCS use to quantify carbon sequestration and carbon dioxide, methane, and nitrous oxide emissions?

Biogeochemical process models (DNDC, Daycent, SALUS, etc.) that have been calibrated and validated using relevant peer-reviewed experimental data sets provide the most cost-effective means for GHG emissions estimations. Any models-based approach must also include an estimation of the uncertainty of the outcomes. Agricultural emissions are too diverse and situation specific that emission factors and empirical equations are too crude, even tier 2 methods, and ignore specific conditions that are important for accurately deriving emissions reductions.

We further recommend the NRCS fund research into the development of a model ensemble, with an eye towards developing a strong field of options and not committing NRCS-funded grants to using one specific model, e.g. Daycent. This would be a step towards innovation, and there is a growing movement from the science community for using model ensemble approaches.

What types of field-based data should be collected and analyzed to assess carbon sequestration and reduction in carbon dioxide, methane, and nitrous oxide emissions outcomes associated with agricultural and conservation activities?

USDA & NRCS should require all federally-funded regenerative agriculture programs to collect targeted, extensive soil organic carbon measurements, with a focus on situations where gaps exist in data, or where existing data are lacking in rigor and quality. Significant amounts of environmental data exist for major commodity cropping systems in the US. Although continuing to collect targeted data for these better known systems is critical to keeping models current, more of the focus should be shifted now toward systems that lack a comparable level of data. This would fill both informational and research gaps.

For example, given the recently increased focus on meat production in agriculture, filling data gaps in grassland/grazing systems as well as other GHG emissions associated with beef and dairy production (including methane) should be prioritized to enable scaling of mitigation outcomes for these supply chains. Similarly, soil carbon and GHG emissions data gaps also exist in the production of specialty crops including fruits, vegetables, and tree crops. As conservation programs become common across cereal crop production, these other systems will provide increased opportunities for further conservation/climate action resulting in further economic opportunities for those producers. Concentrated upfront funding and resources to close informational gaps should be considered the first step toward creating a less-intensive, more routineized practice of on-farm data collection.

Additionally, the NRCS should enable program applicants to leverage historical data collected under previous carbon measurement programs. Building upon the recent funding to measure RCP lands, remeasuring a subset of Rapid Carbon Assessment sites where management data from 2010 to present exist will add value to the existing historical data. Collection of data to fill these gaps, combined with historical data could be part of a larger effort to create a much-needed soil carbon monitoring network.

While collecting more data across production systems is critical for scaling outcomes for farmers and the environment, collection alone is insufficient without broad sharing of this information. These data should be made publicly available in an anonymized database that would serve as a data source for the calibration and validation of biogeochemical process models. This would greatly improve the accuracy and applicability of models for GHG emissions estimations broadly across US agricultural production.

How should USDA monitor and track carbon sequestration and greenhouse gas emissions trends and the effects of NRCS supported activities?

USDA needs to ‘de-risk’ the market. Farmers need to be in a position to make climate-related decisions that will not put their crop, their livestock, their farm and livelihood at risk. Right now there is an incentive to just pick the highest $/ton carbon value, with the expectation that prices will rise in the future (and are too low right now). Farmers need to have flexibility in contracts (for variable weather conditions that may make it hard to do a practice some years), and the ability to get higher rates in the future. There is a clear and growing need for the strong standards and publicly available data sets mentioned above.

To that end, the USDA should monitor carbon sequestration and GHG emissions by using biogeochemical process models that have been calibrated and can be deployed at scale. To enable this, USDA should develop standard methods for determining counterfactual baseline scenarios that can be modeled so that the net impact of the NRCS supported activity can be determined.

How or should the framework developed by NRCS to provide field-based quantification integrate with satellite data to provide a comprehensive picture of GHG emissions and removals from agricultural activities and conservation practice implementation?

Satellite data should be used to verify the adoption of agricultural practices detectable via remote sensing (i.e. reduced/no tillage and cover crops). NRCS and others should then use these data as inputs to biogeochemical process models discussed above. The NRCS could also develop and test remote sensing models of soil carbon sequestration as a potential alternative to biogeochemical process models.

(2) How can NRCS engage the private sector and private philanthropy to leverage the IRA investments, including for systems of quantification?

The NRCS can attract and engage private sector philanthropy by not limiting IRA-funded grant opportunities to specific models or data collection methods. As stated above, there is no singular best model or method for assessing carbon sequestration and reduction in carbon dioxide, methane, and nitrous oxide emissions outcomes associated with agricultural and conservation activities. If program applicants are required to use one specific model/method, this will be less attractive to follow-on private sector investment.

Our recommendation would be to link and leverage existing private sector technologies for mapping/monitoring climate smart agricultural practices funded through the IRA.

(3) How should NRCS target IRA funding to maximize improvements to soil carbon, reductions in nitrogen losses, and the reduction, capture, avoidance, or sequestration of carbon dioxide, methane, or nitrous oxide emissions, associated with agricultural production?

  1. Collection of ground-truth data that can be used to calibrate both biogeochemical process models and remote sensing models of GHG emissions;
  2. Creation of standard methods for determining counterfactual baseline scenarios; and
  3. Funneling of data towards good databases, expanded sampling, improved oversight and transparency of standards

(5) How can NRCS expand capacity among partners to assist in providing outreach and technical assistance to support the implementation of IRA funding?

One of the most important capacity building initiatives the NRCS can undertake is investing in hiring staff and extension agents at local NRCS offices with knowledge of GHG accounting and carbon program development. This will ensure that partners have sufficient expertise to deliver useful technical assistance.

Additionally, the NRCS should expand specific climate-focused programs within EQIP/NRCS/etc as climate funding is a tiny fraction of potential funds currently available within those programs.

Catch All: Any other information or data commenters believe are relevant to this document.

Any programs/projects that generate GHG emissions reduction/carbon removal assets should be required to follow some basic transparency principles to ensure benefits to producers and credibility to civil society. The Keystone Policy Center Principles for Transparency document offers an example of these transparency principles.

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