As farmers and ranchers in the U.S. and abroad experience the reality of more extreme and unpredictable weather, soil carbon sequestration is catching national and international attention as a means of climate change mitigation and adaptation. California is poised to lead the way with its soon-to-be-launched Healthy Soils Incentives Program, the nation’s first program to directly incentivize farmers for adopting practices that improve soil health, sequester carbon and reduce greenhouse gas emissions overall.
According to the California Department of Food and Agriculture’s (CDFA) most recent proposed Healthy Soils program framework, farmers and ranchers will be eligible to apply for up to $50,000 to defray the costs of adopting healthy soils practices (pictured below) over the course of three years.
The Environmental Farming Act Science Advisory Panel (SAP) – the body responsible for advising CDFA in the design of the program – met last week to review the latest proposed framework. CDFA expects to release applications for the program sometime in July.
The proposed framework discussed at last week’s meeting contained significantly more details than we have previously seen. A number of important program changes were put forward. We support CDFA’s proposal to accept the Natural Resource Conservation Service (NRCS) Environmental Quality Incentive Program’s (EQIP) awards as matching funds, which will leverage the federal agency’s popular technical assistance and conservation cost-share program to extend the impact of the program. We applaud CDFA’s commitment to providing technical assistance to growers, which will be critical to ensuring limited-resource farmers can successfully apply for the program. We also support their decision to award extra points in their scoring criteria for adopting more than one practice, as we know that “stacking” soil health practices often has synergistic outcomes.
However, some proposed program details raised significant concerns, many of which were shared by EFA SAP members and CalCAN partners. In response to these concerns, CDFA agreed to release the program’s draft request for proposal (RFP) for public comment and subsequent revision before officially launching the program.
We greatly appreciate CDFA taking this step and giving Healthy Soils stakeholders a chance to provide feedback on the more detailed program framework before its inaugural RFP officially goes out. Below, we outline our recommendations for the proposed program framework.
Allow on-farm compost to be eligible for compost application
- On-farm compost is more cost-effective than purchased compost.
- On-farm compost is already regulated under federal law and coming under new state regulations.
Clarify how payments and payment timelines will work for different practices, as well as how that will affect the 3rd year matching fund requirement
- Some practices require similar annual costs (e.g. compost application), while others require higher initial costs and subsequently lower maintenance costs (e.g. hedgerows).
Eliminate the requirement for applicants to apply for at least one of the “cropland and rangeland soil management practices”
- All of the eligible incentive practices improve soil health and reduce GHGs.
- Many operations, especially organic agriculture operations, already utilize many of the “cropland and rangeland soil management practices,” and may only be eligible to apply for the herbaceous and woody cover practices. This limitation of the program could keep innovative farmers and ranchers unnecessarily out of the program.
Simplify the application for applicant feasibility
- To the extent possible, convert the proposed narrative questions into checkboxes and bullet points, and clarify the remaining narrative questions to make it clear what CDFA is looking for in responses.
Require soil tests from award recipients, not applicants
- Soil tests require labor, money, and time to complete, which make them unreasonable to require in a short application window; instead, require them to be completed within a certain timeframe after awards are announced.
Reward applicants for conservation plans and matching funds, but not so much that it creates a structural disadvantage to limited-resource and small-scale farmers
- Conservation plans and matching funds will extend the impact of the program, but the reality is that few farmers currently have them. Those that do and/or can acquire them within a short application period will tend to be larger-scale farms with more resources. The reward for conservation plans and matching funds can increase over time.
- Limit extra points for conservation plans to no more than 5 points.
Shift the demonstration program back to its intended goal of expanding the impact and adoption of Healthy Soils practices
- The primary intent of demonstration projects is to demonstrate the efficacy and practical considerations of adopting new practices to fellow farmers and ranchers; scoring criteria should reflect that intent.
- Eliminate the requirement for GHG flux monitoring and focus scoring criteria on outreach and education outcomes, including demonstrating farmer and rancher adoption of healthy soils practices.
- The quantification methodology from Air Resources Board (ARB) is sufficient to meet the requirements of Greenhouse Gas Reduction Fund dollars; limited program funds should not be used for unnecessary, expensive monitoring.
- Without this change, we run the risk of developing a program that results in neither the publication of peer-reviewed science (because the program is not set up to accomplish this) nor the achievement of its full potential in encouraging farmers to adopt new practices.