Dear Ms. Deavers,
Thank you for moving quickly to implement the Soil Health Demonstration Trial, which was authorized by the 2018 Farm Bill. As you begin implementation of the Soil Health Demonstration Trial, the undersigned farmers, ranchers, AgTech representatives, and conservation nonprofit organizations wish to provide the following recommendations:
• Ensure funds support diverse projects: NRCS should facilitate diverse participation in this trial, allowing aggregation of data from farms and ranches of a variety of sizes, types, and locations. To achieve this outcome, NRCS should target outreach to underrepresented cropping systems and geographies, including farms using extended rotations, mixed crop-livestock operations, and rangeland. If NRCS receives an insufficient number of proposals from diverse applicants, the deadline for applications should be extended, and NRCS should continue outreach to those communities.
Diverse distribution of projects will help create a robust dataset that models such as COMET-Farm can build upon. This will enable farmers and ranchers to make informed decisions and develop tailored, site-specific blends of conservation practices that support climate change mitigation and conservation outcomes, while also building the foundation for credible carbon markets.
• Ensure the data generated by the demonstration trial is credible and scalable: We were pleased to read in the project announcement that NRCS requires Soil Health Demonstration Trial participants to use “consistent soil health assessment protocols developed by NRCS.” To achieve that outcome, we urge NRCS to fund initial comprehensive soil tests for participating farmers, as well as another round of testing after three years. This would ensure that the data generated by this project is tracked and collected in a reliable manner, creating the basis for a market-driven price for carbon removal. We also urge NRCS to share data generated from this trial throughout USDA and with climate and farm-decision models, such as COMET-Farm, so that the demonstration trial can be a basis for future research and policy-making on the topic of soil health.
The Soil Health Demonstration Trial has received enthusiastic support from a diverse collection of stakeholders because the need for serious investments in our soil is so great. From farmers hungry for a steady revenue stream in an era of uncertain crop prices and erratic weather, to investors excited about the potential for new markets, to conservation groups eager to double down on practices that provide a host of environmental co-benefits, the Soil Health Demonstration Trial has something for everyone. And to ensure this program achieves its critical and beneficial goals, we urge NRCS to prioritize diversity and scalability when considering applications for funding.