The National Association of State Departments of Agriculture (NASDA) appreciated the opportunity to provide oral comments during the U.S. Environmental Protection Agency’s (EPA) Farm, Ranch, and Rural Community Committee (FRRCC) meeting on May 26, 2016. Per the request of the FRRCC’s Designated Federal Officer (DFO), NASDA submits the following overview of those oral comments for the record.
NASDA represents the Commissioners, Secretaries, and Directors of the state departments of agriculture in all fifty states and four U.S. territories. State departments of agriculture are responsible for a wide range of programs including food safety, combating the spread of disease, and fostering the economic vitality of our rural communities. Conservation and environmental protection are also among our chief responsibilities.
NASDA thanks all of the members of the FRRCC for your collective time, leadership, and engagement on behalf of the agricultural community. NASDA supports the FRRCC putting forward recommendations based on sound-science to better inform EPA’s policy initiatives related to soil health and to assist EPA in better understanding the intended, or unintended, consequences the Agency’s policy or regulatory activities may have on agricultural producers.
NASDA notes the FRRCC’s charge is to provide recommendations on: “how can EPA best create a framework for facilitating partnerships that builds upon existing resource protection efforts through collaboration and innovation? In what ways can this framework advance the Agency's knowledge, efforts and use of resources to promote soil health, particularly as it relates to water and air and to the adaption to a changing climate?”
NASDA sees EPA’s objective in promoting soil health as an opportunity for the Agency to better coordinate and engage with state departments of agriculture and the agricultural community across the diversity of production practices throughout the states and EPA Regions.
As the FRRCC continues to develop and formulate its recommendations, it is important to note the science around soil health is still developing, so NASDA encourages the Committee to avoid endorsing or recommending any regulatory actions related to soil health. NASDA supports the FRRCC’s discussions in delivering non-regulatory solutions in responding to the Administrator’s charge to the Committee, and NASDA strongly supports the Committee’s recommendations for a collaborative approach between EPA, the states, and the agricultural community to leverage existing resources, cultivate additional partnerships, and enhance the existing agricultural infrastructure within EPA.
During the committee meeting, the FRRCC heard numerous updates from EPA regional and program staff. NASDA noted one common theme throughout all of these reports was the limited time, resources, and capacity EPA’s Agricultural Advisors are able to invest in fulfilling their respective agricultural advisory roles. It is essential for the agricultural advisors to have the time, resources, and Agency support to engage directly with the agricultural producers in their regions. These activities facilitate continuing education and collaboration between EPA and the agricultural community, and NASDA is concerned the current lack of resources and personnel within the Agency’s agriculture advisory infrastructure has deteriorated the importance and significance of the roles and responsibilities these critical positions are meant to provide. NASDA is very supportive of any recommendations this Committee may make to the Administrator identifying the need for additional investments of resources and personnel in the Agency’s Agricultural Advisors infrastructure throughout EPA’s Regions.
As regulatory partners with EPA, NASDA stands ready to assist the Agency and the Regional Administrators across the country in facilitating and leveraging existing resources, cultivating additional partnerships, and enhancing the existing agricultural infrastructure within EPA.
Again, NASDA thanks all of the members of the FRRCC, Mr. Ron Carleton (Counselor to the Administrator for Agricultural Policy), and especially Secretary Northey for your collective time, leadership, and engagement on all of these issues impacting agriculture.
Thank you for your consideration of these comments. Please contact Dudley Hoskins (firstname.lastname@example.org) if you have any questions or would like any additional information.
Barbara P. Glenn, Ph.D.
Chief Executive Officer