USDA public comment on climate-smart agriculture & forestry
Release Date: 04-29-2021

Forestry, agriculture, fisheries, green building, and ecosystem services are all sectors with strong potential for mitigating greenhouse gas emissions through carbon storage and have real needs for investment to bolster their resilience in the present and ever worsening climate crisis. Ecotrust is a nonprofit that for 30 years has worked at the intersection of equity, economy, and environment in communities from California to Alaska and we are responding to the USDA’s Notice of Request for Public Comment on the Executive Order on Tackling the Climate Crisis at Home and Abroad with recommendations to expand and improve climate-smart agriculture and climate-smart forestry practices.

The impacts of climate-smart agriculture and climate-smart forestry related to both climate mitigation and climate adaptation should not be underestimated. If farmers and ranchers globally began implementing climate-smart agriculture practices today, we could capture 106.25 gigatons of carbon in the soil before 2025, effectively halting climate change. In our own region, forests on private lands are currently sequestering and storing carbon at about a third of their potential. The need is urgent and the opportunities in agriculture and forestry are great.

Our recommendations for climate-smart agriculture and climate-smart forestry are shaped by our engagement with and experience in frontline communities across our region. Frontline communities are Black, Native American, Indigenous and People of Color communities and immigrant and low-income communities that historically and presently experience the brunt of health, economic and ecological impacts and have been made more vulnerable to the consequences of climate change because of these factors (definition reference: Oregon SCR 17 written by Beyond Toxics, NAACP Eugene-Springfield, and others). In response, for decades and millennia these communities have been adapting and innovating solutions to build resilience and support economic and social well-being. Ecotrust recommends broad changes to enable these communities to further drive policy. This includes engaging with science which includes Traditional Ecological Knowledge (TEK) and reconciling TEK and other cultural, non-European, ways of knowing into decision-making processes.
We also strongly endorse the co-management of federal lands and waters by American Indian tribes. The USDA should seek out and financially support co-management agreements and prioritize building trust with tribes. Additionally, as many Native American communities are facing serious impacts of climate change, co-managing resources provides opportunity for innovation and adaptation.

The following recommendations will help advance climate-smart agriculture and climate-smart forestry through incentives, targeted research, ecosystem supports, and equity-centered approaches. They have the potential to speed climate adaptation and mitigation, while generating stable prosperity and enhancing the natural systems on which we all rely.


Climate-smart agriculture is a method of growing food that improves the resources it uses, rather than destroying or depleting them. By promoting adoption of practices such as cover cropping, low or no till cultivation, compost application and nutrient management, preservation and restoration of riparian corridors, and the perennialization of our agriculture systems, we can:

  • Regenerate the soils of our region
  • Produce healthy foods for local communities
  • Build resilience in the face of extreme weather events
  • Cultivate habitats of rich biodiversity
  • Combat climate change through carbon sequestration

There is good evidence supporting climate-smart practices as a tool for climate mitigation, but more studies are needed to better understand where and how carbon sequestration happens in soil and in particular, how management practices impact carbon drawdown and retention in specific soil types. We recommend the USDA fund such studies or conduct them directly via local NRCS offices.

While climate-smart agriculture projects have the potential to result in both the sequestration of greenhouse gases, who leads these projects matters. Black, Indigenous and communities of color have the ability to be regional leaders in generating durable, creative, and equitable strategies that respond effectively to climate change. And yet systemic oppression continues to create barriers for our region’s frontline communities to access land and infrastructure, resources, skills, and experiences to achieve these aims. We recommend the USDA address ongoing discrimination experienced by BIPOC farmers at local USDA and Farm Service Agency offices, and ensure equitiable access to programs, credit and resources. USDA should prioritize those who have been historically excluded and discriminated against by developing financing programs and establishing set-asides that enable farmers of color to build intergenerational wealth via land and business ownership. Ecotrust values and supports efforts such as the American Rescue Plan Act 2021 dedicating $5 billion to Black farmers.

A key advantage of climate-smart agricultural practices is that these practices both mitigate climate change and help farmers and ranchers be better prepared for the inevitable impacts of climate change. Policies that provide non-market incentive mechanisms that shift farms towards climate-smart practices are our key recommendation. Policies that are focused solely on maximizing sequestration or reducing emissions do not necessarily lead to more resilient landscapes. We recommend therefore focusing on incentivizing changes in land management, not carbon offsetting. For example, debt relief structures that support land managers in transitioning away from conventional agriculture will help support farmers’ ability to deploy climate-smart practices. We also recommend the USDA develop grant programs that support collaborative and community ownership of farmland, creating more opportunities for climate-smart practices to be implemented and lowering barriers to farming for individuals that may have important land-based knowledge regarding adaptation.

Furthermore, future policies must consider the impact to small and mid-sized farmers and ranchers who play an important role in their local communities and regional economies. For example, current carbon pricing policies that generate offset opportunities for agricultural producers can only be exploited at economies of scale because of the relatively large amounts of land required. This has an indirect effect of disadvantaging producers who function at smaller scales (e.g., the majority of producers in Oregon and Washington). Rather, policies that are focused on incentivizing specific practices that are known to build and retain soil organic matter can be equally accessed for all agricultural producers regardless of scale. We therefore support incentive-based policies for agricultural producers, like those offered by the USDA NRCS.

Existing NRCS programs (EQIP, CRP, CSP) are critically important to supporting farmers in transitioning to climate-smart agriculture. Decision-making on who receives incentive funding and what projects are funded should be a community-driven process that includes diverse perspectives with priority for BIPOC, small-scale, and young farmers. Decision-support tools, software, and technologies that are open source, accessible, and free to share should be created to support transition. USDA NRCS and FSA should invest in hiring additional field staff at the local level that reflect the growing diversity of farmers in our nation and make all of its programs and resources language accessible to better serve diverse ethnic groups. The USDA should consider building capacity of farmers and ranchers to better monitor ecosystems (soil testing, water infiltration, biodiversity counts) so that they are able to understand the impact of transitioning to regenerative management practices, and so that the agency is able to better quantify the impact of their programs. The USDA and its associated agencies should have the ability to explore developing new programs and initiatives with partners at a community level vs a national or state-level.


The potential climate impacts of careful, targeted management across the 766 million acres of forest lands in the United States is hard to overstate. Targeted policy is a critical component of progress towards drawing down carbon and reducing wildfire risk while protecting clean drinking water, biodiversity, cultural resources, and natural forest functions.
Today, “climate-smart forestry” may mean different things to different people. However, there are common themes worthy of the USDA’s consideration. Climate-smart forestry requires a long-term view of forest management and an appreciation for the array of economic, social, environmental, and cultural benefits forests offer. Climate-smart forest management includes:

  • Encouraging longer rotations than is common practice and limiting average harvest sizes to no more than 40 acres
  • Protecting water quality and aquatic habitats with larger buffers around streams and wetlands than is common practice
  • Tightly restricting the use of chemicals and prohibiting particularly hazardous chemicals
  • Placing primary, unique, and rare forests under permanent protection
  • Honoring and restoring the rights of indigenous people to access and shape the future of the forests within their traditional lands
  • Taking extra caution on steep and unstable slopes, including foregoing harvest on some
  • Including restoration activities as a routine part of management
  • Respecting the role fire plays in forest systems. This includes promoting the use of cultural burns and prescribed fires as restoration forestry tools. It is important to note that salvage logging post fire is not climate-smart or ecological forest practice
  • Open, accessible, and free-to-share technology and software created with the outcome of protecting ecosystems, preserving biodiversity, and understanding the other human impacts that have created our climate crisis.

Certifying all federal forests under the Forest Stewardship Council’s program, which is widely-recognized as the gold standard of forest certification programs, would be a first step to climate-smart forestry on all public lands.

In 2018, Ecotrust published a study in the peer-reviewed, open access journal Forests that found that changes to the market must occur for climate-smart forestry to grow. Leaving more trees standing to protect streams, provide better wildlife habitat, cultural resources, or to store more carbon comes at a financial cost to forest owners — conservation isn’t free. We found that climate-smart forest practices, using the Forest Stewardship Council’s guidelines as a proxy, store 30% more carbon on average than is commonly practiced by industrial timber companies. We also found that climate-smart forest management would be as financially attractive as this “business as usual” forestry if landowners were rewarded $37 per extra ton of CO2 they stored or if they received a 10 percent price premium on timber they sold, either through carbon policy incentives or premiums for certified wood. This study also shows that certification through the Forest Stewardship Council (FSC) in the Pacific Northwest is climate-smart, so further study into the climate benefits of FSC certification and whether public subsidies that make this certification more accessible to smaller landowners in particular would have climate benefits, while also supporting access to new markets.

Through a carbon incentive program targeted at private forest lands and modeled after the Natural Resource Conservation Service’s Grassland and Wetland Reserve Programs, we could develop a carbon rental program and achieve quantifiable increases in carbon sequestration and storage on private lands. Consistent with EQIP and some other USDA programs, this carbon rental program should be limited to producers who earn less than $1million per year.

We also fully endorse the NRCS’s Healthy Forest Reserve Program and strongly recommend that its geographic scope and funding be significantly expanded, so that the thousands of interested landowners who are currently unable to participate in the program could enroll their forests in this program that is highly popular with forest landowners.


Since 1991, Ecotrust has worked at the intersection of equity, the economy, and the environment, focused on our mission to create economic opportunity, social equity, and environmental well-being. Ecotrust envisions a future in which the worst consequences of climate change are averted, due in large part to better management of natural systems, and that the impacts of climate change are met with solutions that are equitable and restorative. Well-funded current programs and new policies provide critical links between where we are today and equitable, prosperous, and climate-smart future. We look forward to continuing to partner with the USDA toward this shared goal.