We believe that crop insurance is a critical component of the farm safety net and warrants support from taxpayers. However, we believe that reforms designed to require basic environmental protection, improve transparency, and place reasonable limits on the amount of premium subsidies for the largest and most profitable farm businesses would have no impact on program participation but would create a more equitable, sustainable, and fiscally responsible safety net.

We urge you to strengthen the federal crop insurance program by supporting common sense reforms, including proposals designed to strengthen America’s family farms while making crop insurance more equitable, transparent, and fiscally responsible.

Signed,

This letter is sent on behalf of the undersigned groups. For more information contact Lorette Picciano, Rural Coalition at lpicciano@ruralco.org or 202-628-7160; Katherine Ozer, National Family Farm Coalition at kozer@nffc.net or 202-543-5675 and Ferd Hoefner, National Sustainable Agriculture Coalition at fhoefner@sustainableagriculture.net, 202-547-5754.

May 13, 2013

Dear Chairs and Ranking Members,

As Congress continues its work on a new farm bill, we write to express our support for the Agriculture Committee efforts to complete a full and fair 2013 Farm Bill that will increase economic opportunity for the nation’s diverse family farmers, farmworkers, rural and urban communities and Indian Tribes; protect the environment; and ensure proper nutrition for all families and communities.

We, the undersigned organizations, all have recommendations for the farm bill that extend well beyond the specific issues in this letter, but we focus here on specific equity considerations. We support a full and fair package that balances any reductions across all areas of the Farm Bill, mitigates disasters especially for the most vulnerable producers, protects natural resources, enhances equity and inclusion, constructs a new and economically viable future for agriculture and rural communities, and assures healthy food for all consumers.

For years we have struggled to achieve a fair share of federal farm spending for all the communities we serve. Working with you in the 2002 and 2008 Farm Bills, we have made significant strides forward to allocate a small but growing portion of overall US farm and food policy to enhance equity for our nation’s diverse producers and farmworkers, secure a future in agriculture for new entry farmers and rural, urban and tribal communities, and provide fresh, local food for all consumers. Unfortunately, the farm bill extension we are currently operating under has shut down many of these very programs, setting back the modest progress achieved earlier.

We urge you to provide long-term protection and continued funding to this critical subset of small programs and offices charged with serving the most chronically underserved segments of agriculture. These represent a fraction of the full agriculture budget but are the lifeblood of a sustainable agriculture, rural development and food policy, including Indian Tribes, socially disadvantaged, beginning, and veteran producers, and farmworkers.

As you continue to shape your policy and budget proposals, we urge you to assure strong farm bill mandatory funding support at no less than $20 million a year each for the Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers Program, Beginning Farmer and Rancher Development Program, and Value-Added Producer Grants, as well as at least $4 million a year for Rural Microentrepreneur Assistance Program.

A fairer farm bill would also provide appropriate waiver, premium reduction, targeting, and advanced payment provisions for beginning, limited resource and socially disadvantaged farmers and ranchers within the farm bill conservation, credit, crop insurance, NAP, specialty crop, and rural development programs. In this light, we urge you to include all of the provisions of the Beginning Farmer and Rancher Opportunity Act and the 2013 Farm Bill Equity and Access Priorities Package in the new five-year farm bill (summaries attached; noting that a number of priorities are included in both packages).

As you proceed with your farm policy deliberations, we urge you to make all funding and policy recommendations relative to farm bill programs with an eye toward the future, a concern for the next generations of our nation’s farmers and ranchers and healthy and nutritious for food for all, and great care to being inclusive of women, minority, tribal and limited resource farmers, farmworkers and rural and urban communities who are oftentimes in most need of these important programs.

Sincerely,
African American Farmers of California, Fresno, CA
Agricultural Missions, Inc (AMI), New York, NY
Alabama State Association of Cooperatives, Forkland, AL
Alianza Nacional de Campesinas, Oxnard, CA
American Federation of Government Employees, Local 3354, St. Louis, MO
American Raw Milk Producers Pricing Association (ARMPPA), Kendall, WI
Arkansas Land and Farm Development Corporation, Brinkley, AK
Ashtabula, Geauga, Lake Counties Farmers Union, Windsor, OH
Atrisco Grant-Merced, Albuquerque, NM
BioRegional Strategies, Albuquerque, NM
California Climate and Agriculture Network, Sacramento, CA
California FarmLink, Sacramento, CA
Cape Cod Community Supported Fishery, Chatham, MA
Carolina Farm Stewardship Association, Pittsboro, NC
Cedarville Band of the Piscataway Indians, Inc., Waldorf, MD
Center for Rural Affairs, Lyons, NE
Center for Social Ecology and Public Policy, Honolulu, HI
Center for Social Inclusion, New York, NY
Center for Social Sustainable Systems (CeSoSS), Albuquerque, NM
Colorado Hispanic Ranchers & Farmers, Antonito, CO
Community Alliance for Global Justice, Seattle, WA
Community Food and Justice Coalition, Oakland, CA
Community Servings, Boston, MA
Connections Unlimited, LLC, Yachats, OR
Cultivating Community, Portland, ME
Dakota Rural Action, Brooking, SD
Dixon Farmers Market, Dixon, NM
Dockery Group, LLC, Elm City, NC
Ecological Farming Association, Soquel, CA
Equal Exchange, West Bridgewater, MA
Family Farm Defenders, Madison, WI
Farm Aid, Cambridge, MA
Farm Fresh Rhode Island, Providence, RI
Farm to Table, Santa Fe, NM
Farms Not Arms, Petaluma, CA
Farms to Grow, Oakland, CA
Farmworker Association of Florida, Apopka, FL
Federation of Southern Cooperatives, Epes, AL
Federation of Southern Cooperatives/Land Assistance Fund, East Point, GA
Food & Water Watch, Washington, DC
Food Chain Workers Alliance, Los Angeles, CA
Food First, Oakland, CA
Foodshed Alliance, Blairstown, NJ
Franciscan Fraternity Espiritu Santo, Albuquerque, NM
Grassroots International, Boston, MA
Healthy Farms Healthy People Coalition, Washington, DC
Hmong National Development, Inc., Washington, DC
Hunger Action Network of New York State, New York, NY
Illinois Stewardship Alliance, Springfield, IL
Indian Country Agriculture and Resource Development Corporation (ICARD),
Anadarko, OK
Institute for Agriculture and Trade Policy, Minneapolis, MN
Johns Hopkins Center for a Livable Future, Baltimore, MD
Kentucky Resources Council, Inc., Frankfort, KY
La Minga Cooperative Farm, Prospect, KY
La Plazita Farm, Albuquerque, NM
La Semilla Food Center, Anthony, NM
Land Stewardship Project, Minneapolis, MN
League of United Latin American Citizens (LULAC), Hereford, TX
Lideres Campesinas, Oxnard, CA
Live Real, Oakland, CA
Local Food Hub, Charlottesville, VA
Los Jardines Institute (The Gardens Institute), Albuquerque, NM
Maine Rural Partners, Orono, ME
Matthews Family Farm, Eighty-Four, PA
Michigan Coalition of Black Farmers, Detroit, MI
Michigan Food & Farming Systems (MIFFS), East Lansing, MI
Mississippi Association of Cooperatives, Jackson, MS
National Council of La Raza, Washington, DC
National Family Farm Coalition, Washington, DC
National Hmong American Farmers, Inc., Fresno, CA
National Immigrant Farming Initiative, Washington, DC
National Sustainable Agriculture Coalition, Washington, DC
National Women In Agriculture Association, Oklahoma City, OK
Nebraska Sustainable Agriculture Society, Ceresco, NE
New Entry Sustainable Farming Project, Lowell, MA
New Mexico Acequia Association, Santa Fe, NM
New Mexico Food and Agriculture Policy Council, Santa Fe, NM
North Carolina Association of Black Lawyers Land Loss Prevention Project, Durham,
NC
Northeast Organic Dairy Producers Alliance, Deerfield, MA
Northeast Organic Farming Association- Interstate Council, Stevenson, CT
Northeast Sustainable Agriculture Working Group (NESAWG), New Paltz, NY
Northern New Mexico Stockmens Association, Espanola, NM
Northwest Atlantic Marine Alliance, Gloucester, MA
Northwest Center for Alternatives to Pesticides, Eugene, OR
Northwest Farm Bill Action Group, Seattle, WA
Northwest Forest Worker Center, Albany, CA
Ohio Ecological Food and Farm Association, Columbus, OH
Oklahoma Black Historical Research Project Inc., Oklahoma City, OK
Panola Land Buyers Association Housing Development Corporation, Eutaw, AL
Pennsylvania Association for Sustainable Agriculture, Millheim, PA
Pesticide Action Network, Oakland, CA
Positive Action Now, Inc., Richmond, VA
Presbyterian Church (USA), Washington, DC
Progressive Agriculture Organization, LaFargeville, NY
Pululu Farm, Arroyo Seco, NM
Root ‘N Roost Farm, Livingston Manor, NY
Rural Advancement Foundation International-USA (RAFI-USA), Pittsboro, NC
Rural Advancement Fund, Orangeburg, SC
Rural American Network, Estancia, NM
Rural Coalition/Coalición Rural, Washington, DC
Rural Vermont, Montpelier, AL
School Food FOCUS National Office, New York, NY
Shoreline Study Center, Carlsbad, CA
Silas H Hunt CDC, Texarkana, AR
Slow Food USA, Brooklyn, NY
South Valley Economic Development Center, Atrisco, NM
South Valley Regional Association of Acequias (SVRAA), Albuquerque, NM
Southern Sustainable Agriculture Working Group (SAWG), Fayetteville, AR
Sustainable Farming Association, Princeton, MN
Taos County Economic Development Corporation, Taos, NM
The Border Agricultural Workers Project, El Paso , TX
The Cornucopia Institute, Cornucopia, WI
The Eye of Heru Study Group, Detroit, MI
The Second Chance Foundation, New York, NY
Tilth Producers of Washington, Seattle, WA
Torrez Farm, Arroyo Seco, NM
United Farmers USA, Manning, SC
Valencia County Older American Program, Belen, NM
Verley Family, LLC, Annandale, VA
Vian Peace Center, Vian, OK
Virginia Association for Biological Farming, Lexington, VA
Washington Sustainable Food & Farming Network, Mount Vernon, WA
WhyHunger, New York, NY
Winston County Self Help Cooperative, Louisville, MS
World Farmers, Inc., Lancaster, MA
Youngsville Livestock Association, Espanola, NM
Attachments:
2013 Farm Bill Equity and Access Priorities Package
Beginning Farmer and Rancher Opportunity Act Summary

This letter was prepared and circulated by the signatories who regularly participate in the “Getting Our Act Together (GOAT) on the Farm Bill” Collaboration, which promotes a fair farm bill with equity and sustainability.

2013 Farm Bill Equity and Access Priorities Package

The 2013 Farm Bill Equity and Access Priorities Package will promote balanced rural development and job opportunities in all rural communities across the nation and will expand opportunities for the nation’s diverse producers, including socially disadvantaged and veteran farmers and ranchers.

• Disadvantaged Producer Training – The Outreach and Assistance Program for Socially Disadvantaged Farmers and Ranchers and Veteran Farmers and Rancher (also known as the 2501 Program) is a historic program that provides competitive grants to educational institutions, Extension, and community-based organizations to assist African-American, American-Indian, Asian- American and Latino farmers and ranchers in owning and operating farms and participating in USDA programs. Language to expand program eligibility requirements to include veteran farmers and ranchers as approved in both the House and Senate in 2012 should be including and adequate funding of not less than $20 million per year included in order to serve both the traditional and new producers now eligible for the program.

• Establishment of a USDA Office of Tribal Relations – Language to permanently establish an Office of Tribal Relations within the Office of the Secretary of Agriculture, as included in 2012 versions of the Farm Bill, will ensure Tribal Consultation and Tribal Access to USDA programs and spurring job creation and economic development in rural communities across America.

• Expansion of the Substantially Underserved Trust Area Initiative with USDA Rural Development – Retaining the 2012 language to expand the Substantially Underserved Trust Area (SUTA) Initiative in USDA Rural Development Rural Utilities Service to all programs under Rural Development would improve access to family housing and community facilities financing and business and economic development funding, and provide RD with added flexibility to invest in individuals, businesses, and organizations developing private sector jobs and local economies in rural trust land communities.

• Expansion of the Highly Fractionated Land Loan Program – Legislative changes are necessary to make the Farm Service Agency (FSA) Highly Fractionated Land Loan Program practicable. Today, many land parcels on Indian lands have multiple owners – due to the historical lack of legal services and estate administration, residual owners can range into the hundreds or thousands of owners – resulting in situations which make it virtually impossible for such land to be economically viable. As ownership of tribal land passes from one generation to another, the owners’ ability to derive economic benefits from the land decreases as fractionation increases. Language included in 2012 would ensure implementation of the Highly Fractionated Land Loan Program within the Farm Service Agency by disconnecting that program from Bureau of Indian Affairs processes, to spur productive land use and job-creating development in Indian Country.

• Crop Insurance for Socially Disadvantaged Producers – Crop insurance is the center of the new farm safety net, but current programs do not work well for small scale producers of multiple fresh crops, or for organic producers. It is a priority to assure that socially disadvantaged producers as well as beginning and limited resource farmers and ranchers all receive the same premium waivers. Also necessary is an expansion of authority for the USDA’s Risk Management Agency to develop flexible new insurance products that better serve diverse producers of multiple fresh products on small-scale operations.

• Non Insured Crop Disaster Assistance Program (NAP) – Many small scale producers find the cost of NAP coverage for noninsurable crops prohibitive for small scale diverse operations (the cost for 1-3 commodities is the same for a 5 acre farm as for a much larger farm). As such, their income remains at great risk in times of natural disasters. Disaster coverage should be increased by expanding the current NAP premium waiver for Limited Resource Farmers and Ranchers to Socially Disadvantaged and Beginning Farmers and Ranchers.

• Improving the Farm Labor Workforce – The farm labor force faces a growing number of obstacles in obtaining training and services in methodology, technology, and environmental concerns. Previous statutory and funding authority of 10 million annually in authorizations for Grants to Improve the Agricultural Labor Workforce Program to provide training and other services to Farmworkers should be continued.

• USDA Coordination Activities for Socially Disadvantaged, Beginning and Veteran Farmers and Ranchers – Statutory and funding authority of $2 million annually to continue the work of the Office of Advocacy and Outreach to coordinate activities within the department to advance participation of socially disadvantaged, beginning, veteran and other small farmers and ranchers and farmworkers in the programs of the department should be continued and a USDA Military Veterans Agricultural Liaison Position charged with facilitating the process of educating returning veterans about and connecting them with training and/or agriculture vocational and rehabilitation programs should be added.

• Resource and Marketing Management Coordination – Additional authority would help producers improve resource management by allowing FSA, NRCS and FS to provide funding for loans, projects and practices serving socially disadvantaged farmers and ranchers that require the participation of multiple farmers and ranchers to be successful directly to entities directly managed and governed by farmers and ranchers who meet the definition of socially disadvantaged, including cooperatives, acequias and land grants (include definitions). A waiver of restrictions on the funding of governmental units should be provided for entities which meet the above definitions and which do not have independent tax collection authority.

• Strengthen Farm Service Agency Micro Loan and Youth Loan Program Authority – Term limits should be waived for youth loans and for socially disadvantaged, beginning and veteran farmers and ranchers in direct loans, including the new micro loan program. Authority should also be provided to expand eligibility for youth loans to youth in urban areas.

• Receipt for Service – Authority should be added to require the issuance of a written receipt for service or denial of service to any current or prospective participant programs serving farmers and ranchers as operated by the Farm Service Agency, the Natural Resources and Conservation Service and any other program directly serving producers.

• Conservation and Forestry Access – The following policies would expand conservation and forestry access including:
• Continue and expand the existing set asides for socially disadvantaged and beginning farmers and ranchers in the Environmental Quality Incentives Program (EQIP) and Conservation Stewardship Program (CSP) from 5 percent to 10 percent of the total EQIP funds and to 10 percent of total CSP acres and extends these set asides to all conservation and forestry programs serving farmers and ranchers.
• Expand the existing EQIP increased cost shares for SDFR and BFR to all Conservation and Forestry Programs serving farmers and ranchers which include a cost share, including community forestry and the Forest Stewardship Program.
• Extends and expands the advance payment authority for socially disadvantaged and beginning farmers from 30% to 50% in all conservation and forestry programs with cost shares.
• Add protection of the land of owned and operated by socially disadvantaged farmers and ranchers as a purpose for the use of Farm and Ranch Land Protection funds and to authorizes payment of up to 90 percent of the value of development rights in areas with high loss of land owned by socially disadvantaged farmers and ranchers.
• Add a 10% set aside for BFRs and socially disadvantaged farmers and ranchers in the Conservation Innovation Grant subprogram.                                                                                   • Whole Farm Conservation and Forestry Planning: Farm bill authority for special incentives for beginning, limited resource, and socially disadvantaged farmers and ranchers should be continued and authority added that Natural Resource Conservation Service (NRCS) and the Forest Service to provide these farmers and ranchers with technical and financial assistance (through EQIP, CSP, Conservation Technical Assistance or other programs) to develop whole farm resource management system plans.

• Treatment of Farms With Limited Base Acres – The Farm Bill 2008 exemption for limited resource, beginning and socially disadvantaged farmers and ranchers from the base-acreage minimum should be extended for producers receiving any direct, counter-cyclical, or average crop revenue election payments provided in the 2013 Farm Bill.

• Enhanced Access to Beginning Farmers and Ranchers Development Program – Previous setasides for projects serving socially disadvantaged farmers and ranchers in the BFRDP should be continued and the matching requirements for these projects reduced to 10%.

• Enhanced Opportunities in Value-Added Producer Grants – Priority for Value-Added Producer grant projects benefitting beginning farmers and ranchers should be expanded include socially disadvantaged and veteran farmers and ranchers, as well as the set-aside of program funding for these projects, and the match requirement reduced to 10% for projects benefitting socially disadvantaged farmers and ranchers.

• Rural Cooperative Development Access – Set-asides for projects serving socially disadvantaged farmers and ranchers should be continued.

• Assistance with Transitioning to Bioenergy Crops – Access to the Biomass Crop Assistance Program should be expanded by adding programs serving more than 51% beginning and socially disadvantaged farmers and ranchers as a selection criteria for projects.

• Access to Rural Energy for America Program – Matching requirements for project serving tribes and socially disadvantaged farmers, ranchers and communities in the REAP program should be reduced to 10% for Feasibility Studies and for Projects and an annual report required on amount and percentage of funds provided to these groups in each program.

• Report on Specialty Crop Production by Certain Farmers – Language should be included as passed in the House 2012 Committee bill to require USDA to conduct a study on specialty crop production by small, women, socially disadvantaged and veteran farmers and ranchers, who are significantly represented in specialty crop production. This provision would also require USDA to assess the public and private sector tools available to help expand, improve, and add value to the agricultural operations of these producers which are also an important source of varieties of products for preferred by expanding markets of growing diverse cultures. Data is a critical first step in bolstering production for these sectors of agriculture.

• Specialty Crop Block Grants – The requirement in the conference report in the 2008 farm bill that requires states to stipulate a plan for reaching and meeting the needs of small-scale, women, socially disadvantaged and veteran farmers and ranchers, who are significantly represented in specialty crop production, in their applications for Specialty Crop Block Grants should be continued.

• Emergency Disaster Relief Program for Farmworkers– The current program authority for emergency disaster relieve for farmworkers should be expanded to add a $2 million replenishable standing disaster fund and authority provided to the Secretary to require Farm Service Agency to assess conditions among farmworkers when assessing any disaster and to address the needs of farmworkers in any disaster declaration or response.

Beginning Farmer and Rancher Opportunity Act of 2013
Sponsored by Representative Tim Walz and Senator Tom Harkin
H.R. 1727 / S. 837
Section by Section Summary

Title I — Conservation
(Title III of the Farm Bill)

Sections 101, 102 & 131 — Conservation Reserve Program Transition Incentive Program (CRP-TIP) – Amend Sections 1231 and 1235 of the Food Security Act to to reauthorize CRP-TIP through 2018 and provide $50 million in mandatory funding over the life of the farm bill. Additionally, include provisions to strengthen the conservation language, create a comprehensive conservation plan option, create an easement option through the Grassland Reserve Program or the Farm and Ranch Land Protection Program, and allow transition between family members who meet the eligibility criteria but only in the case of land sales to the younger generation

Section 111 — Farm and Ranchland Protection Program (FRPP) – Amend Section 1238I of the Food Security Act of 1985 to make preserving farm viability for future generations a part of the purpose of the program, and to give funding priority to easements with an option to purchase at the agricultural use value, to deals that transfer the land to beginning and farmers and ranchers, to applicants with detailed farm succession plans, and other similar mechanisms to maintain the affordability of protected farm and ranch land, keep it as working land, and foster new farming opportunities.

Sections 121 & 132 — Environmental Quality Incentives Program (EQIP) – Amend Sections 1240B of the Food Security Act of 1985 to continue the existing cost share differential for beginning, limited resource, and socially disadvantaged producers within EQIP), and reaffirm the advance payment option allowing beginning and socially
disadvantaged producers to receive an advance payment for the project’s costs for purchasing materials or contracting services, but increase the limit on the advance payment from 30 percent to 50 percent of costs. Also, increase the rate at which USDA can provide conservation technical assistance to beginning farmers, and include a
priority on beginning and socially disadvantaged farmers within the Conservation Innovation Grants subprogram.

Section 133 — Whole Farm Conservation Planning – Amend Sections 1244(a) of the Food Security Act of 1985 to strengthen special incentives to beginning farmers and ranchers and limited resource producers to participate in federal agricultural conservation programs by authorizing NRCS to provide these farmers and ranchers with technical and financial assistance through EQIP, CSP, or other programs to develop whole farm resource management system plans.

Title II — Credit
(Title V of the Farm Bill)

Sections 201 & 203 — Direct Farm Ownership Experience Requirement – Amend Section 302(b)(1) of the Consolidated Farm and Rural Development Act to provide the Secretary with greater discretion in determining the number of years of farm management experience required for “qualified beginning farmers and ranchers” to be eligible for direct farm ownership loans. Also raise the cap on these loans by indexing the loan cap to farmland inflation rates.

Section 202 — Conservation Loans – Amend Section 304 of the Consolidated Farm and Rural Development Act to raise the guarantee amount under USDA Conservation Loans from 75 to 90 percent, create a 50 percent target participation rate for beginning farmers and ranchers similar to the targets for other loan programs, and delete the existing provision that waives the family farm eligibility requirement which is required for all other FSA loan programs.

Section 205 — Down Payment Loan Limits – Amend Section 310E(b)(1)(C) of the Consolidated Farm and Rural Development Act to increase the limit on the size of the land value that can be FSA-financed from $500,000 to $677,000, consistent with other FSA direct loan programs.

Section 211 — Microloan Authorization – Amend Section 313 of the Consolidated Farm and Rural Development Act to create a new simplified loan category within USDA’s direct operating loan portfolio to provide flexible capital through microloans (not to exceed a balance of $35,000) that shall be available to any eligible borrower, but
will have special incentives for young, beginning and veteran farmers, including a lower interest rate and exempting microloans to these borrowers from counting towards their loan history term limits. Also establish a cooperative lending program to allow USDA-selected intermediaries to make microloans to eligible borrowers.

Section 221 — Beginning Farmer and Rancher Individual Development Accounts Pilot Program – Amend Section 333B of the Consolidated Farm and Rural Development Act to reauthorize this matched savings program per the 2008 Farm Bill but with $5 million per year in mandatory funding to jump start the program. IDAs will be administered by the Farm Service Agency (FSA) through pilot programs in at least 15 states.

Section 222 — Graduation to Commercial Credit – Amend Sections 311(c) and 319of the Consolidated Farm and Rural Development Act to modify the FSA loan term limits provisions to not more than 15 consecutive years for guaranteed loans and not more than 9 consecutive years for direct loans.

Sections 204 & 223 — Priority for Participation Loans – Amend Section 346(b)(2)(A) of the Consolidated Farm and Rural Development Act to give priority within direct farm ownership loans to joint financing participation loans and down payment loans that involve private lenders. Also, decrease the unreasonably high minimum interest rates on these loans to make them more relevant in the current low-interest rate climate.

Section 206 — Limited Resource Interest Rate – Amend Section 316(a)(2) of the Consolidated Farm and Rural Development Act to adjust the minimum interest rate on direct loans to low-income borrowers so that it reflects the current low-interest rate climate.

Section 207 — Definition of Qualified Beginning Farmer – Amend Section 343(a)(11)(F) of the Consolidated Farm and Rural Development Act to modify the definition of “qualified beginning farmer and ranchers” so that the average, not median, farm size is used to determine FSA loan eligibility.

Title III — Rural Development
(Title VI of the Farm Bill)

Section 301 — Value-Added Producer Grants – Amend Section 231 of the Agricultural Risk Protection Act of 2000 to retain the priority and set-aside for projects benefitting beginning and socially disadvantaged farmers and ranchers, but clarify the language to make both individual farmer grants and farm business and coop grants practical and effective. Direct USDA to develop an outreach and technical assistance strategy to reach underserved states and regions. Renew mandatory farm bill funding at $20 million a year.

Title IV — Research, Extension, and Related Matters
(Title VII of the Farm Bill)

Section 401 — Beginning Farmer and Rancher Development Program – Amend Section 7405(c) of the Farm Security and Rural Investment Act of 2002 to reauthorize this highly successful flagship training program through 2018 and provide with $20 million per year in mandatory funding. Also, include a new priority on agricultural rehabilitation and vocational training programs for military veterans, and food safety training. Include a 10 percent cooperative agreement alternative to higher negotiated administrative reimbursement rates.

Section 402 — Beginning Farmer and Rancher Research Priority – Amend Section 2(b) of the Competitive, Special, and Facilities Research Act of 1965 to include a new program area to support research, education, and extension projects related to beginning, socially-disadvantaged and immigrant farmers and ranchers, farm transition and entry, new marketing and farm viability alternatives, and related issues. Also clarify the authorizing legislation to ensure that all AFRI programs (including integrated) are fully competitive and open to all eligible entities.

Title V — Crop Insurance
(Title XI of the Farm Bill)

Section 501 — Risk Management Partnership Programs – Amend Section 522 of the Federal Crop Insurance Act to add a strong emphasis on beginning and socially disadvantaged farmers and ranchers within this partnership grant program that funds projects to inform farmers about crop insurance products and broader risk management topics.

Title VI — Miscellaneous
(Title XIV of the Farm Bill)

Section 601 — Military Veterans Agricultural Liaison – Add a new section in Subtitle A of the Department of Agriculture Reorganization Act of 1994 to create a new Veterans Agricultural Liaison position at USDA charged with facilitating the process of educating returning veterans about and connecting them with beginning farmer and rancher training and agriculture vocational and rehabilitation programs.

Food and Drug Administration Listening Session on Proposed Food Safety Rules
Tuesday, April 30, 2013
Ohio Agricultural Research and Development Center, Wooster, OH

Good Afternoon. My name is MacKenzie Bailey and I am the Policy Program Coordinator for the Ohio Ecological Food and Farm Association (OEFFA).

Since our start 34 years ago, OEFFA has been dedicated to promoting and supporting sustainable, ecological, and healthy food systems. Today we have a membership of more than 3,200 dedicated farmers, consumers, gardeners, chefs, researchers, and retailers. Together, we are working to recreate a regionally-scaled farming, processing, and distribution system that move food from farm to local fork.

OEFFA is also an accredited organic certifier, and certifies more than 750 operations throughout the Midwest, many of whom are growers or food processors that will be required to either fully or partially adhere to the FDA’s proposed preventative controls and produce rules.  For this reason we are diligently working to educate and engage our members in the rulemaking process.

We understand the importance of providing safe food, free from dangerous pathogens, and have recently offered a training workshop to our members on methods for meeting Good Agricultural Practices.

Nevertheless, the proposed rules are daunting to many producers and I’d like to address several areas of concern:

First is that of cost. Under the proposed rule Ohio’s many small family farmers will incur expenses, perhaps higher than they can afford. According to the FDA’s own estimates a “small” farm would bear a more than $27,000[1] initial cost of compliance and from then on an average annual cost of nearly $13,000[2]. The average net cash income for farmers nationally was 10 percent of sales in 2011[3]. In other words, initial compliance with the produce safety rule could consume more than half of a small farm’s yearly profits [i.e., a farm with sales of $450,000 making $45,000 profit per year, would see their profits drop to $17,434 in the first compliance year].

This scenario is only more extreme for the “very small” farm, which is estimated to incur more than $22,000[4] in initial compliance expenses [i.e., a farm with sales of $200,000 making $20,000 profit per year, would lose money their first year of compliance].

If the FDA does not address the cost of the proposed rule, many of America’s farmers may face the real risk of going out of business and our nation’s ability to attract future generations of farmers will only become more difficult.

Second is that of conflict with the organic standards. The Food Safety Modernization Act stated that produce standards should not conflict with the U.S. Department of Agriculture’s (USDA) National Organic Program (NOP) regulations for certified organic production. For example, the NOP allows farms to use raw manure fertilizer if it is applied 120 days (approximately four months) before harvest if the crop’s edible portions come into contact with the soil. Under the proposed rule a nine month restriction period would be required, which is excessive in comparison to the organic standards[5].

Third is that of exemptions. The smallest farms (those making less than $25,000) will be exempted from the produce safety rule, while others fall under a modified requirement status. There are many questions about the withdrawal of such statuses, as well as the restitution process. There need to be clear, predictable steps leading to a withdrawal, rather than a “one strike and you’re out” approach.

Finally, every farmer I have met strives to provide safe food, free of pathogens that cause illness. Training and education for preventing food safety outbreaks is necessary for farmers to succeed. Adequate funding will be needed for plain speak training materials, workshops, and outreach.

Maintaining safe food in this country is essential, but it should not create unnecessarily burdensome regulations that put diversified, sustainable, and organic farms at risk of going out of business. Many of these farms are already at lower risk of creating large foodborne illness outbreaks due to their size, scope, and, for some, alternative farming practices that maintain soil and water integrity.

Thank you for your time.

Addressed to the Franklin County Planning Commission on a Zoning Amendment Regarding Chickens, Ducks and Rabbits
Wednesday, May 8, 2013

Good afternoon and thank you for accepting my request to speak today about the proposed zoning amendment to allow chickens, ducks, and rabbits on lots less than 5 acres.  My name is MacKenzie Bailey and I am the Policy Program Coordinator for the Ohio Ecological Food and Farm Association, or OEFFA.

Since our start 34 years ago, OEFFA has been dedicated to promoting and supporting sustainable, ecological, and healthy food systems.  Today we have a membership of more than 3,200 dedicated farmers, consumers, gardeners, and homesteaders, including more than 300 members in Franklin Co.

Together we are working to recreate regionally-scaled farming, processing, and distributions systems that move food from farm to local fork.  We are extremely encouraged to hear about the county’s efforts to make allowances for small livestock that will strengthen local food security, give consumers more of a connections to their food, and potentially save Franklin Co. residents money,

In February, OEFFA submitted comments to the County Economic Development and Planning Department that we felt would improve the practical application of the Zoning Amendment.

After reading the most recent draft of the amendment, it is clear that the County looked carefully at each comment submitted and made thoughtful adjustments – changes that have both simplified and clarified the requirements, and which will allow animal owners to more easily comply with the regulations.

Namely, OEFFA was pleased to see a reduction in the fencing requirements for lots more than 1 acre; more flexibility in the disposal, storage, and application of manure; and reference to the standards established by the Ohio Livestock Care Standards Board.

For us, one area of concern remains – the restriction on the number of animals allowed on lots larger than 1 acre. In our original comments we recommended two dozen birds for every acre of land. We stand by that recommendation for two primary reasons:

1)      The first is that – The current allotment is too small for a family to sustain themselves.  According to Harvey Ussery, author of The Small-Scale Poultry Flock, a family of four requiring two eggs per day per person would need a flock of a dozen laying hens.

If the same family would like to raise chickens for meat, they would need many more animals.  In our original comments, we provided a conservative estimate that if a family of four ate one bird a week they would need 52 birds for the year.  I spoke with a chicken farmer who explained to me that it wouldn’t be unreasonable to expect a family to bring those birds to slaughter on a quarterly basis.  Meaning at any one point in time this family of four would need a minimum of 25 birds.

Depending on a family’s individual circumstances, they may need more birds.

When OEFFA originally submitted comments, the rule appeared to count rabbits separate from birds, now it counts all animals on a point system. This change would further restrict a family who preferred to produce their own supply of meat and eggs.

2)      The other point I’d like to make is that birds do not require much space, and as acreage increases the likelihood that they would create a nuisance or public health concern decreases. In fact, as a comparison, the Ohio Livestock Care Standards allow for as many as 43,560 laying hens per acre. Granted those allotments are intended for commercial use, but it illustrates just how little space two dozen birds would require.

For these reasons, and because it is important to OEFFA and our members that the rules meet their intent, I ask the County to consider raising the number of animals allowed to two dozen per acre.

I’d like to end my comments today on a personal note.  I am not an Ohio native. I transplanted here five years ago from Buffalo, NY. One of the reasons I’ve stayed in Ohio, and plan to remain here, is that the local food economy is thriving. I appreciate the value of keeping my dollars local and even more so, I enjoy the strong sense of community that is associated with the local food movement.  I’m proud to live in a county that is proactively creating policies that support homesteaders, farmers markets, and food cart businesses. In the future, I hope the County considers expanding the rules to cover commercial production.

Nevertheless, I want to emphasis how appreciative OEFFA is to have these new allowances in place and thank you again for your efforts, as well as to have the opportunity to provide input on this important issue.