A chance to make a difference?

Note: Comments needed prior to the end of July 2020!

I saw this on social media: the USDA is seeking stakeholder comments pertaining to Agricultural Innovations and regulations.

https://www.regulations.gov/docket?D=USDA-2020-0003

One of their "clusters" of research for increasing agricultural production by 40% while decreasing adverse environmental footprint is for "Systems Based Farm Management".

Perhaps I'm not reading the site correctly, bit it sounds like an amazing opportunity to innoculate permaculture design into the USDA's thinking, while advocating for smaller, freer, localized solutions.

Who is with me?

It's hard to know if/when the big guys are listening to the little guys, but why don't you post your response in this thread? If a bunch of us pick up the same theme but write it in slightly different ways, we might get someone's attention - sort of the "geeze that's the 10th reply that mentioned permaculture and some dude name Mark Shepard" kind of reaction.

I haven't followed the link you gave - I'm not sure they'd be welcoming to a Canadian's perspective! That said, getting your farming system more sustainable would impact positively on us, so I would consider myself a stakeholder, even if they don't!

I have developed several potential comments to share with the USDA Agricultural Innovation Agenda developers.  

I'm going to assume that they are honostly listening to feedback.  What do people think?  As mentioned, we could each post something pushing for more small-scale, ecologically diverse, localized, permaculturized solutions.  Thoughts?



**1**
On February 20th, USDA Secretary Perdue called for an agricultural productivity increase of 40% by 2050 via the department-wide Agricultural Innovation Agenda, while simultaneously calling for social, economic, and environmental sustainability.  USDA has requested public feedback on the agenda.  As a Navy veteran (and beginning farmer and farming systems designer) who has had a passion for innovation in the federal government, I think it is always important to challenge baseline assumptions.  A common technique in brainstorming and innovation circles I’ve been in or read about is to “flip the question”.  In this case, I’d like to flip the core goal of USDA’s Agricultural Innovation Agenda:

Do we really want to increase agricultural productivity by 40%?

**2**
I’m very concerned with this generic goal to increase production. I firmly believe that across the board agricultural productivity increases to the American food system will not make us a freer, healthier, more resilient society.  If production increases, it is critical to address “where” the productivity increases.


**3**
High volume, high efficiency, monoculture crop systems tend to increase farmer stress, and decrease their resilience to market changes and environmental disasters.  We need to get rid of this government-inspired mantra to “feed the world”.  The scale of necessary production has become too great of a burden placed upon so few.  

**4**
There is a reason that the age of the average farmer has become much older, and that youth are not becoming farmers in mass.  There are reasons that farmer suicides are double the American rate, and food literacy is low.  The solution is not more technology, bigger production, big data, cheaper food, small sensors, or genome-design.  The solution is ecologically diverse, culturally rich, localized, highly valued, and ethical food systems such as those espoused in permaculture design.

**5**
Increases in production efficiency, such as the factory farm meat system, or our reliance on chemically-based corn production, economies of scale, large machinery, commodity markets, and just-in-time long distance supply systems have all tended to increase the prevalence of faster, cheaper food, at the expense of quality home grown, homemade family meals and know how, and ultimately American resilience.    Socially, Americans’ away-from-home eating habits have now far outpaced the traditional family dinner at the table.  Even the best selling truck in the world is now being designed to make it easier to eat inside the vehicle.  This absolutely has greater societal ramifications.  The importance of family values developed around family meals at the dinner table must not be overlooked.  

**6**
Conventional (government-sponsored) agriculture systems contribute to American obesity, which is currently at record highs, to the detriment of our health, economy, and even national defense.  Why continue this trajectory?  USDA reports Americans are eating 20% more calories than in the ‘90’s.  Simultaneously,  CDC reports that American obesity is now over 40%.  And while we may be “eating more vegetables” than in the 1970’s, this is a misnomer, as America’s number one vegetable is the potato.  Obesity is literally killing us.  Even the American military has become fat, with the combined overweight and obese portion of the military rising to 60% between 1995 and 2008.

**7**
Economically, it is true that American disposable income has increased, and people are spending less on food as a portion of their earnings than in the past.  But while at first this seems like a good thing, the reality is that Americans spend over$66,000,000,000 annually on trying to lose those very calories which government programs and subsidies have made so freely and easily available.  Simultaneously, health spending continues to skyrocket in the United States, to the tune of over $10,000 annually per person.  As the ancient saying goes “Let food be thy medicine.”

Wouldn’t it be great if a portion of that $10,000 in health spending went straight to developing more local and backyard farm (healthy) systems?  Even the $445 per person per year that the USDA costs American taxpayers could go a long way in developing a resilient backyard food system, as even apple trees--apples are Americans’ favorite fruit-- cost only a couple dollars per tree.

**8**
Focusing on increases to conventional production systems, generating more data, technology, and genome design capability will not address local food resilience.  
A decentralization of food policy and production systems is especially poignant because food literacy is waning.  American children don’t know where their food comes from, and I am willing to bet that the majority of US adults, if surveyed now, would think that pineapples grow on trees.  

**9**
The US spends billions a year on pets, but how many can take care of a chicken (thereby greatly reducing at home food waste) and eventually butcher it as our grandparents could?  Can the average teenager bake a loaf of sourdough bread, or keep a culture alive in their refrigerator?  

**10**
In the event of “black swan” style disruptions to the ever centralized US food system, Americans absolutely need to have backyard and small-farm wisdom, skills, and food production, processing, and storage capabilities, regardless of whether they live in urban or rural environments.  Any USDA innovation agenda must focus on developing this “victory garden” or cottage food industry culture by removing regulation and systems which promote its exact opposite.  

George - I followed the link and it did not give *any* information on the page as to what they're looking for. Does more appear if you "sign in" (there's a little button for that which I didn't push.) You stated, "On February 20th, USDA Secretary Perdue called for an agricultural productivity increase of 40% by 2050 via the department-wide Agricultural Innovation Agenda". Is that a document you could either link to, or copy to this thread in its entirety?

As for what you've written, it reads like a government document to me. If you think that will appeal to them, fair enough, but since you're suggesting they change their approach dramatically, I'd be willing to re-write what you've written in a style I've used to get my "letters to the editor" published and my "letter to my MP" quoted in an official government document, and you could see if you like it?

I went ahead and actually already submitted my comments.  Frankly, I'm sure my voice and opinion will mean less than nothing; but mostly I needed to just vent.

I love America.  I love how blessed we are as a country.  But I'm concerned that any "innovation" agenda in government research will be more of the same trajectory: monoculture, cheap food, American obesity, and big government picking the big company winners at taxpayer expense.

***

These links should work in case others would like to weigh in, though my submission won't show, as it has to be "approved" by the Department before it shows up:

https://www.usda.gov/media/press-releases/2020/02/20/secretary-perdue-announces-new-innovation-initiative-usda

https://beta.regulations.gov/document/USDA-2020-0003-0001

George, thank you for bringing this to our attention!  I think that many of us will be willing to submit some comments, and that we can continue to develop those comments on this thread.  Goodness knows we don't need "more of the same," from USDA.  

Jay, I would be willing to take you up on your offer to share your writing skills and create even more compelling copy.  I think if we give our fellow permies some choices, they can craft their own responses (and might be more eager to do so).

I would like to reference Gabe Brown and Joel Salatin in my response.  (I'm going to look up the most appropriate citations for each.)  Both are creative, innovative, and can speak to farmers from a highly credible position.

Anne Pratt wrote:George, thank you for bringing this to our attention!  I think that many of us will be willing to submit some comments, and that we can continue to develop those comments on this thread.  Goodness knows we don't need "more of the same," from USDA.  

Jay, I would be willing to take you up on your offer to share your writing skills and create even more compelling copy.  I think if we give our fellow permies some choices, they can craft their own responses (and might be more eager to do so).

I would like to reference Gabe Brown and Joel Salatin in my response.  (I'm going to look up the most appropriate citations for each.)  Both are creative, innovative, and can speak to farmers from a highly credible position.

We need to remember that all the inputs that "big Ag" require - fossil fuels, pesticides, commercial seed, chemical fertilizers - are produced by big companies that donate money to the people who run for government and who then support the hiring of people in government positions. Advertising has convinced everyone that this is the way to go, so we need clear compelling information if we want to redirect the system. And I *will* use the work "information" as tempting as it is to use the word "arguments" - I think that's part of the problem - arguments suggest a "winner" and a "looser", one "right way" and therefore anything else has to be a "wrong way" - if we're going to suggest a "permaculture way", I feel it has better odds of success if it demonstrates an alternate route. For example, George quoted USDA Secretary Perdue calling for "an agricultural productivity increase of 40% by 2050" and questioned that. What if we suggested that we redefine "agricultural productivity" to include City Farms, boulevard polyculture "orchards", and vertical food structures against buildings? Food produced where it needs to be sold? What if we push to shift the line between "farming" and "gardening"?

I think that referencing Gabe Brown and Joel Salatin are valuable because they've both demonstrated that farming can repair the soil through intelligent design and observation. Some areas of the US would benefit from Alan Savory's Holistic Management approach. I've seen research that the California strawberry fields benefit from the installation and management of hedgerows - a farming technique that's hundreds of years old that still works. Savory's work has a track record for holding water on the land and reversing desertification - who's doing that in the US? With the increase in big storms, Permaculture techniques that manage storm water and produce food at the same time (Brad Lancaster for example?) need to be seen as "part of agricultural support".

A benefit of sharing your responses on this thread is that we can reinforce what others say by quoting variations on a theme. So please Anne, see what you can come up with and if you want ideas of changes, I will offer them for you to consider and use or discard as you wish. The more voices encouraging them to think outside the old box, the better the odds are that it won't all be "more of the same".

I went ahead and attached the USDA's Agriculture Innovation Agenda (AIA) vision statement document.

Their vision is much broader than just "let's make more cheap food using science and stuff!" as I had initially surmised.  There are good things in there, too.

Here's a summary-ish of their PDF, to help anyone channel thoughts to address their goals (but ultimately yours/ours):

1. They want 40% more production, with half the environmental footprint, by 2050.  

2. The "2019 National Academies of Science report, Science Breakthroughs to Advance Food and Agricultural Research by 2030," is a document they are using to guide RFIs, discussion, and to find opportunities.

3.They are trying to find common themes from your feedback to direct research efforts.

4. They want to rapidly get cutting edge tech and best practices to farmers.  They intend to "champion commercialization of innovative technologies in the private sector".

5. They want to collect more data on conservation efforts.

6. Their benchmarks for success:

*Agricultural productivity: Increase agricultural production by 40 percent by 2050

*Forest Management: investing in forest management and restoration through "Shared Stewardship Agreements with States".

*Food loss and waste: reduce food loss and waste by 50 percent by 2030.

*Carbon Sequestration and Greenhouse Gas: Reduction of the agricultural sector’s carbon footprint by 2050 without regulatory overreach via:
fertilizer and manure management,
capturing biogas,
improving livestock production efficiency,
conserving sensitive and marginal lands to enhance carbon sinks,
reforestation preventing wildfire,
maximizing the benefits of renewable energy through improved efficiency and carbon capture, and
encouraging soil health practices such as no-till to sequester carbon.

*Water Quality: Reduce nutrient loss by 30 percent nationally by 2050.

*Renewable Energy: Support renewable fuels, including ethanol, biodiesel, and biomass.

Wow! Thank you George - great job!
Your item #3 supports comments I've suggested - getting more permies to contribute "variations on a theme" that includes the word "permaculture" might get them paying more attention, particularly if we suggest things like how it would be nice to know just how much more carbon is sequestered in permaculture-based systems than industrial farming!

*Forest Management: investing in forest management and restoration through "Shared Stewardship Agreements with States".

For the record, mono-culture forests, aren't forests - they're mono-culture tree deserts. They're also at greater risk of both starting a forest fire, and spreading it to the uncontrollable levels we've seen recently. There's evidence that deciduous trees are important as fire breaks, and yet "professional foresters" see them as "garbage trees". Let's get them thinking outside the box, where a wide row of Sugar maples breaking up 10 acres of fir trees and provides the owner with a second source of income is seen positively. Similarly, we need to push coppicing for many wood needs - it can be done in very sustainable and ecologically responsible ways. I do wish Dave Jacke would get on with the book on the subject that's been a work in progress for 10 years now!

*Water Quality: Reduce nutrient loss by 30 percent nationally by 2050.

They haven't said here, "restored and artificial wetlands for removing nitrogen and other contaminants from run-off while generating useful biomass out of those contaminants". Unfortunately, the reality is that cities are contributing as much if not more of that nitrogen through people, pets and grass lawns! There's evidence that beavers not only support wetland creation, but their efforts at holding water on the land decrease the risk of forest fires. Biomass plants like cattails harvested from artificial wetlands can be composted for soil remediation.

There are plenty of good suggestions here - I think I'll see what I can do to generate more participation!

George - did you have to be 'signed in' to leave your comment? Did they ask you any questions that suggested that non-US-citizen feedback was unwelcome?

Thanks!

No sign in is required.  Additionally you can post anonymously.

Only 5 days left to add your 2¢ to the USDA's Agricultural Innovation Agenda.

https://www.regulations.gov/comment?D=USDA-2020-0003-0001

I didn't do this, but when writing your comments on their website, consider addressing their writing prompt:

1. What agricultural commodity, group of commodities, or customer base does your response pertain to or would benefit?

2. What are the biggest challenges and opportunities to increase productivity and/or decrease environmental footprint that should be addressed in the next 10- to 30-year timeframe?

3. For each opportunity identified, answer the following supplemental questions:

a. What might be the outcome for the innovation solution (e.g., the physical or tangible product(s) or novel approach) from each of the four innovation clusters?


b. What are the specific research gaps, regulatory barriers, or other hurdles that need to be addressed to enable eventual application, or further application, of the innovation solution proposed from each of the four innovation clusters?

The "clusters" they care about are as follows:

Genome Design—Utilization of genomics and precision breeding to explore, control, and improve traits of agriculturally important organisms.

Digital/Automation—Deployment of precise, accurate and field-based sensors to collect information in real time in order to visualize changing conditions and respond automatically with interventions that reduce risk of losses and maximize productivity.

Prescriptive Intervention—Application and integration of data sciences, software tools, and systems models to enable advanced analytics for managing the food and agricultural system.

Systems Based Farm Management—Leverage a systems approach in order to understand the nature of interactions among different elements of the food and agricultural system to increase overall efficiency, resilience, and sustainability of farm enterprises.

George Yacus wrote:
The "clusters" they care about are as follows:

Genome Design—Utilization of genomics and precision breeding to explore, control, and improve traits of agriculturally important organisms.

Digital/Automation—Deployment of precise, accurate and field-based sensors to collect information in real time in order to visualize changing conditions and respond automatically with interventions that reduce risk of losses and maximize productivity.

Prescriptive Intervention—Application and integration of data sciences, software tools, and systems models to enable advanced analytics for managing the food and agricultural system.

Systems Based Farm Management—Leverage a systems approach in order to understand the nature of interactions among different elements of the food and agricultural system to increase overall efficiency, resilience, and sustainability of farm enterprises.

Genomics and precision breeding? Looks like we are going to have to address loss of genetic diversity. Is this cluster even compatible at all with permaculture values? If you can think of a way, you are more clever than I in that regard. This is definitely a place where out of the box thinking would, at first glance, appear unwelcome.

Jason Hernandez wrote:

Genomics and precision breeding? Looks like we are going to have to address loss of genetic diversity. Is this cluster even compatible at all with permaculture values? If you can think of a way, you are more clever than I in that regard. This is definitely a place where out of the box thinking would, at first glance, appear unwelcome.

This is where phrasing one's response can make a huge difference. There are permacultural designers who are using camera drones to get accurate to the foot topo maps of properties and another that I know personally who's using moisture sensors to evaluate whether key line plowing is effective in our ecosystem (there's good research in Australia, but none where I live). So responses can focus on positive permaculture uses of automation and suggested responses can also be permaculture based, particularly in situations where we're trying to get industrial farmers to shift their focus to less industrial systems, while still enabling them to make enough money to pay their mortgage.

"Systems Based Farm Management" can totally be re-focused on permaculture "interactions".

Yes, "Genome Design" is too scary for words from what it's been used for so far, but so has the current model of plant breeding which involves extreme treatment of plants and seeds in an effort to force genetic changes. Simply advocating for genetic diversity and farm-based seed production in an effort to meet the needs of "resilience and sustainability" gets the message across that many of us value that over genome design. They're asking for our opinion - let's politely give it to them with reasonable rationals for them to ponder.