ADMC responds to the NRCS request for public input on how to spend Inflation Reduction Act funds

The Natural Resources Conservation Service (NRCS) recently requested public input on how the NRCS should implement funding that will be received under the Inflation Reduction Act (IRA). The Agricultural Drainage Management Coalition responded to the request to advocate for the inclusion of drainage and water management practices as well as for the use of private technical service providers (ADMC’s full response). The IRA funding is intended for climate-smart practices that are eligible for funding through four Farm Bill conservation programs.

Funding levels are set to increase in Federal Year 2023 and will build over 4 years. The total funding increase in Farm Bill program and administrative costs are:

  • Environmental Quality Incentives Program – $8.45 billion
  • Conservation Stewardship Program – $ 3.25 billion
  • Regional Conservation Partnership Program – $4.95 billion
  • Agricultural Conservation Easement Program – $1.4 billion
  • Conservation Technical Assistance — $1 billion
  • Greenhouse Gas (GHG) Monitoring – $300 million
  • Administrative costs – $100 million

ADMC’s Response to Select Questions from the NRCS’s List in the Federal Registrar

What systems of quantification should NRCS use to measure the carbon sequestration and carbon dioxide, methane, and nitrous oxide emissions outcomes associated with activities funded through IRA?

Work by Iowa State University utilized the Agricultural Production Systems Simulator (APSIM) process-based model for continuous corn and corn-soybean cropping systems across 18 weather-years to capture interannual variability. From this, the project team was able to identify the average annual agronomic optimum fertilizer rates in drained and un-drained systems. Model outputs and subsequent literature review allowed the project team to calculate the major sources of GHG emissions in drained and undrained soils. ADMC recommends expanding the use of the APSIM model in different regions and directly test for the effect of drainage intensity on crops response to N fertilizer.

How can NRCS engage the private sector and private philanthropy to leverage the IRA investments, including for systems of quantification?

Actively promote and support the use of quality private sector technical assistance working in complementary ways with the public sector, and in coordination with state agricultural conservation agencies and the local leadership of soil and water conservation districts.

  • Use certified Technical Service Providers to address specialized technical needs more effectively in a timely manner, including the engineering services needed to plan, design, and assist the implementation of conservation drainage practices and systems.
  • Use all available administrative tools to facilitate timely assistance from Technical Service Providers for producers, including streamlined producer programmatic contracts and NRCS’s direct procurement of these specialized technical services through cooperative agreements, grants, and contracts.
  • Establish transparent NRCS set pricing for the services of Technical Service Providers that is fair and based on their full cost; compete NRCS-funded agreements, grants, and contracts based on the demonstrated performance, quality of work, and timeliness of these Technical Service Providers and not the pricing of these technical service to establish a “level playing†for all qualified Providers
  • Establish a stronger and sustained connection between regenerative soil health and water management practices as they operate in an equilibrium and not as separate unique system.
  • Engage more qualified organizations to be deemed “partners†of the NRCS to utilize the partner’s ability to reduce the transactional cost of the NRCS to implement IRA funded projects.
  • Ensure that soil water management and conservation drainage is an integrated and priority emphasis for the use of IRA funding through conservation practices and systems that produce multiple benefits – – climate change mitigation, adaptation, and resilience; water quality improvement; downstream flood reduction; improved soil health; and, increased crop yields.
  • Ensure that educational and promotional efforts are geared to establish the critical role of soil water management in all working lands conservation efforts – – conservation objectives can only be achieved and results optimized through science-based practical management of the soil water regime.

How should NRCS target IRA funding to maximize improvements to soil carbon, reductions in nitrogen losses, and the reduction, capture, avoidance, or sequestration of carbon dioxide, methane, or nitrous oxide emissions, associated with agricultural production?

  • Use IRA funding to build momentum for conservation drainage practice/systems adoption that is focused on priority watersheds and landscapes where benefits can be optimized with minimal transaction costs and burden on producers.
  • Ensure focused IRA funding in priority watersheds and landscapes does not diminish base-level support for broad-based, ongoing locally-led conservation efforts.
  • Simplify requirements and streamline processes for NRCS financial assistance for farmers to enable the implementation of conservation drainage practices and systems in a more efficient and timely manner.

How should NRCS streamline and improve program delivery to increase efficiencies and expand access to IRA funded programs and projects for producers, particularly underserved producers?

  • Ensure that programmatic approaches are public/private partnership based, centered on collaboration where partners contribute commensurate with their capabilities and capacities, and include key roles and opportunities for both the public and private sectors that are complementary and capitalize on each sector’s respective attributes and strengths.
  • Reduce the barriers to the adoption of conservation practices and systems through innovations in delivery approaches, such as the successful “turn key†project approach employed in Minnesota by NRCS with Ecosystem Services Exchange, LLC and the “batch and build†project approach in Iowa between the Iowa Department of Agriculture and Land Stewardship and ADMC.
    • Fund and actively support more widespread use of the “turn key†project approach with qualified Technical Service Providers that can do the complete job for NRCS – – from site assessment and planning, through design and implementation, and inclusive of contracting with both the producer and the land improvement/drainage contractor.
    • Fund and actively support more widespread use of the “batch and build†project approach with state conservation agencies and other qualified entities to focus on key conservation drainage practices in a geographic and accelerate their implementation in a streamlined manner.
  • Seek out and proactively support pilot innovative approaches to accelerate farmer adoption of site-specific conservation systems that reduce administrative burden both producers and partners and are timely.

How can NRCS expand capacity among partners to assist in providing outreach and technical assistance to support implementation of IRA funding?

  • Support the development and use of practicable science-based decision-support tools to aid producer education and their sound management of implemented conservation drainage practices and systems.
  • Support focused education about and marketing of conservation systems that produce multiple benefits on a coordinated and sustained basis, such as automated drainage water management applied in combination with edge-of-field and agronomic/vegetative/cultural practices on the soil surface.

Coordinated public/private action in support of working lands decision makers and a practical site-specific conservation systems approach must be central to NRCS’s deployment of IRA funding for climate change mitigation, adaptation, and resilience.  For the roughly 60 million acres of U.S cropland that have pattern tile-drainage, conservation drainage must be part of the conservation systems approach that farmers voluntarily plan, implement, and manage.  Producers, communities, and the public can only realize optimized environmental, production, and economic benefits, including GHG reductions and adapted crop production that is resilient to climate change, through a conservation systems approach that includes keen attention to water management.  The strategic use of IRA funding affords NRCS a unique opportunity to help ensure water management in ag production is central to all conservation decisions on working lands, thereby optimizing multiple environmental and production benefits.