July 15, 2021

Elizabeth C. Archuleta
Director, Office of Intergovernmental & External Affairs
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250

Re: Identifying Barriers in USDA Programs and Services; Advancing Racial Justice and Equity and Support for Underserved Communities at USDA; Docket ID FSA- 2021-0006

Submitted electronically

Dear Ms. Archuleta,

The Northeast Organic Farming Association Interstate Council (NOFA-IC) appreciates the opportunity to comment on barriers to participation in USDA programs and services. We believe that we will never achieve a system of food and farming worth sustaining until we dismantle systemic racism and put an end to white supremacy.

The Northeast Organic Farming Association Interstate Council (NOFA-IC), is dedicated to organic farming and to the principles of ecology, health, care, and fairness on which it is based. The NOFA-IC has been coordinating the seven state chapters of NOFA since the 1980’s when NOFA expanded from its beginnings in Vermont and New Hampshire in 1971 to encompass seven state chapters with over 5000 members, most of them organic farmers and homesteaders.

The NOFA-IC is a member of the National Organic Coalition (NOC) and we support the comments submitted by NOC on Advancing Racial Justice and Equity and Support for Underserved Communities at USDA.

NOFA also shares NOC’s concern about the short length of time for public comment on this critically important topic, especially during the short northern growing season.  USDA should extend the comment period for this important topic, and also consider providing an open docket on this topic so groups and individuals can provide input to USDA in an ongoing way.

NOFA-IC will add a few points to the NOC comments that come from our experience in the seven states where there are NOFA chapters (CT, MA, NJ, NH, NY, RI and VT.)

The 2017 Ag Census data shows that people of color are underrepresented in farming, including organic farming. The northeast states are no exception. According to 2017 ag census data, although organic farmers are very slightly “more diverse” than conventional farmers (94% of conventional farmers and, 92% of organic farmers identify as white), fewer than 1% of organic farmers identified as Black or African American, and 0.5% identified as American Indian or Alaska Native.[1] However, in the NOFA states, we are experiencing a vibrant expansion of urban agriculture and many of the urban farms are managed by people of color.  Almost every one of these urban farms and community gardens uses organic or agroecological methods, though hardly any are certified organic with the National Organic Program.  In some cases, these methods have been learned from NOP certified organic farms, but often, urban farmers of color are using techniques learned from their family traditions.  The indigenous agriculture of many cultures is grounded in natural practices, the millennial learning of peasant farmers. Thus, USDA programs that support the development of urban agriculture, such as NRCS funding of hoop houses for urban farms, are supporting agroecological practices.  Training for USDA county and state staff should include these indigenous traditions.

General Questions

  1. Are there USDA policies, practices, or programs that perpetuate systemic barriers to opportunities and benefits for people of color or other underserved groups? How can those programs be modified, expanded, or made less complicated or streamlined, to deliver resources and benefits more equitably?

In the seven NOFA states, access to land, resources, and technical assistance are some of the main barriers to participation in farming, both urban and rural, for Black, Indigenous, and other people of color (BIPOC) farmers.  USDA will need to address these multiple barriers to enable more BIPOC farms to access the resources they need and to create a more diverse, robust, and inclusive organic program and farming population.

Access to Land

Policy initiatives to help address the land-access limitations in the organic sector should include:

  • Expansion of the Agricultural Conservation Easement Program (ACEP) to include a prioritization for conservation of land that has been managed organically and BIPOC-owned land;
  • Creation of a federal land-link program to connect retiring organic landowners with young or beginning farmers who are seeking organic land but cannot afford it. This program should also include legal resources, such as model leases, on how to structure enforceable lease and lease-to-own agreements to respect the unique needs of both retiring and new organic farmers. These legal resources should include options for new and transitioning organic farmers to purchase land at agricultural value (OPAV), after the development rights on the property are donated or sold, to reduce the cost of purchasing the land.
  • Expansion of FSA grant and loan guarantee programs (such as the Highly Fractionated Indian Land Loan Program and Indian Tribal Land Acquisition Loan Program) for land acquisition for beginning and socially disadvantaged farmers under sustainable agriculture covenants.
  • Establishment of lending guidelines for the Small Business Administration (SBA) and private loans to low-income resident farmers and BIPOC-led farmer cooperatives[2].
  • Appointment of a USDA-led “land commission” to conduct a periodic national-scale land tenure study to provide a holistic perspective on socio-economic, political, and market-based factors limiting BIPOC access to land.5
  • For many BIPOC farmers, moving to predominately white rural areas raises concerns about social isolation, acceptance and safety. In this regard, cooperative models of land ownership can be one approach for groups of BIPOC farmers to overcome these barriers as a group. These models should be recognized by USDA as viable alternatives to individual land ownership and prioritized for support.


Expanding cost share assistance for organic certification, particularly for small-and-medium-scale farms

In addition to restoring the reimbursement rates for Organic Certification Cost Share Program (OCCSP) for Fiscal Years 2020 and 2021, NOFA requests that, starting in Fiscal Year 2022, USDA:

  1. Increase reimbursement rates to $1000 annually per certification scope per operation.
  2. Provide reimbursement of 100 percent of annual certification costs up to $1000 per scope per operation. The assistance should be restricted to small-and-medium scale operations only.
  3. Streamline and simplify the reimbursement process, by having reimbursements go directly to organic certifiers to reduce certification fees, as opposed to reimbursing organic operations for the annual certification fees they pay to certifiers. For this approach to be effective, these reimbursements must be disbursed to certifiers in a timely fashion, so certifiers do not face cash flow issues. This change will result in a more-timely reduction in certification cost burdens to organic operations, and reduce paperwork burden on these operations. This is important for addressing barriers to certification for small farmers, underserved operations, and BIPOC farmers since the upfront, additional costs of certification are a barrier for these operations.
  4. Permanently expand the cost share program to reimburse technical assistance fees paid by farmers transitioning to organic, prior to full certification. Organizations that can competently provide technical services to producers transitioning to organic should be compensated through the cost share program, with priority given to organizations serving BIPOC producers.


Creation of a Farmer-to-Farmer Mentorship Program for Farmers Transitioning to Organic

Farmers looking to move toward increased sustainability face difficult challenges during the 3-year transition period prior to certification, during which time the farmer incurs the higher production costs of organic without receiving the benefit of organic premiums.

To help address this tenuous period, funding should be authorized to create National Organic Program (NOP)-accredited mentorship programs to assist farmers during the transition period.  Under this program, both the mentor farmer and the transitioning farmer would be eligible for a stipend of up to $5,000 annually to facilitate the process. These farmer-to-farmer mentoring programs would help new farmers understand organic practices and encourage their success.  Producers just beginning their transition process will be paired with an experienced certified organic producer who operates an operation similar to that of the transitioning farmer or rancher. For farmers of color, it is especially effective when mentors are culturally appropriate.

Not for profits like the NOFA chapters, State Departments of Agriculture, or universities can coordinate mentorship programs, and USDA grants should be provided to help with the costs of administering the programs. Priority should be given to organizations and programs that provide mentorship to Black, Indigenous and other People of Color (BIPOC) farmers and historically underserved producers.

Transitioning to organic requires the development of an entirely new set of skills and knowledge, and the mentors who can best share that knowledge are the farmers and ranchers who have already gone through the transition process.[3] In some cases, mentorship should also include mentors with experience in business development and marketing, since that is also a critical skill set needed by many organic farmers. Therefore, mentorship to help transitioning farmers understand marketing options for their products should be an allowable activity under this program as well.


Training for Organic Professionals and USDA Staff

The organic program is a public-private partnership. It is a voluntary program overseen by third-party private certification agencies in combination with government oversight from the USDA’s National Organic Program, which accredits organic certifying agents and develops the rules & regulations for the production, handling, labeling, and enforcement of all USDA organic products.

For farmers who are seeking organic certification, often their first point of contact is with a certifying agent and an organic inspector, who is responsible for conducting the annual on sight inspection of the farm or handling operation that is mandatory to be eligible for organic certification.

Staff, board members and other members of the NOFA chapters are engaging in training in diversity, equity, and inclusion, but more training is needed focused on understanding the legacy and history of race in American economic and policy development and in the food and agriculture system specifically, along with an understanding of how institutions and systems produce unjust and inequitable outcomes. USDA should provide training for USDA staff, but also should help facilitate the efforts already initiated by organic community members to provide training and professional development to organic professionals given the public-private partnership that is at the foundation of the organic program. This training should be focused on the ways in which systemic racism and USDA’s discriminatory programs and policies have impacted access to organic certification. The training should also include a discussion about how to break down barriers to increase participation in organic certification by BIPOC farmers, build a more inclusive organic community, and develop a more equitable organic program.

  1. How can USDA establish and maintain connections to a wider and more diverse set of stakeholders representing underserved communities?

NOFA endorses the NOC  request that USDA ensure adequate training among FSA and NRCS staff at the state and county levels regarding existing opportunities to support historically underserved producers, landowners, and communities. FSA and NRCS should recruit and hire more BIPOC individuals to serve as FSA and NRCS agents, and can build a pipeline by partnering with 1890 Land Grant Universities and offering internships that may lead to employment opportunities. It is critical that FSA and NRCS staff, including BIPOC staff, undergo literacy training with regards to organic standards and production methods. NOFA also recommends that USDA allow producers to be served by a USDA service center that has trained staff who can best serve the needs of organic and BIPOC producers, including staff who can provide services to producers in other languages, even if that service center is not the closest office.

  1. What suggestions do you have for how USDA can effectively assess and measure its outreach and inclusion of underserved groups and individuals?

The NASS survey of organic farmers only goes to certified organic farms. NASS should make sure to include urban farms in the next full census of agriculture. Questions should be added to the census to find out what practices BIPOC farmers are using, what kinds of training they believe would strengthen their farms and what resources would increase access to farming for people of color.

  1. How can USDA remove or reduce barriers that underserved communities and individuals face when they participate or attempt to participate in agency procurement and contracting opportunities?

NOFA urges a significant increase in the procurement of organic products and products from BIPOC farms in the National School Lunch program, the Commodity Supplemental Food Program, The Emergency Food Assistance Program (TEFAP), and Food Distribution Program on Indian Reservations (FDPIR).

Offering organic food through federal nutrition programs, including the National School Lunch program and for purchase through the Women Infants and Children (WIC) program is important for reducing exposure to pesticides for vulnerable populations.

USDA has a long history of supporting specific producers and commodities through federal procurement programs – future procurement should allocate funding to benefit organic operations, with preference given to BIPOC producers and producers who are increasing access to nutritious food for underserved communities.

Thank you for this opportunity to provide comments on this important topic.


Elizabeth Henderson

Co-chair Policy Committee of the Natural Organic Farming Association Interstate Council

[1] 2017 Census of Agriculture: Characteristics of All Farms and Farms with Organic Sales, April 2019, United States Department of Agriculture, National Agricultural Statistical Service


[2] [2]Soul Fire Farm & Northeast Farmers of Color alliance – Food Sovereignty Action Steps (2018) http://docs.google.com/document/d/1dt0hicyhGdJSKlC3qyE1AbG9fdDrONjUh_M_bE0KMGs/edit#bookmark=id.rji88dqczea2

[3] Based on a broader proposal from National Sustainable Agriculture Coalition during 2018 Farm Bill process.