Racial Equity: Comments to U.S. Department of Agriculture

​In June 2021, the U.S. Department of Agriculture opened a public comment period to receive input on Executive Order 13985: "Identifying Barriers in USDA Programs and Services; Advancing Racial Justice and Equity and Support for Underserved Communities at USDA."

On August 14, 2021, Agriculture Secretary Russell Redding submitted the below comments to Secretary Tom Vilsack:

On behalf of the Pennsylvania Department of Agriculture, we thank the United States Department of Agriculture (USDA) for the opportunity to respond to the request for comment on how the USDA can the advance racial justice and equity for underserved communities. This continues to be a top priority at the Pennsylvania Department of Agriculture (PDA) as we look to improve diversity, equity, and inclusion both internally and externally. Agriculture is the largest economic enterprise in Pennsylvania, making it critical that we, along with our federal partners, ensure that our programs and outreach are equitable and culturally competent. We hope that our comments can enhance and expand the valuable services that USDA provides to agricultural stakeholders across the country.

Section: General Questions

Did you experience problems with required USDA paperwork, the USDA internet sites, the attitudes of USDA workers, or the locations of USDA offices?

• The 15 to 30 day time allotted for comments or request for information can be challenging, especially for first time applicants.
• USDA should establish Farm Services Agency offices or some kind of USDA-liaison office within major urban centers to provide outreach and support to urban farmers and growers. Even when a USDA office exists in neighboring counties, urban growers within the urban center may not be aware those offices exists or have the ability to reach those offices easily due to lack of public transportation to those areas outside the city.
  

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?

• We Recommend creating a policy fellowship at USDA agencies in partnership with Historically Black Colleges and Universities, Historically Hispanic Serving Institutions (HSI), diverse affinity groups like the Minorities in Agriculture, Natural Resources, and Related Sciences (MANRRS), and other historically underserved communities to provide direct access and placement in leadership positions.
• USDA can partner with state commissions and departments in this effort whenever possible, including building relationships and facilitating connections.
• There are very few BIPOC Certified Agricultural Educators. USDA should develop supporting programs to encourage and increase the number of BIPOC Certified Agricultural Educators. Students interested in agricultural careers, especially in urban centers, can better connect and engage with educators who have similar backgrounds and experiences. This is another area in which BIPOC communities have been excluded from due to socio-economic and institutional racism.
  

Please describe USDA programs or interactions that have worked well for underserved communities. What successful approaches to advancing justice and equity have been undertaken by USDA that you recommend be used as a model for other programs or areas?

• The webinars provided by USDA to explain the individual grant application process is helpful, but it can be challenging to find the webinars and navigate the federal website, even if a prospective applicant knows about the grant opportunity. Better promotion of the grant opportunities and clear online pathways to find grant opportunities and archived webinars would be helpful, as well as including translation options and diverse sign language interpreters to increase accessibility of the webinars.
  

• USDA can continue to increase the diversity of its boards and commissions.
• USDA can connect with national affinity organizations to share information about its programs and explore new opportunities for partnerships.
  

Have you made recommendations for improvement in the past to USDA? If so, please list or attach those recommendations.

• The PA Department of Agriculture submitted comments for the interim and final hemp rules that encouraged USDA to work with Congress to pass legislation to lower the 10-year ban on participation in the hemp industry if a participant has been convicted of felony drug-related charges. We believe this is an unfair burden to prospective growers and that it has a disproportionate impact on communities of color. The interim final rule does not regulate processing of hemp, and the fact that the drug-related conviction ban only applies to prospective growers further exemplifies the inequity of this provision.
• The PA Department of Agriculture provided USDA its COVID-19 Fresh Food Financing Initiative program guidelines as a recommended model for spending additional American Rescue Plan dollars. The program prioritized Black, Indigenous, and Person of Color (BIPOC) owned businesses and those businesses that serve BIPOC communities. The program was very popular and oversubscribed in Pennsylvania in 2020, so we believe it could be a model implemented at the federal level or delegated to the states to implement.
• In 2020, the PA Department of Agriculture advocated to the Pennsylvania Congressional delegation that Congress should ensure the prioritization of new and beginning farmers, farmers of color, veteran farmers, and small and diverse businesses to require they equitable access to federal programs and resources in stimulus programs and COVID-19 recovery efforts. We encourage USDA to continue to work toward these goals in all of their programs.
  

The PA Department of Agriculture supports USDA's efforts to evaluate and improve access for underserved producers and communities. We are happy to answer any questions you might have and are eager to assist USDA in these efforts.

View the full letter: Federal Advocacy, USDA Racial Equity