Editor’s Note: This is the second post in a multi-part blog series analyzing the Farm, Food, and National Security Act of 2024, which was reported out of the House Agriculture Committee on Friday, May 24. The first post provides an overview of the markup process and the bill as a whole, as well as its likely (or unlikely) path to becoming law. This post explores the FFNSA’s impacts on local and regional food systems. Subsequent posts provide a deep dive analysis of the bill’s potential impacts on farmers’ access to land and capital, beginning and other underserved producers, conservation and climate resilience, and sustainable and organic research, among other issues.
The Farm, Food, and National Security Act of 2024 (FFNSA, HR 8467) offers a number of policy reforms and authorizes new programs that seek to strengthen existing programs and sustain the novel United States Department of Agriculture’s local supply chain initiatives. The bill under-delivers, in part, by not targeting initiatives to the small and small and mid-scale operations that are the foundation of local food supply chains. At the same time, it significantly underfunds certain programs, and in some instances, the bill does both of these things at the same time. As a result, NSAC is concerned that many of the new investments included in the House bill will disproportionately benefit large operations and distributors or hamstring the impact of new programs due to insufficient funding.
The following analysis is separated into sections addressing local and regional market access and development, supply chain infrastructure and support, and food access:
- Market Access and Development
- Supply Chain Infrastructure and Support
- Food Access
Local Food: Market Access and Development
Since the COVID-19 pandemic, Congress has initiated numerous novel food supply chain initiatives through the CARES Act and the ARP Act that bolstered markets and spurred new local opportunities for small-scale operations. By original design, funding for many of these programs is likely to end soon, unless a new farm bill continues and enhances these strategic investments. The farm bill has a longstanding history of supporting local market development through programs such as the Value-Added Producer Grants and Farmers Market and Local Food Promotion Grants, yet any new farm bill must incorporate lessons learned from COVID-era programs into both well-established and new federal programs to better sustain these catalytic market investments.
Food Box Pilot Program
The FFNSA insufficiently promotes new and emerging markets and fails to support smaller-scale farmers in accessing federal markets. Rather than identifying a permanent funding source for the new but already influential market development program – the Local Food Purchase Assistance Program – the bill authorizes a Food Box Pilot Program (Sec. 4302) that:
- Directs USDA’s Agricultural Marketing Service to contract with no more than 20 entities to carry out a food box program that provides staple foods to food insecure households,
- Seeks to complement existing federal nutrition programs, increase the capacity of community and faith-based organizations, and support local and regional food systems,
- Considers a range of criteria when selecting contracts, including whether they have demonstrated partnership networks, experience or commitment sourcing from small and medium-scale farmers, and source local and regional products, when seasonally available or at a reasonable price, and
- Includes a total of $200 million of mandatory funding.
While there are elements of the Food Box Pilot Program that theoretically support new local markets, there is a track record of a similar program design leading to limited purchases from small, mid-sized farms and farmers of color, inadequately serving the most food insecure communities, and contracting with a few distributors that concentrated funding with few, large companies.
Food Safety Outreach Program
Investments in food safety education and equipment or training are essential to meeting ever-evolving market and regulatory food safety requirements. Without sufficient investments, these food safety requirements can prevent many smaller-scale producers from entering new markets. The FFNSA reauthorizes some of the programs that provide these investments – such as the Food Safety Outreach Program (FSOP). FSOP, which funds education on a variety of food safety topics, includes an intentional focus on reaching underserved communities of producers. However, FFNSA misses the opportunity to increase funding levels for FSOP, a crucial misstep especially given the array of food safety regulations increasingly impacting smaller producers. (Sec. 7301).
Federal Procurement
The farm bill offers an opportunity to address some of these barriers to enter federal markets, such as USDA’s Commodity Program. The EFFECTIVE Food Procurement Act (HR 6569) created a pathway for this but was not included in FFNSA. However, the bill does direct USDA to study the barriers farmers and enterprises that produce culturally appropriate food experience when trying to compete for federal commodity contracts and make recommendations on how to improve the process (Sec. 10107).
Local Agriculture Market Program
Despite the significant impact of and demand for the Local Agriculture Market Program (LAMP), the FFNSA does not offer an increase in appropriations or mandatory funding levels for the program. However, the bill offers program reforms that will generate new demand including a number of provisions from the Local Farms and Food Act (H.R. 2723) to expand access to LAMP funds by reaching food hubs and creating a simplified application and reporting process for projects of less than $100,000 (Section 10102). Unfortunately, the combined effect of the FFNSA will likely create more demand for LAMP while failing to provide sufficient funding to address that demand.
Cooperative Interstate Shipment Program
Meat and poultry processing is a closely regulated industry. Yet, for decades, geographic and funding limitations have frequently prevented Food Safety and Inspection Service (FSIS) personnel from providing food safety education before regulation. These same limitations have also made it challenging for FSIS to cost-effectively regulate smaller processors in many states. As a result, Congress created the Cooperative Interstate Shipment Program (CIS) in the Food Conservation, and Energy Act of 2008 (2008 Farm Bill) to enable products processed at state-inspected plants to be sold interstate if the state has a Meat and Poultry Inspection program equivalent to the federal inspection program.
CIS has expanded markets and opportunities and encouraged the creation of new products in the small plants it serves. Over time, however, it has become evident that the CIS program needs an expansion of scope and funding to serve more small and very small meat processors. The bipartisan Strengthening Local Processing Act (SLPA, HR 945) includes changes to the federal and state regulatory authorities’ cost-share model, which could alter the cost-benefit analysis for states that have their own meat and poultry inspection programs, ultimately making for more effective regulation of small and very small meat processors. Those plants will then be able to work more effectively with the small and diversified farms that are an essential component of a sustainable and equitable food system.
Unfortunately, the FFNSA declines to make any changes to the CIS program structure, instead promoting outreach about the program and requiring a report on that outreach each year (Sec 12113). While we support more effective promotion of the CIS program, the failure to include many of the necessary structural and funding changes means that the FFNSA misses a critical opportunity to expand markets for smaller processors, increase competition in the industry, and help bring more nutritious, locally, and often sustainably raised animal products to market. The FFNSA requires that FSIS provide more publicly available food safety resources designed for small and very small meat processors, which we support. Of specific importance is making more validation studies publicly available, which small processors can use to substantiate scale -appropriate food safety control techniques. (Sec. 12112).
Local Food: Supply Chains
USDA’s recent transformative food system initiative has focused on improvements across the supply chain, with investments in infrastructure, workforce development, value-chain coordination, and business technical assistance. The FFNSA offers a few new options for infrastructure investments but does not adequately respond to the needs of rural communities for specialized food workforce training and technical assistance for scaling businesses. Disproportionate investment along the supply chain can lead to supply without adequate markets for producers, or potentially new infrastructure for businesses without sufficient business planning to strategically scale.
Infrastructure
The FFNSA attempts to sustain some of the meat processing expansion programs that were created by ARPA, for example through a “new, mobile, and expanded meat processing and rendering grants” program (Sec. 6305). This section bears some but not enough resemblance to the original programs (MPPEP, Local MCap, MPIRG) that were developed in part based on the proposals in SLPA.
At only $3 million in authorized funding, the FFNSA’s Sec. 6305 grants are insufficiently funded relative to the demand across the US. Furthermore, the bill expands eligible applicants to include land grant universities, state departments of agriculture, and other organizations with existing capacities well beyond the small and very small meat processors for whom this program was intended. Instead of limiting these grants to small and very small processors, the FFNSA only includes it as a priority that the funding goes to small and very small processors. This, combined with the lack of a ‘socially disadvantaged’ priority means that the FFNSA-created grant program runs the risk of funneling money to processors that already have access to other financial instruments to expand capacity. This fails to meaningfully address the processing bottleneck that smaller-scale producers nationwide experience.
The FFNSA expands upon the existing business and industry guaranteed loan program by authorizing a permanent food supply chain guaranteed loan that seeks to support commercial food supply chains by financing projects focused on aggregation, processing, distribution, and manufacturing. Additionally, it caps the guarantee fee institutions pay to USDA to 3%, which has been cited as a barrier for a number of lenders. However, with no stated program goals or parameters for business scale or production type, this financial product is unlikely to support emerging food enterprises or small and mid-scale enterprises participating exclusively in regional food supply chains due to the rigorous underwriting standards associated with USDA guaranteed loans (Sec. 6304, 6412).
Finally, the bill codifies the recently implemented updates to LAMP’s program offerings by ensuring necessary special purpose equipment can be purchased (Sec. 10102).
Workforce Development
Small and very small processors – for whom jobs tend to be more cross functional than in their larger industry competitors – have struggled to recruit and maintain the highly skilled workforce they need. More funding and programs specifically created to support the unique needs of small and very small meat workforce development are important to increase growth in the sector.
Unfortunately, the FFNSA does not offer any new funding or new programs to meet the much needed investment in this sector. The bill does amend the USDA’s Agriculture and Food Research Initiative (AFRI) to include meat processing workforce development as an area of research. The bill also authorizes the creation of new community college grants oriented towards the development of a broader highly skilled agricultural workforce. While this may include meat processing training, it does not do so explicitly (Sec. 7123, 7503).
Value-chain Coordination and Technical Assistance
As recently highlighted, the people offering business technical assistance and coordinating activities along the supply chain can often be invisible but are nonetheless essential to operating efficient local food systems. Two of USDA’s most notable initiatives to support these activities are the Regional Food Business Centers and the Meat and Poultry Processing Capacity Technical Assistance program. Unfortunately, the FFNSA does not authorize either program.
Local Food: Access
A number of USDA programs aim to ensure high quality local foods are easily accessible to all individuals. Many of these programs do so by ensuring families can use their Supplemental Nutrition Assistance benefits (SNAP) in local food markets or by providing additional cash benefits for fruits and vegetables produced by local farmers.
The FFNSA provides new additional mandatory funding for several programs that increase the accessibility of local food within food insecure communities, including:
- $2 million annually for the Senior Farmers Market Nutrition Program,
- $5 million annually for the Community Food Project Program (CFP), and
- $19 million for the Gus Schumacher Nutrition Incentive Program (GusNIP).
Unfortunately, the increase for the Senior Farmers Market Nutrition Program is insufficient to fix the program’s persistent issue in which some states are allocated so little funding that they pass on the opportunity entirely due to the administrative burden of implementation. While this restores CFP to the higher funding levels it received before the Agriculture Improvement Act of 2018 (2018 Farm Bill), all of these increases will come at the expense of future increases to the Supplemental Nutrition Assistance Program.
Some changes in the FFNSA will likely lead to greater local food access in vulnerable communities. For example, the bill allows the Secretary of Agriculture to waive the GusNIP match requirement for persistent poverty counties (Section 4306). It also expands the responsibilities and improves the services of the Office of Urban Agriculture and Innovative Production (OUAIP) to improve upon the farmer networks supporting food insecure communities. The bill would also enable community experts to partner with USDA to better serve urban producers through cooperative agreements, and support farmer cooperatives and individual farmers through grants and subgrants, respectively (Section 10004). Yet, similar to the changes to LAMP, the House changes will generate increased demand without any increase or guarantee of funding. OUAIP has consistently been underfunded or forgotten in Appropriations Cycles. Therefore, these program improvements will likely be delayed without adequate funding.
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