NAMA Submits Comments to USDA On Climate-Smart Agriculture, Buy American

November 3, 2021 – This week, the North American Millers’ Association submitted public comments to the U.S. Department of Agriculture on two different topics of importance to the milling industry.

Climate-Smart Agriculture and Forestry Partnership Program

Federal Register Notice 

Click here to download NAMA’s full comments.

Key points:

• Standardization through the involvement of USDA is integral to the success of low carbon commodities and carbon market credits because it will improve integrity within the marketplace and address the current uncertainty facing both private companies and farmers. 
• USDA should develop a set of standards for any voluntary carbon markets so that all those involved are meeting the same objectives and know what benefits will accrue to which practices. 
• Millers support activities that test and evaluate standardized protocols that define eligible climate-smart agriculture practices, quantification methodologies, and verification practices, with an emphasis on minimizing transaction costs and operating at scale, which is imperative for our members. 
• Future USDA climate-smart programs should be  structured in a way that many different organizations, grower groups, research institutions, and individual farmers have the ability to apply.
• Millers believe USDA should not establish a single payment per ton of GHG generated through partnership projects as part of the project payment structure. Instead, USDA should evaluate a range of incentive options so that producers are not inherently disincentivized from growing small grains. As grain processors, we are concerned that certain practices, if adopted, may inadvertently negatively impact the production and functionality of the grain. 
• It would be helpful for producers and processors to have closer partnerships with USDA to achieve a better understanding of how climate-smart practices would impact their commodities, including through USDA research programs.

Request for Information: Buy American in the National School Lunch Program and School Breakfast Program

Federal Register Notice 

Click here to download NAMA’s full comments.

Key points:

• Current Buy American exceptions in the National School Lunch Program and School Breakfast Program allow for real-world flexibilities that reflect the reality that U.S. grain millers face while delivering highly nutritious foods to American consumers. Because of the unique issues faced by U.S. millers, it is vital that these exceptions remain in place. 
• Over ninety percent of the oats milled in the U.S. are currently grown in Canada. While U.S. millers source American grown oats, the reality is that oat acres have been on a steady decline and oats harvested in the U.S. do not satisfy the U.S. consumer demand. Keeping the application of the rules consistent with what they have been over the past decade is critical to ensuring oat based products, found in everyday cereals, oatmeal, and breakfast bars continue to be a foundational component of the school breakfast program.
• In some cases, particularly in the northern states bordering Canada, U.S. millers may use Canadian wheat in order to meet consumer demand in a cost-effective manner (just as Canadian millers may do the same with U.S. wheat). This cross-border trade is fluid throughout the year and would be difficult to capture in a snapshot of one specific food product. Additionally, there are questions as to how ingredients in a product would be weighted. 
• Inclusion of grains in the diet of children is important as we as a nation provide more grain based solutions to customers and consumers. The option of transportation and origin of grain should not be an obstacle to that goal.
• Millers recognize the importance of Buy American provisions and are eager to meet those provisions whenever possible, while recognizing the importance of exceptions so as to not create barriers between healthy foods and U.S. students.

About NAMA:

NAMA is the only national trade association that exclusively represents the interests of the North American wheat, corn, oat, and rye milling industry before Congress, federal agencies, and international regulatory bodies. Member companies operate mills in 31 states, Puerto Rico, and Canada, representing more than 90 percent of total industry production capacity.