Luke Brubaker, Member
Grant Gulibon, Alternate Member
Pennsylvania Climate Change Advisory Committee

Dec. 21, 2018

On behalf of the Pennsylvania Farm Bureau (PFB), we offer the following comments on the draft Pennsylvania Climate Action Plan (CAP), prepared for the Pennsylvania Department of Environmental Protection (DEP) by ICF. PFB is a general farm organization, made up of more than 62,000 members. Since 1950, PFB has provided support, advocacy and informational and professional services for Pennsylvania agriculture and farm families. Our comments are focused first on the sections of the draft plan specifically related to agriculture, and then pivot to address the draft plan in general.

Comments on Agricultural Strategies in the Draft Plan

First, several of the draft plan’s primary recommendations directly regarding agriculture—under the broad aegis of “using agricultural best practices” and “providing resources and technical assistance for farmers to adapt”—are generally in line with strategies that many Pennsylvania farmers are already utilizing. For example, providing financial incentives and support for agricultural best practices (if properly crafted to ensure meaningful compensation to farmers for planting crops or adopting farming practices that keep carbon in the soil or plant material) will build upon current successful conservation initiatives, such as the implementation of no-till farming practices. However, the draft plan’s recommendation of requiring mandatory compliance with PA DEP’s Stormwater Best Management Practices Manual is problematic, as doing so may deny Pennsylvania farmers the opportunity to cost-effectively deploy the mix of conservation options that best suit their operations.

At the same time, increasing the use and recovery of gas from agriculture will aid farmers engaged in more intensive farming operations to manage adverse environmental effects and legally meet the increased water and air quality standards imposed on more intensive agricultural practices while also providing the opportunity to offset costs or generate revenue. Energy conservation and renewable energy generation such as digesters for methane capture and recovery, energy efficiency, and the production and use of renewable energy (e.g., biofuels, solar, wind) are current examples of integrated farm management strategies that are working for Pennsylvania farmers.

PFB would also like to comment specifically on Pennsylvania’s agricultural community’s utilization of solar energy systems. In Pennsylvania, solar energy systems are very often operated on more concentrated farming operations, and are developed and operated as an integral part of the farm’s plan to meet the environmental standards imposed under state and federal law. At the same time, it is important to note that farmers must incur high input and operation costs to viably engage their farms in agricultural production, and development and maintenance of solar energy systems can require farmers to make significant capital outlays and incur debt.