Environmental Services Markets in the 2008 Fram Bill
Environmental Services Markets
in the 2008 Farm Bill
Updated June 10, 2008
Specialist in Agricultural Policy
Resources, Science, and Industry Division
Environmental Services Markets
in the 2008 Farm Bill
Environmental goods and services are the benefits society obtains from the
environment and ecosystems, both natural and managed, such as water filtration,
flood control, provision of habitat, carbon storage, and many others. Farmer
participation in providing these types of goods and services began in earnest in the
1990s with the development of watershed approaches incorporating nutrient credit
trading and wetlands mitigation banking, as well as the more recent development of
voluntary carbon credit markets. These efforts have triggered further interest in the
possibility of developing market and trading opportunities for farmers and
landowners as a source of environmental offsets. These services would be in
addition to the food and fiber services traditionally supplied by the agriculture and
forestry sectors. Congress is expressing growing interest in developing such market-
based approaches to complement existing federally supported programs that promote
conservation in the farm and forestry sectors, as well as to complement existing
and/or emerging environmental regulations or natural resource requirements that may
affect the agriculture and forestry sectors.
The enacted 2008 farm bill (P.L. 110-234, the Food, Conservation, and Energy
Act of 2008) contains a new conservation provision that seeks to facilitate the
participation of farmers and landowners in environmental services markets by
directing USDA to develop technical guidelines for measuring farm- and forestry-
based environmental services. This provision focuses first on carbon storage and
indirectly references various agriculture and forestry provisions in some legislative
initiatives that are being considered as part of the broader climate change debate,
which have highlighted the perceived need for uniform standards and ways of
measuring emissions reduction and increases in carbon storage in the agriculture and
forestry sectors. These types of provisions could expand the scope of existing land-
based conservation programs and facilitate the development of private-sector markets
for a range of environmental goods and services from farmers and landowners.
Among the possible questions that may emerge as these agriculture and forestry
provisions are either implemented as part of U.S. farm conservation policy, or
considered as part of a broader climate change initiative, are the following: Can
agricultural interests effectively provide environmental services along with traditional
food and forestry services? How would uniform standards address differences within
different production areas, types of resources, and ecosystems? What is the role of
USDA as the lead federal agency in establishing technical guidelines for the
agriculture and forestry sectors? How would collaboration work between other
participating federal agencies? How would the agreed-upon decisions and standards
work within existing regulatory authorities? How would the agreed-upon decisions
and standards work within possible forthcoming regulatory authorities, such as in
proposed climate change options currently being debated in Congress? What role
should federal agencies play in establishing environmental services markets?
What Are Environmental Services Markets?.............................1
What Are the Benefits and Barriers?...................................4
What Is the Recent Congressional Action?..............................5
Farm Bill Legislation...........................................6
Climate Change Legislation .....................................7
What Are Some Possible Considerations?...............................8
List of Tables
Table 1. Possible Range of Services and Regulatory Drivers................3
Environmental Services Markets
in the 2008 Farm Bill
The enacted 2008 farm bill (Food, Conservation, and Energy Act of 2008, P.L.
110-234) includes a new conservation provision that seeks to facilitate the
participation of farmers and landowners in environmental services markets, covering
a range of farm and forestry services, including improved water and air quality,
increased carbon storage, and habitat protection. The inclusion of this provision
could expand the scope of existing farmland conservation programs and facilitate the
development of private-sector markets for agriculture- and forestry-based
environmental goods and services.
In part, congressional interest in this area has developed in response to increased
attention to the agriculture and forestry sectors’ contributions to some remaining
environmental pollution and resource degradation concerns. For example, the U.S.
Environmental Protection Agency (EPA) reports that agriculture is the leading source
of water pollution in U.S. lakes and rivers, and a major contributor of pollution in
U.S. estuaries. EPA also reports that agriculture contributes to an estimated 6% of
all greenhouse gas emissions in the United States. At the same time, some in
Congress are suggesting that U.S. farm support programs should do a better job
promoting environmental benefits and also complying with domestic support
constraints called for by the World Trade Organization. The agriculture and forestry
sectors are also being regarded as a possible source of carbon capture and storage
within the broader climate change debate in the 110th Congress.
The development of market-based approaches to farm conservation and land
management might complement existing and/or emerging environmental regulations
or natural resource requirements affecting the agriculture and forestry sectors, as well
as complement existing federally supported programs that promote conservation in
the farm and forestry sectors. Environmental goods and services from the agriculture
and forestry sectors might also provide for environmental improvements and
mitigation at a relatively lower cost, compared to mitigation in other sectors of the
economy. Environmental services markets may also offer additional financial
opportunities to farmers and landowners.
What Are Environmental Services Markets?
Environmental goods and services are the benefits society obtains from the
environment and ecosystems, both natural and managed, such as water filtration,
flood control, provision of habitat, carbon storage, and many others (Table 1).1 In
1 These may also be referred to as ecosystems services. See, for example, World Resources
most cases, these constitute “free services” since landowners and managers are not
compensated in the marketplace. However, as many such services have become
degraded over time, there is growing recognition that they should be sustained or
substituted by market capital, similar to investing in water treatment plants and
engineered flood control systems. One solution would be to create markets, often
developed through regulation, so that providers of environmental services can be
compensated in private markets for the services they provide. This could offer a
potential business opportunity to the farm and forest sectors, which may be able to
provide for such services and participate in the market, for example, by creating,
restoring, preserving function and value in a natural resources area, or by capturing
and storing carbon before gases that contribute to global climate change are released
into the atmosphere. These services would be in addition to the food and fiber
services traditionally supplied by the agriculture and forestry sectors.
The market for environmental goods and services involving the agricultural and
forestry sectors began mostly through various pilot programs starting in the 1990s.
The development of voluntary carbon credit markets and watershed approaches
incorporating nutrient credit trading, along with wetlands mitigation banking, have
involved the farm and forestry sectors. These programs provide a market for farmers
to sell carbon or nutrient farm-based offsets to emitters/dischargers that are looking
to buy offsets to mitigate their own emissions/discharges. These efforts have
triggered interest in other types of tradeable permits and credits, including habitat
credit trading and other types of conservation banking. USDA identifies
environmental markets with relevance to the agriculture and forestry sectors to
include water quality, air quality, wetlands, endangered species, greenhouse gases,
and developmental rights.2 Often the impetus for these efforts may be linked to a
“regulatory driver” specific to an actual or anticipated environmental regulation or
natural resource requirement, such as requirements in the Clean Water Act (CWA),
Endangered Species Act (ESA), or other state or local regulation (see Table 1).
Other incentives may include market drivers that make trading environmental
services financially attractive, or the desire to cultivate community goodwill.
Farmer participation in voluntary carbon credit trading programs has been
growing rapidly, and currently involves an estimated 4,000 farmers across 25-303
states covering more than 4 million acres. The two largest programs providing for
farm-based offsets are programs operated by the Iowa Farm Bureau and the North
Dakota Farmers Union; other similar programs are operated by the Illinois
Conservation and Climate Initiative, the Environmental Credit Corporation (based
in Indiana), the Upper Columbia Resource Conservation and Development Council
(Northwest), and Terrapass (based in California).4 These programs cover some or all
Institute, Millennium Ecosystem Assessment, Ecosystems and Human Well-being, 2005.
2 USDA, 2007 Farm Bill, Conservation and Environment Theme Paper, June 2006, at
3 CRS estimate based on information from the Iowa Farm Bureau (January 17, 2008).
4 See, for example, Iowa Farm Bureau [http://www.iowafarmbureau.com/special/carbon/];
aspects of the following types of carbon capture and storage activities: sustainable
agriculture practices (such as conservation tillage, grass seedlings); planting of
unharvested grasslands; tree-plantings; methane capture/biogas production with
manure digesters; wind, solar, or other renewable energy use; controlled grasslands
or pasture management; and forest restoration.
Table 1. Possible Range of Services and Regulatory Drivers
Tradeable Resource/Credit (Type of Service)Regulatory Driver
Wetland, stream, aquifer recharge, forests, buffers,
stormwater controls, habitat/biodiversity (e.g, habitatFederal and/or state
creation/preservation; water filtration; flood control and
protection; water/air pollution controls; runoff reduction)
Nutrients (e.g, runoff reduction; water pollution controls) State
Carbon/greenhouse gas (e.g., capture,State (and possibly
storage/sequestration, methane destruction; air pollutionfederal)
Renewable energy (e.g., biofuel generation; fuelState
Water and development rights (e.g., alternative land and
natural resource preservation; habitatState, county, or local
creation/preservation; aesthetic value; recreational use)
Source: CRS, information from American Farmland Trust and World Resources Institute.
Currently, about 300 farmers are participating in water quality trading programs
across six states.5 These include initiatives such as those by the Southern Minnesota
Beet Sugar Cooperative, the Grassland Areas Farmers (California), the Rahr Malting
Company (Minnesota), the Great Miami River Watershed (Ohio), and the Red Cedar
River (Wisconsin), among others. These programs cover some or all of the following
types of nutrient runoff reduction activities: cover cropping; reduced fertilizer use;
conservation tillage; tree-plantings; buffers; drainage management; and wetlands
mitigation trading.6 Most water quality trading programs were initiated at the local
or state level, often involving EPA. In 2006, EPA and USDA’s Natural Resources
North Dakota Farmers Union [http://www.ndfu.org]; Illinois Conservation and Climate
Initiative [http://www.illinoisclimate.org]; Terrapass [http://www.terrapass.com/projects];
and Environmental Credit Corporation [http://www.envcc.com]. See also CRS Report
RL33898, Climate Change: The Role of the U.S. Agriculture Sector, by Renée Johnson.
5 Information from EPA. Does not include the Tar-Pamlico in North Carolina since not
enforceable through a CWA permit.
6 H. L. Breetz et al., Water Quality Trading and Offset Initiatives in the U.S.: A
Comprehensive Study, Dartmouth College, at [http://www.dartmouth.edu/~kfv/
waterqualitytradingdatabase.pdf]; and EPA’s website at [http://www.epa.gov/owow/
watershed/trading.htm]. Also see CRS Report RS21403, EPA’s Water Quality Trading
Policy, by Claudia Copeland.
Conservation Service (NRCS) signed a partnership agreement to establish uniform
trading standards, along with supporting other collaborative efforts.7
The U.S. Fish and Wildlife Service, USDA’s NRCS, and the Association of
Fish and Wildlife Agencies signed a partnership agreement in April 2007 to promote
habitat credits that could offer incentives to landowners who preserve and enhance
the habitat of endangered or at-risk species. Among the stated objectives of this
agreement is to develop and adopt common definitions, standards, and measurement
protocols.8 Habitat credits or “conservation banking” act like a savings account,
where credits are earned for land preservation of habitat and credits can then be sold
to land use industries or others who are required to mitigate the loss of habitat under
the ESA and other laws that restrict or prohibit development. This is conceptually
similar to wetlands and stream mitigation banking, which allows for compensation
of adverse impacts of development activities (“compensatory mitigation”) to
wetlands, streams, wildlife refuges, or other aquatic resources. Such allowances,
whether through wetlands or conservation banking, typically involve creating,
restoring, enhancing, or preserving function and value in a natural resources area,
often within the context of meeting a federal, state, or local regulatory requirement.
The participation of agriculture and forestry in emerging environmental services
markets is gaining wide support within the farm community and its supporting
organizations and agencies, as well as among the regulatory agencies and some
environmental groups.9 As part of its recommendations for the 2007 farm bill, the
U.S. Department of Agriculture (USDA) has proposed to further facilitate the
development of environmental services markets in ways that would more effectively
involve the farm and forestry sectors. Both the House- and the Senate-passed
versions of the farm bill (H.R. 2419) included similar provisions as part of the
conservation title in their respective bills.
What Are the Benefits and Barriers?
The development of market-based approaches has been widely touted as a
possible source of additional farm income, whether through the sale of tradeable
credits or from other types of payments, such as recreational use or hunting fees.
This could offset or partially offset the costs of pollution abatement incurred by
farmers who make environmental improvements on their farmlands. In some cases,
adopting alternative production practices could also result in on-farm cost savings,
7 The agreement text can be found at [http://www.epa.gov/owow/watershed/trading/
8 The agreement text can be found at [http://www.fws.gov/endangered/pdfs/Credit_Trading_
9 See, for example, Ann Sorensen, “Ecosystem Service Markets in Agriculture,” May 2007,
at [http://www.aft research.org/aaas/]; presentations at USDA’s Ag Outlook forum by Ginny
Kibler, “Water Quality Trading Basics,” and Carl Lucero, “USDA Farm Bill Conservation -
Supply Side of Trading,” March 2007 [http://www.usda.gov/oce/forum/2007%20Speeches/
index.htm]; and presentation material distributed by staff at the Environmental Defense.
such as the use of renewable fuel generated on-farm. Market-based approaches are
also often viewed as encompassing broader societal benefits by complementing
existing farm conservation programs and evolving regulatory approaches intended
to address environmental improvements in the farm and forestry sectors.
USDA reports that there are several existing barriers that may prevent the
development of environmental goods and services markets involving the farm and
forestry sectors.10 These include but may not be limited to:
!uncertainty quantifying, measuring, and valuing credits;
!low demand for or discounted value of credits from agricultural
sources because of uncertainty about the measurement and value of
!low participation in the farm and forestry sectors due to uncertainty
over the value of environmental credits compared to the cost of
!reluctance by farmers and landowners to participate in a regulatory-
!small quantity of benefits that can be provided by individual farmers
!high transaction costs;
!performance risks and liability;
!lack of information about program benefits and how to participate;
!lack of monitoring and enforcement; and
!uncertainty about whether conservation and environmental
improvements that were initially funded through other publicly
funded programs, such as cost-share programs administered by
USDA, will be allowed to be traded.
What Is the Recent Congressional Action?
The enacted 2008 farm bill contains a new conservation provision that seeks to
facilitate the participation of farmers and landowners in environmental services
markets by directing USDA to develop technical guidelines for measuring farm- and
forestry-based environmental services. This provision focuses first on carbon storage
and indirectly references various agriculture and forestry provisions in some
legislative initiatives that are being considered as part of the broader climate change
debate, which have highlighted the perceived need for uniform standards and ways
of measuring emissions reduction and increases in carbon storage in the agriculture
and forestry sectors.
10 For more information, see USDA, 2007 Farm Bill, Conservation and Environment Theme
Paper, June 2006, at [http://www.usda.gov/documents/FarmBill07consenv.pdf]; and M.
Ribaudo and C. Jones, “Environmental Credit Trading: Can Farming Benefit,” Amber
Waves, USDA’s Economic Research Service, Feb. 2006.
Farm Bill Legislation
In the managers report on the 2008 farm bill (P.L. 110-234, the Food,
Conservation, and Energy Act of 2008),11 the conferees state that “the largest barrier
to participation [in emerging environmental services markets] is the lack of standards
and accounting procedures that make transparent the benefits that are being produced
and marketed.” To address this concern, the enacted bill contains a new provision
in the bill’s conservation title that seeks to “establish technical guidelines that outline
science-based methods to measure the environmental services benefits from
conservation and land management activities in order to facilitate the participation
of farmers, ranchers, and forest landowners in emerging environmental services
markets” (Sec. 2709, Environmental Services Markets).
The intended purpose of these technical guidelines is to develop (1) a procedure
to measure environmental services benefits; (2) a protocol to report environmental
services benefits; and (3) a registry to collect, record, and maintain data on the
benefits measured. The provision also requires that USDA provide guidelines for
establishing a verification process as part of the protocol for reporting environmental
services, but it allows USDA to consider the role of third parties in conducting
independent verification. In carrying out this directive, USDA is directed to work in
consultation with other federal12 and state government agencies, nongovernmental
interests,13 and other interested persons as determined by USDA.
The inclusion of this provision could expand the scope of existing farmland
conservation programs by facilitating the development of private-sector markets for
a range of environmental goods and services from farmers and landowners.
Although the provision covers a range of farm and forestry services, including
improved water and air quality, increased carbon storage, and habitat protection,
among other types of environmental services, it explicitly gives priority to first
establishing guidelines related to participation in carbon markets.
Both the House- and Senate-passed farm bills (H.R. 2419) proposed versions
of this provision in their respective bills. Although the two versions differed in scope
and in overall approach, both were similar in their intent to establish a framework to
develop consistent standards and processes for quantifying farm- and forestry-based
environmental services. The House-passed provision (Sec. 2407) proposed to
establish a USDA-led Environmental Services Standards Board, which would
11 The law was enacted on May 22, 2008, following a House and Senate vote to override the
Administration’s veto of the bill on May 21. However, an enrolling error resulted in one
title of the bill (Title III, Trade) being omitted from the version that was sent to the White
House, and the enacted law contains 14 of 15 farm bill titles. Congress is considering a
range of options on how to resolve this issue.
12 In the House- and Senate-passed versions of this provision, other federal agencies were
identified as including the Departments of Interior, Energy, Commerce, and Transportation;
the Environmental Protection Agency; and the Army Corps of Engineers.
13 Identified as including farm, ranch, and forestry producers; financial institutions involved
in environmental services trading; and institutions, nongovernmental organizations, and
private sector representatives with relevant expertise or experience.
provide contracts, cooperative agreements, and grants to develop consistent standards
and processes for quantifying environmental benefits from the farm and forestry
sectors, thus establishing a framework to develop such standards and processes.14
The Senate-passed version (Sec. 2406) also directed USDA to establish a framework
to develop consistent standards and processes that would facilitate the marketability
of farm- and forestry-based environmental services, but differed in that it directed
USDA to “give priority” to providing assistance to farmers and landowners
participating in carbon markets. The Senate version differed also in that it called for
a “collaborative” process involving governmental and nongovernmental
representatives. It also required a series of progress reports to Congress, which were
subsequently not included in the enacted bill.
The House, Senate and conference versions of this provision differed in terms
of funding. For FY2008-FY2012, the House bill authorized $50 million to be
appropriated for this provision, whereas the Senate bill authorized such sums as are
necessary annually. However, the enacted bill does not specifically address funding;
instead, the manager’s report states that USDA is expected to “fulfill the intent of this
section with resources available to the Department.” In contrast, USDA’s farm bill
recommendations requested authorization of $50 million in mandatory funds to cover
the types of tasks addressed in this provision.
Climate Change Legislation
Aside from the 2008 farm bill debate, there are other legislative initiatives that
might also facilitate the development of environmental services markets involving
the farm and forestry sectors — particularly in the area of carbon storage and
emissions reduction — as part of the ongoing climate change debate. During the
110th Congress, several proposals have been introduced that would either mandate
or authorize a cap-and-trade program to reduce greenhouse gas (GHG) emissions.
A cap-and-trade program provides a market-based policy tool for reducing emissions
by setting a cap or maximum emissions limit for certain industries. Sources covered
by the cap can choose to reduce their own emissions, or can choose to buy emission
credits that are generated from reductions made by other sources.
In general, the current legislative proposals would not require emission
reductions in the agriculture and forestry sectors as a covered industry. However,
several of the cap-and-trade proposals do incorporate the agriculture and forestry
sectors either as a source of carbon offsets or as a recipient of set-aside allowances.15
14 The House provision is similar to that proposed by USDA as part of its farm bill
recommendations. See USDA, USDA’s 2007 Farm Bill Proposals, Jan. 31, 2007, at
[http://www.usda.gov/documents/07finalfbp.pdf]; USDA, 2007 Farm Bill, Conservation
and Environment Theme Paper, June 2006, at [http://www.usda.gov/documents/FarmBill07
15 In the context of these legislative proposals, a carbon offset is a measurable avoidance,
reduction, or sequestration of carbon dioxide (CO2) or other GHG emissions, expressed in
carbon-equivalent terms. A set-aside allowance refers to a set percentage of available
allowances under the overall emissions cap that is allocated to non-regulated entities, in this
The inclusion of these provisions as part of a cap-and-trade framework could provide
additional financial incentives to encourage additional land-based conservation
activities involving the agriculture and forestry sectors. For example, these
provisions could allow farmers and landowners to participate in this emerging market
by allowing them to generate (and sell) carbon offsets and credits associated with
carbon capture and storage, emissions reductions, and/or other implemented
environmental improvements on their farm or forested lands.16 These allowances and
credits could be sold to regulated facilities (e.g., power plants) covered by a
cap-and-trade program to meet their emission reduction obligations. Under some
cap-and-trade proposals the agriculture and forestry sectors also would receive
proceeds from the sale of these allowances, credits, and auctions to further promote
and support activities in these sectors that reduce, avoid, or sequester emissions.
These bills and issues continue to be debated in Congress.
In most cases, these bills contain language highlighting the perceived need for
uniform standards and ways of measuring emissions reduction and increases in
carbon storage in the agriculture and forestry sectors. The initiatives generally
stipulate that measurements of emissions reductions and carbon uptake should be
real, verifiable, additional, permanent, and enforceable. This requirement indirectly
ties back to the new conservation provision in the 2008 farm bill (see previous
section) that seeks to establish technical standards and accounting procedures for
environmental services generated in the agriculture and forestry sectors.
For more information about the farm and forestry provisions within a leading
Senate cap-and-trade initiative, see CRS Report RS22834, Agriculture and Forestry
Provisions in Climate Change Legislation (S. 3036). For other general information
on the current GHG policy debate and legislative proposals, see CRS Report
RL33846, Greenhouse Gas Reduction: Cap-and-Trade Bills in the 110th Congress,
by Larry Parker and Brent D. Yacobucci; and CRS Report RL34067, Climate Change
Legislation in the 110th Congress, by Jonathan L. Ramseur and Brent D. Yacobucci.
What Are Some Possible Considerations?
Among the principal questions regarding the inclusion of these types of
provisions as part of any major legislative initiative is whether the agriculture and
forestry sectors can effectively provide environmental goods and services along with
the more traditional food, fiber, and other services these sectors already provide. The
inclusion of these provisions could also raise certain procedural or implementation
questions as Congress debates future farm policy or as it continues to consider the
role of the agriculture and forestry sectors in climate change legislation.
case domestic agriculture and forestry entities.
16 Some legislative proposals would allow relatively broad use of agricultural and land use
offset types, while others would allow for a more narrow use of offsets, such as emission
reductions from animal waste. Some bills would not allow for offsets, but would set aside
a percentage of allowances for various purposes, including biological sequestration.
!Standards-setting process/implementation. How will USDA
implement its new farm bill directive for establishing uniform
standards, accounting procedures, protocols, and registries for
quantifying farm- and forestry-based environmental services? Can
USDA accomplish its task using available agency resources?
!Jurisdictional issues. What are the advantages of establishing
USDA as the lead role? What lead role will USDA play, given the
mostly regulatory authority and statutory obligations of other likely
participating federal agencies? Might putting USDA as the lead
create conflict of interest as both the regulator and promoter of
standards? Are there other jurisdictional issues, such that this
provision needs to be referred to other authorizing congressional
committees? How might existing state and local programs
implemented by other agencies be affected? How will the
collaborative effort between USDA and the other participating
federal agencies be put into practice? How will disagreements be
addressed and resolved among all federal partners?
!Consistency with existing regulatory authorities. Will the agreed-
upon decisions and standards resulting from such an effort be
binding among all federal agencies? What assurances are there that
these decisions will not override the authorizing legislation
regulating water and air quality, and wildlife habitat? Will
regulatory agencies with authorizing legislation have the flexibility
to not adopt the standards authorized by the board or other
collaborative process, if they violate the individual agencies’
authorizing statutes, or contain regulations, such as measurement
protocols? What are the possible implications if these decisions and
standards are inconsistent with other existing regulatory guidelines
!Consistency with possible future authorities and initiatives. Will
such a standard-setting framework and the agreed-upon standards be
consistent with, or readily adapted to, other possible future
regulatory initiatives, such as those involving climate change? If
possible future climate change initiatives do not provide for carbon
offsets and credits from the agriculture and forestry sector, will the
agreed-upon standards be enforceable within the existing voluntary
carbon market? What are the potential implications if these
decisions and standards are inconsistent with other possible
forthcoming regulatory guidelines and authorities?
!Standards. Will uniform standards be national, regional, local, or
site-specific in scope? How will uniform standards address
differences within different production areas, types of resources, and
ecosystems? Will established protocols and management practices
take into account these differences? Will these standards consist of
an assigned value? Given the wide range in the types of
environmental services, how will outcomes or benefits be measured
and expressed as standards? Will there be penalties for non-
!Federal versus marketplace functions. What roles should
government agencies play in actually establishing environmental
services markets involving agriculture and forestry? What roles will
be strictly within the purview of the private-sector and independent
credit markets? Is there a federal role beyond developing the
reporting and credit registries that would require the board to act as
intermediary between sellers and buyers? Who will be responsible
for oversight of third party verification and certification, and for
assigning market value to tradeable credits within an environmental
services market? Will the federal agencies play a role in market
oversight, enforcement, risk management, and capital investment?
What other types of federal assistance may be needed to further
facilitate the development of environmental services markets
involving agriculture and forestry?
!Congressional reporting/timeline. How and when will the
agencies involved in setting standards be expected to report their
accomplishments to Congress? Should reporting requirements be
included as part of these provisions?
!Market barriers. How effectively do the current proposals address
the types of barriers that have been identified by USDA and others
that may prevent the development of environmental goods and
services markets involving the farm and forestry sectors?
!Possible unintended consequences. Might establishing a market-
based approach shift governmental and/or industry priorities away
from addressing more serious environmental problems by allowing
some industrial facilities to buy relatively lower-cost farm-based
carbon credits rather than pay for on-site pollution abatement at the
facility? Might a market-based program shift USDA resources away
from established farm conservation programs?