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DEPARTMENT OFAGRICULTURE
Daren Bakst

American farmers efficiently and safely produce food to meet the needs ofindividuals around the globe. Because of the innovation and resilienceof the nation’s farmers, American agriculture is a model for the world. If
farmers are allowed to operate without unnecessary government intervention,
American agriculture will continue to flourish, producing plentiful, safe, nutritious,and affordable food.
The U.S. Department of Agriculture (USDA) can and should play a limited role,with much of its focus on removing governmental barriers that hinder food production or otherwise undermine efforts to meet consumer demand. The USDA
should recognize what should be self-evident: Agricultural production should firstand foremost be focused on efficiently producing safe food.
This chapter provides important background on the USDA and identifies manyof the USDA-specific issues that will be faced by an incoming Administration. It
provides specific recommendations for the next Administration about how toaddress these issues and lays out a conservative vision for what the USDA shouldlook like in the future.
MISSION STATEMENT

The current mission statement as stated by the Biden Administration highlights
the broad scope of the USDA:
To serve all Americans by providing effective, innovative, science-based
public policy leadership in agriculture, food and nutrition, natural resource— 289 —

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protection and management, rural development, and related issues with acommitment to delivering equitable and climate smart opportunities thatinspire and help America thrive.1

The first part of the mission statement regarding the issues covered is not new
to the Biden Administration; it reflects the overly broad nature of the USDA’s work.
However, the language bringing in equity and climate change is new to the Biden
Administration and part of the USDA’s express effort to transform agricultural
production.2
The USDA’s new vision statement illuminates the focus of this effort:
An equitable and climate smart food and agriculture economy that protects andimproves the health, nutrition and quality of life of all Americans, yields healthy
land, forests and clean water, helps rural America thrive, and feeds the world.3

This effort is one of a federal central plan to put climate change and environmental issues ahead of the most important requirements of agriculture—to
efficiently produce safe food. The USDA would apparently use its power to change
the very nature of the food and agriculture economy into one that is “equitable andclimate smart.” As an initial matter, the USDA should not try to control and shapethe economy, but should instead remove obstacles that hinder food production.
Further, it should not place ancillary issues, such as environmental issues, aheadof agricultural production itself.
A Proper Mission Statement. Even before the Biden Administration’s radical effort to reshape the USDA’s work, the USDA’s mission was and is too broad,including serving as a major welfare agency through implementation of programs
such as food stamps. This far-reaching mission is not the fault of the USDA, but of
Congress, which has given the department its extensive power.
Congress must limit the USDA’s role. A proper mission would clarify that the
department’s primary focus is on agriculture and that the USDA serves all Americans. The USDA’s “client” is the American people in general, not a subset ofinterests, such as farmers, meatpackers, environmental groups, etc.
Within this agricultural focus, the USDA should develop and disseminate
information and research (the historical role of the USDA); identify and address
concrete threats to public health and safety arising directly from food and agriculture; remove unjustified foreign trade barriers blocking market access for
American agricultural goods; and generally remove government barriers that
undermine access to safe and affordable food across the food supply chain.
Core principles should be included within any mission statement, includinga recognition that farmers, and the food system in general, should be free from
unnecessary government intervention. Further, there should be clear statements— 290 —

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about the importance of sound science to inform the USDA’s work and respect for
personal freedom and individual dietary choices, private property rights, and therule of law.
Taking these factors into account, below is a model USDA mission statement:
To develop and disseminate agricultural information and research, identify andaddress concrete public health and safety threats directly connected to food andagriculture, and remove both unjustified foreign trade barriers for U.S. goods
and domestic government barriers that undermine access to safe and affordable
food absent a compelling need—all based on the importance of sound science,
personal freedom, private property, the rule of law, and service to all Americans.
OVERVIEW

In 1862, President Abraham Lincoln signed into law the legislation that createdthe USDA.4 The department had a very narrow mission focused on the dissemination of information connected to agriculture and “to procure, propagate anddistribute among the people new valuable seeds and plants.”5 During the last 160
years, the scope of the USDA’s work has expanded well beyond that narrow mission—and well beyond agriculture itself. In addition to being a distributor of farmsubsidies, the USDA runs the food stamp program and other food-related welfare programs and covers issues including conservation, biofuels, forestry, andrural programs.
Based on the USDA’s fiscal year (FY) 2023 budget summary, outlays are estimated at $261 billion: $221 billion for mandatory programs and $39 billion for
discretionary programs.6 These outlays are broken down as follows: nutrition assistance (70 percent); farm, conservation, and commodity programs (14 percent); “allother,” which includes rural development, research, food safety, marketing andregulatory, and departmental management (11 percent); and forestry (5 percent).7
The USDA has provided a summary of its size, explaining, “Today, USDA is comprised of 29 agencies organized under eight Mission Areas and 16 Staff Offices,with nearly 100,000 employees serving the American people at more than 6,000
locations across the country and abroad.”8
MAJOR PRIORITY ISSUES AND SPECIFIC RECOMMENDATIONS

For an incoming Administration, there are numerous issues that should be
addressed at the USDA. This chapter identifies and discusses many of the mostimportant issues. The initial issues discussed should be priority issues for the next
Administration:
Defend American Agriculture. It is deeply unfortunate that the first issue
identified must be a willingness of the incoming Administration to defend American agriculture, but this is precisely what the top priority for that Administration— 291 —

Mandate for Leadership: The Conservative Promiseshould be. As previously discussed, the Biden Administration is seeking to use
the federal government to transform the American food system.9 The USDA web
site explains:
The U.S. Department of Agriculture (USDA), alongside Biden–Harris
Administration leadership and the people of this great country, has embarked
on another historic journey: transforming the food system as we know it—from farm to fork, and at every stage along the supply chain.10

The federal government does not need to transform the food system or develop
a national plan to intervene across the supply chain. Instead, it should respect
American farmers, truckers, and everyone who makes the food supply chain soresilient and successful. One of the important lessons learned during the COVID19 pandemic was how critical it is to remove barriers in the food supply chain—not
to increase them.
The Biden Administration’s centrally planned transformational effort minimizes the importance of efficient agricultural production and instead places issues
such as climate change and equity front and center. The USDA’s Strategic Plan
Fiscal Years 2022–2026 identifies six strategic goals, the first three of which focus
on issues such as climate change, renewable energy, and systemic racism. In the
Secretary of Agriculture’s message, there is only one mention of affordable food—and nothing about efficient production and the incredible innovation and respect
for the environment that already exists within the agricultural community.11
The Biden Administration’s USDA strongly supported12 the recent United
Nations (U.N.) Food Systems Summit. According to the USDA:
The stated goal of the Food Systems Summit was to transform the way theworld produces, consumes and thinks about foods within the context of the2030 Agenda for Sustainable Development and to meet the challenges ofpoverty, food security, malnutrition, population growth, climate change, andnatural resource degradation.13

Not unlike those who oppose reliable and affordable energy production, there
is a disdain, especially by some on the Left, for American agriculture and the foodsystem.14 The Biden Administration’s vision of a federal government developing
a plan that “fixes” agriculture and focuses on issues secondary to food production
is very disturbing.
A recent USDA-created program captures both the disrespect for American
farmers and the Biden Administration’s effort to dictate agricultural practices.
The USDA explained that it was concerned with farmers not transitioning toorganic farming, and therefore announced that it will dedicate $300 million to— 292 —

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induce farmers to adopt organic farming.15 There was no recognition that farmers
know how to farm better than D.C. politicians16 or a that organic food is expensive17
and land-intensive.18 The Biden Administration has also been pushing so-called“climate-smart”19 agricultural practices which received additional support in thepartisan Inflation Reduction Act.20
American agriculture should not need defending. According to the USDA’s latest
data, farm output nearly tripled (a 175 percent increase) from 1948 to 2019, while
the amount of land farmed decreased. In fact, as farm output increased by 175
percent, all agricultural inputs increased by only 4 percent.21
In 2021, despite high food prices—a major problem and regressive—American consumers spent an average of about 10 percent of their personal disposable
income on food, which is close to historic lows. For decades, this share has been in
decline.22 America’s farmers efficiently produce food using fewer resources, making
it possible for food to be affordable. This reality is not only something that should
be defended but also touted as a prime example of what makes American agriculture so successful. The connection between efficiency and affordability seems lostin the Biden Administration’s effort to transform the food system.
RECOMMENDATIONS

Proactively Defend Agriculture. From the outset, the next Administration
should: Denounce efforts to place ancillary issues like climate change ahead offood productivity and affordability when it comes to agriculture.
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Remove the U.S. from any association with U.N. and other efforts to pushsustainable-development schemes connected to food production.
Defend American agriculture and advance the critical importance ofefficient and innovative food production, especially to advance safe andaffordable food.
Stress that ideal policy should remove obstacles imposed on American
farmers and individuals across the food supply chain so that they can meetthe food needs of Americans.
Clarify the critical importance of efficiency to food affordability, and why afailure to recognize this fact especially hurts low-income households who
spend a disproportionate share of after-tax income on food compared tohigher-income households.23

To accomplish these objectives, a new Administration should announce its
principles through an executive order, the USDA should remove all references— 293 —

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to transforming the food system on its web site and other department-disseminated material, and it should expressly and regularly communicate theprinciples informing the objectives listed above, as well as promote these principles through legislative efforts. The USDA should also carefully review existing
efforts that involve inappropriately imposing its preferred agricultural practices
onto farmers.
Address the Abuse of CCC Discretionary Authority. With the exception offederal crop insurance, the Commodity Credit Corporation (CCC) is generally themeans by which agricultural-related farm bill programs are funded. The CCC is afunding mechanism, which, in simple terms, has $30 billion a year at its disposal.24
Section 5 of the Commodity Credit Corporation Charter Act (Charter Act)25
gives the Secretary of Agriculture broad discretionary authority to spend “unused”
CCC money. However, in general, past Agriculture Secretaries have not used thispower to any meaningful extent. This changed dramatically during the Trump
Administration, when this discretionary authority was used to fund $28 billion
in “trade aid” to farmers, consisting primarily of the Market Facilitation Program.
In 2020, this authority was used for $20.5 billion in food purchases and income
subsidies in response to the COVID-19 pandemic.26
At the time, critics warned that this use of the CCC, which in effect created a
USDA slush fund, would lead future Administrations to abuse the CCC, such as
by pushing climate-change policies.27 Predictably, this is precisely what the Biden
Administration has done, using the discretionary authority to create programsout of whole cloth, arguably without statutory authority,28 for what it refers to asclimate-smart agricultural practices.29
The merits of the various programs funded through the CCC discretionary
authority is not the focus of this discussion. The major problem is that the Secretary of Agriculture is empowered to use a slush fund. Billions of dollars are being
used for programs that Congress never envisioned or intended.
Concern about this type of abuse is not new. In fact, from 2012 to 2017, Congress
expressly limited the Agriculture Secretary’s discretionary spending authority
under the Charter Act.30 And this was before the recent massive discretionary CCC
spending occurred.
The use of the discretionary power is a separation of powers problem, with
Congress abrogating its spending power. This power is ripe for abuse—as could be
expected with any slush fund—and it is a possible way to get around the farm billprocess to achieve policy goals not secured during the legislative process.
The next Administration should:lRefrain from using section 5 discretionary authority. The USDA canaddress this abuse on its own by following the lead of most Administrations
and not using this discretionary authority.

— 294 —

2025 Presidential Transition ProjectlPromote legislative fixes to address abuse. Ideally, Congress would
repeal the Secretary’s discretionary authority under section 5 of the Charter
Act. There is no reason to maintain such authority. If Congress needs tospend money to assist farmers, it has legislative tools, including the farm bill
and the annual appropriations process, to do so in a timely fashion. While
not an ideal solution, Congress could also amend the Charter Act to requireprior congressional approval through duly enacted legislation before any
money is spent.
At a minimum, Congress should amend the Charter Act to:

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Limit spending to directly help farmers and ranchers address issues due
to unforeseen events not already covered by existing programs and that
constitute genuine emergencies that must be addressed immediately.
Prohibit the CCC from being used to assist parties beyond farmers and ranchers.
Clarify that spending is only to address problems that are temporary innature and ensure that funding is targeted to address such problems.
Tighten the discretion within section 5 and identify ways for improper
application of the Charter Act to be challenged in court.

Reform Farm Subsidies. Too often, agricultural policy becomes synonymouswith farm subsidy policy. This is unfortunate, because making them synonymous fails to recognize that agricultural policy covers a wide range of issues,
including issues that are outside the proper scope of the USDA, such as environmental regulation.
However, there is no question that farm subsidies are an important issue
within agricultural policy that should be addressed by any incoming Administration. There are several principles that even subsidy supporters would likely
agree upon, including the need to reduce market distortions. Subsidies should not
influence planting decisions, discourage proper risk management and innovation,
incentivize planting on environmentally sensitive land, or create barriers to entry
for new farmers. Farm subsidies can lead to these market distortions and therefore, it would hardly be controversial to ensure that any subsidy scheme should
be designed to avoid such problems.
The overall goal should be to eliminate subsidy dependence. Despite whatmight be conventional wisdom, many farmers receive few to no subsidies,31 withmost subsidies going to only a handful of commodities. According to the Congressional Research Service (CRS), from 2014 to 2016, 94 percent of farm program— 295 —

Mandate for Leadership: The Conservative Promise

support went to just six commodities—corn, cotton, peanuts, rice, soybeans, andwheat—that together account for only 28 percent of farm receipts.32 Although many
farmers do not receive much in the way of subsidies, especially those in the areasof livestock and specialty crops (fruit, vegetable, and nuts),33 there are still a significant number of farmers growing row crops like corn and cotton that do receive
significant farm subsidies.
The primary subsidy programs include the Agriculture Risk Coverage (ARC)
program,34 the Price Loss Coverage (PLC) program,35 and the federal crop insurance program.36 Farmers can participate on a crop-by-crop basis in the ARC
program or the PLC program. These programs cover about 20 different crops.37 The
ARC program protects farmers from what are referred to as “shallow” losses, providing payments when their actual revenues fall below 86 percent of the expected
revenues for their crops.38 The PLC program provides payments to farmers whencommodity prices fall below a fixed, statutorily established reference price.39
The federal crop insurance program is broader in scope than ARC and PLC,
and in crop year 2019 covered 124 commodities.40 Farmers pay a portion of apremium to participate in the program. Taxpayers on average pay about 60 percent41 of the premium. As explained by CRS, “Revenue Protection was the mostfrequently purchased policy type in 2019, accounting for almost 70 [percent] ofpolicies purchased.”42
While there are certainly other subsidy programs besides ARC, PLC, and federal
crop insurance, one program that deserves special mention is the federal sugar
program. This program, unlike most other subsidy programs, intentionally tries
to restrict supply43 and thereby drives up prices. The program costs consumers asmuch as $3.7 billion a year.44
When it comes to reforming subsidy programs, the next Administration will
primarily have to look to legislative solutions. The next Administration should
champion legislation that would:ll

Repeal the federal sugar program. The federal government should
not be in the central planning business, and the sugar program is a primeexample of harmful central planning. Its very purpose is to limit the sugar
supply in order to increase prices. The program has a regressive effect, since
lower-income households spend more of their money to meet food needs
compared to higher income households.45
Ideally, repeal the ARC and PLC programs. Farmers eligible toparticipate in ARC or PLC are generally already able to purchase federal
crop insurance, policies that protect against shortfalls in expected revenue
whether caused by lower prices or smaller harvests. The ARC program is
especially egregious because farmers are being protected from shallow— 296 —

2025 Presidential Transition Project

losses, which is another way of saying minor dips in expected revenue.
This is hardly consistent with the concept of providing a safety net to help
farmers when they fall on hard times. The Congressional Budget Office(CBO), in one of its options to reduce the federal deficit, has once again
identified repealing all Title I farm programs, including ARC, PLC, and thefederal sugar program.46llStop paying farmers twice for price and revenue losses during thesame year. Farmers can receive support from the ARC or PLC programsand the federal crop insurance program to cover price declines and revenue
shortfalls during the same year. Congress should prohibit this duplication byprohibiting farmers from receiving an ARC or PLC payment the same year
they receive a crop insurance indemnity.
Reduce the premium subsidy rate for crop insurance. On average,
taxpayers cover about 60 percent47 of the premium cost for policies
purchased in the federal crop insurance program. One of the most widely
supported and bipartisan policy reforms is to reduce the premium subsidy
that taxpayers are forced to pay.48 At a minimum, taxpayers should not pay
more than 50 percent of the premium. After all, taxpayers should not haveto pay more than the farmers who benefit from the crop insurance policies.
CBO has found that reducing the premium subsidy to 47 percent would
save $8.1 billion over 10 years and have little impact on crop insurance
participation or on the number of covered acres.49 In that analysis, there
would be a reduction in insured acres of just one-half of 1 percent, andonly 1.5 percent of acres would have lower coverage levels. 50 This reform
is basically all benefit with little to no cost. In its recently released report
identifying options to reduce the federal deficit, CBO found that reducing
the premium subsidy to 40 percent would save $20.9 billion over 10 years.51
Beyond these legislative reforms, the next Administration should:lCommunicate to Congress the necessity of transparency and a genuine
reform process. The White House and the USDA should make it very clearthat the farm bill process, including reform of farm subsidies, must be conducted through an open process with time for mark-up and the opportunity
for changes to be made outside the Agriculture Committee process.
The farm bill too often is developed behind closed doors and without any
chance for real reform. The White House, given the power of the bully pulpit,— 297 —

Mandate for Leadership: The Conservative Promisemust demand a genuine reform process and express unwavering support
for a USDA that shapes a safety net that considers the interests of farmers,
while also remembering the interests of taxpayers and consumers. Any
safety net for farmers should be a true safety net—one that helps farmers
when they have experienced serious unforeseen losses (preferably when
there has been a disaster or unforeseen natural event causing damage) andthat exists to help them in unusual situations.
lSeparate the agricultural provisions of the farm bill from thenutrition provisions. To have genuine reform and proper considerationof the issues, agricultural programs should be considered in separate
legislation distinct from food stamps and the nutrition part of the farm bill,
and reauthorization of such programs should be fixed on different timelines
to ensure this separation. Agricultural and nutritional programs, which are
distinct from each other, have been combined together for political reasons,
something which is readily admitted by proponents of this logrolling. Whenit comes to American agriculture and welfare programs, they deserve soundpolicy debates, not political tactics at the expense of thoughtful discourse.

Move the Work of the Food and Nutrition Service. The USDA implements
many means-tested federal support programs, including the largest food assistance program, Supplemental Nutrition Assistance Program (SNAP, also known
as food stamps), and the Special Supplemental Nutrition Program for Women,
Infants, and Children (WIC) Food Program. The Food and Nutrition Service (FNS)oversees these programs and other food and nutrition programs, including theCenter for Nutrition Policy and Promotion,52 which handles the USDA’s work on
the “Dietary Guidelines for Americans” (Dietary Guidelines).53 Food nutrition
programs include: SNAP; WIC; the National School Lunch Program (NSLP); theSchool Breakfast Program (SBP); the Child and Adult Care Food Program; theNutrition Program for the Elderly; Nutrition Service Incentives; the Summer Food
Service Program; the Commodity Supplemental Food Program; the Temporary
Emergency Food Program; the Farmer’s Market Nutrition Program; and the Special Milk Program.
The next Administration should:lMove the USDA food and nutrition programs to the Department of
Health and Human Services. There are more than 89 current meanstested welfare programs, and total means-tested spending has been
estimated to surpass $1.2 trillion between federal and state resources.54
Because means-tested federal programs are siloed and administered inseparate agencies, the effectiveness and size of the welfare state remains— 298 —

2025 Presidential Transition Projectlargely hidden. There are means-tested food-support programs in the
USDA (specially FNS), whereas most means-tested programs are at the
Department of Health and Human Services (HHS). All means-tested antipoverty programs should be overseen by one department—specifically HHS,
which handles most welfare programs.
Reform SNAP. Ostensibly, SNAP sends money through electronic-benefit-transfer (EBT) cards to help “low-income” individuals buy food. It is the largestof the federal nutrition programs. Food stamps are designed to be supplemented byother forms of income—whether through paid employment or nonprofit support.
SNAP serves 41.1 million individuals—an increase of 4.3 million people during the
Biden years.55 In 2020, the food stamp program cost $79.1 billion. That number
continued to rise—by 2022, outlays hit $119.5 billion.56
The next Administration should:lRe-implement work requirements. The statutory language covering
food stamps allows states to waive work requirements that otherwise
apply to work-capable individuals—that is, adult beneficiaries between theages 18 and 50 who are not disabled and do not have any children or otherdependents in the home.57
Even in a strong economy, work expectations are fairly limited: Individuals
who are work-capable and without dependents are required to work or
prepare for work for 20 hours per week.58 The work requirements are thenimplemented unless the state requests a waiver from the USDA’s Food andNutrition Services.59 Waivers from statutory work requirements can beapproved in two instances: an unemployment rate of more than 10 percent
or a lack of sufficient jobs.60
The Trump Administration bolstered USDA work expectations in thefood stamp program. In February 2019, FNS issued a modest regulatorychange that applied only to able-bodied individuals without dependents—
beneficiaries aged 18 to 49, not elderly or disabled, who did not have children
or other dependents in the home (ABAWD).61 The FNS rule changed
when a state could receive a waiver from implementing the ABAWD workrequirement.
Under the new rule, in order to waive the work requirement, the state’s
unemployment rate had to be above 6 percent for more than 24 months.
The rule also defined “area” in such a way that states would be unable tocombine non-contiguous counties in order to maximize their waivers.62 Of— 299 —

Mandate for Leadership: The Conservative Promise

the more than 40 million food stamp beneficiaries, the Trump rule would
have applied only to 688,000 individuals in fiscal year 2021.63
The Trump reform was scheduled to go into effect, but a D.C. district court
federal judge enjoined the rule.64 The USDA filed an appeal in late December
2020,65 but the Biden Administration withdrew from defending thechallenge, and the rule was never implemented.66
Beyond the able-bodied work requirement, FNS should implement better
regulation to clarify options for states to implement the general workrequirement. This requirement is an option states can apply to workcapable beneficiaries aged 16 to 59. If beneficiaries’ work hours are below
30 hours a week, states can implement the general work requirements to
oblige beneficiaries to register for work or participate in SNAP Employment
and Training or workfare assigned by the state SNAP agency.67 Increased
clarity for states would include items like states being required to offer
employment and training spots for those that request them—not simply
budgeting for every currently enrolled able-bodied adult.
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Reform broad-based categorical eligibility. Federal law permits states
to enroll individuals in food stamps if they receive a benefit from anotherprogram, such as the Temporary Assistance for Needy Families (TANF)
program. However, under an administrative option in TANF called broadbased categorical eligibility (BBCE), ”benefit” is defined so broadly that it
includes simply receiving distributed pamphlets and 1–800 numbers.68 Thisdefinition, with its low threshold to trigger a “benefit,” allows individuals to
bypass eligibility limits—particularly the asset requirement (how much theapplicant has in resources, such as bank accounts or property).69 Adopting
the BBCE option has even allowed millionaires to enroll in the foodstamp program.70
The Trump Administration proposed to close the loophole with a ruleto “increase program integrity and reduce fraud, waste, and abuse.”71 The
regulation was not finalized before the end of the Trump Administration.

lRe-evaluate the Thrifty Food Plan. In a dramatic overreach, the Biden
Administration unilaterally increased food stamp benefits by at least 23
percent in October 2021.72 Through an update to the Thrifty Food Plan, in
which the USDA analyzes a basket of foods intended to provide a nutritious
diet, the USDA increased food stamp outlays by between $250 billion and$300 billion over 10 years.73— 300 —

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Although the 2018 farm bill instructed FNS to update the Thrifty Food Planby 2023 and every five years thereafter, every previous Thrifty Food Plan
has been always cost-neutral ( just an inflation update)—exactly what CBO
estimated as cost of the 2018 farm bill.74
The Biden Administration may have skirted regulations and congressional
authority to increase the overall cost of the program. In fact, Senate andHouse Republicans requested that the Government Accountability Office
investigate the legal authorities and process that the USDA undertook toarrive at such an unprecedented increase.75lEliminate the heat-and-eat loophole. States can artificially boost ahousehold’s food stamp benefit by using the heat-and-eat loophole. The
amount of food stamps a household receives is based on its “countable”
income (income minus certain deductions). Households that receive
benefits from the Low-Income Heat and Energy Assistance Program(LIHEAP) are eligible for a larger utility deduction. In order to makehouseholds eligible for the higher deduction, and thus for greater foodstamp benefits, states have distributed LIHEAP checks for amounts as small
as $1 to food stamp recipients.

The 2014 farm bill tightened this loophole by requiring that a household mustreceive more than $20 annually in LIHEAP payments to be eligible for the larger
utility deduction and subsequently higher food stamp benefits.76 Nonetheless,states continue to inflate their standard utility allowances. Under the Trump
Administration, the USDA proposed a rule, which was not finalized, that would
have standardized the utility allowance.77
Reform WIC. Turning to WIC, this program distributes money through EBT
cards to help low-income women, infants, and children under six purchase nutrition-rich foods and nutrition education (including breastfeeding support). As of
August 2022, approximately 6.3 million people participated in WIC each monthto purchase food.78 In 2021, WIC federal outlays were $5 billion.79
The next Administration should:l

Reform the state voucher system. State agencies control WIC costs
by approving only one brand of infant formula through competitive
bidding for infant formula rebate contracts. Because 50 percent of baby
formula is purchased through the federal WIC program, it is vital that
regulation for these competitive bidding contracts does not unintentionallycreate monopolies.

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Mandate for Leadership: The Conservative PromiselRe-evaluate excessive regulation. As for baby formula regulations
generally, labeling regulations and regulations that unnecessarily delay the
manufacture and sale of baby formula should be re-evaluated.80 During the
Biden Administration, there have been devastating baby formula shortages.

Return to the Original Purpose of School Meals. Federal meal programs for
K–12 students were created to provide food to children from low-income families
while at school.81 Today, however, federal school meals increasingly resemble entitlement programs that have strayed far from their original objective and represent
an example of the ever-expanding federal footprint in local school operations.
The NSLP and SBP are the two largest K–12 meal programs provided by federal
taxpayer money. The NSLP launched in 1946 and the SBP in 1966, both as options
specifically for children in poverty.82 During the COVID-19 pandemic, federal
policymakers temporarily expanded access to school meal programs, but somelawmakers and federal officials have now proposed making this expansion permanent.83 Yet even before the pandemic, research found that federal officials had
already expanded these programs to serve children from upper-income homes,
and these programs are rife with improper payments and inefficiencies.
Heritage Foundation research from 2019 found that after the enactment of
the Community Eligibility Provision (CEP) in 2010, the share of students frommiddle- and upper-income homes receiving free meals in states that participated in
CEP doubled, and in some cases tripled—all in a program meant for children fromfamilies with incomes at or below 185 percent of the federal poverty line (Children
from homes at or below 130 percent of the federal poverty line are eligible for freelunches, while students from families at or below 185 percent of poverty are eligible
for reduced-priced lunches).84
Under CEP, if 40 percent of students in a school or school district are eligible forfederal meals, all students in that school or district can receive free meals. However,the USDA has taken it even further, improperly interpreting the law85 to allow asubset of schools within a district to be grouped together to reach the 40 percent
threshold, As a result, a school with zero low-income students could be grouped
together with schools with high levels of low-income students, and as a result all
the students in the schools within that group (even schools without a single low-income student) can receive free federal meals.86 Schools can direct resources meant
for students in poverty to children from wealthier families.
Furthermore, the NSLP and SBP are among the most inaccurate federal
programs according to PaymentAccuracy.gov, a project of the U.S. Office of Management and Budget and the Office of the Inspector General.87 Before federal
auditors reduced the rigor of annual reporting requirements in 2018, the NSLP
had wasted nearly $2 billion in taxpayer resources through payments provided toineligible recipients.88 Even after the auditing changes, which the U.S. Government— 302 —

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Accountability Office said results in the USDA not “regularly assess[ing] the programs’ fraud risks,” the NSLP wasted nearly $500 million in FY 2021.89 The SBP
now wastes nearly $200 million annually.90
Despite the ongoing effort to expand school meals under CEP and the evidenceof waste and inefficiency, left-of-center Members of Congress and President Biden’s
Administration have nonetheless proposed further expansions to extend federal
school meals to include every K–12 student—regardless of need.91 The Administration recently proposed expanding federal school meal programs offered during theschool year to be offered during the summer as part of the “American Families Plan,”and also proposed expanding CEP. Other federal officials, including Senator Bernie
Sanders (I–VT), have, in recent years, proposed expanding the NSLP to all students.92
To serve students in need and prevent the misuse of taxpayer money, the next
Administration should focus on students in need and reject efforts to transformfederal school meals into an entitlement program.
Specifically, the next Administration should:lll

Promulgate a rule properly interpreting CEP. The USDA should issue
a rule that clarifies that only an individual school or a school district as awhole, not a subset of schools within a district, must meet the 40-percent
criteria to be eligible for CEP. Education officials should be prohibited fromgrouping schools together.
Work with lawmakers to eliminate CEP. The NSLP and SBP should bedirected to serve children in need, not become an entitlement for students
from middle- and upper-income homes. Congress should eliminate CEP.
Further, the USDA should not provide meals to students during the summer
unless students are taking summer-school classes. Currently, students canget meals from schools even if they are not in summer school, which has, in
effect, turned school meals into a federal catering program.93
Restore programs to their original intent and reject efforts to create
universal free school meals. The USDA should work with lawmakers
to restore NSLP and SBP to their original goal of providing food to K–12
students who otherwise would not have food to eat while at school.

Federal school meals should be focused on children in need, and any efforts
to expand student eligibility for federal school meals to include all K–12 students
should be soundly rejected. Such expansion would allow an inefficient, wastefulprogram to grow, magnifying the amount of wasted taxpayer resources.
Reform Conservation Programs. Farmers, in general, are excellent stewardsof the land, if not for moral or ethical considerations, then out of self-interest to— 303 —

Mandate for Leadership: The Conservative Promisemake sure their land and—by extension, their livelihoods—remain intact. Farmers
are often called the original conservationists.94
When evaluating federal conservation programs, it is important to remember
the importance of the land to farmers. In terms of USDA federal conservation
programs, both the USDA’s Farm Service Agency (FSA) and Natural Resources
Conservation Service (NRCS) oversee numerous programs.95
As a general matter, the next Administration should ensure that these programs
address genuine and specific environmental concerns with a focus on currently
existing environmental problems, not those that are speculative in nature. These
conservation programs should have clearly identifiable goals, with the success or
failure of these programs being directly measurable. Any assistance to farmers totake specific actions should not be provided unless the assistance will directly andclearly help to address a specific environmental problem. Further, any assistanceto encourage farmers to engage in certain practices should only be provided if
farmers would not have adopted the practices in the first place.
There are specific issues that the next Administration should address. The
Conservation Reserve Program,96 which is run by FSA, pays farmers to not farmsome of their land. This program has recently received attention, as agriculturalgroups rightfully seek to farm without penalty voluntarily idled land, in light ofthe consequences to food prices of Russia invading Ukraine.97
There is also a need to reform USDA’s conservation easements. These easements
are a powerful tool to incentivize long-term preservation of ecosystems while stillallowing farmers to benefit economically. However, when farmers and ranchers
sign conservation easements with the USDA, they can be enforced in perpetuity.
Future generations, be they the descendants of the landowner or new residents,
are bound by those conditions.
Ecosystems and topography naturally change over time, but without legislativechange, easement requirements will not.
The next Administration should:llChampion the elimination of the Conservation Reserve Program.
Farmers should not be paid in such a sweeping way not to farm their land. If
there is a desire to ensure that extremely sensitive land is not farmed, thisshould be addressed through targeted efforts that are clearly connected toaddressing a specific and concrete environmental harm. The USDA should
work with Congress to eliminate this overbroad program.
Reform NRCS wetlands and erodible land compliance and appeals.
Problematic NRCS overreach could be avoided entirely by removing its
authority to prescribe specific practices on a particular farm operation inorder to ensure continued eligibility to participate in USDA farm programs,— 304 —

2025 Presidential Transition Project

and to require instead that each farm (as a function of eligibility) must havecreated a general best practices plan. Such a plan could be approved by the
local county Soil and Water Conservation District (SWCD). The local SWCD
commissioners are elected by their peers in each respective county and are
better suited than the NRCS to provide guidance for farm operations intheir respective jurisdictions.
At a minimum, a new Administration should support legislation to divest
more power to the states (and possibly local SWCDs) regarding erodible
land and wetlands conservation.98
l

Reform easements. The new Administration should, to the extent
authorized by law, limit the use of permanent easements andcollaborate with lawmakers to prohibit the USDA from creating new
permanent easements.99

Other Major Issues and Specific Recommendations. Although the following
issues have not been listed as “priority,” these issues are still extremely important,and the next Administration should address them.
Only meat and poultry from federally inspected facilities can be sold in interstate commerce.100 Even meat and poultry from USDA-approved state-inspectedfacilities may only be sold in intrastate commerce, with limited exceptions. 101
This is despite the fact that states with USDA-approved inspection programsmust meet and enforce requirements that are “at least equal to” those imposed
under the Federal Meat and Poultry Products Inspection Acts and the Humane
Methods of Slaughter Act of 1978.102 This is an unnecessary regulatory barrierthat makes it difficult to get meat and poultry into interstate commerce to create
more options for consumers and farmers. Legislation entitled the New Markets for State-Inspected Meat and Poultry Act of 2021 would help to remove
this obstacle.103
The next Administration should:lPromote legislation that would allow state-inspected meat to be soldin interstate commerce. These barriers to the sale of meat and poultry
from USDA-approved state-inspected facilities should be removed.

Eliminate or Reform Marketing Orders and Checkoff Programs. Marketing orders and checkoff programs for agricultural commodities are similar inmany ways. They both allow private actors within an industry to collaborate withthe federal government to compel other competitors within an industry to fund therespective marketing order or checkoff program. There are currently 22 checkoff— 305 —

Mandate for Leadership: The Conservative Promise

programs,104 and they focus on research and promotion of commodities such as beefand eggs. Marketing orders cover research and promotion, but also cover issues
such as quality regulations and volume controls. The latter issue, volume controls,
is a means to restrict supply, which drives up prices for consumers. Fortunately,
there are few active volume controls.105
Marketing orders and checkoff programs are some of the most egregious programs run by the USDA. They are, in effect, a tax—a means to compel speech—andgovernment-blessed cartels. Instead of getting private cooperation, they are tools
for industry actors to work with government to force cooperation.
The next Administration should:lllReduce the number and scope of marketing orders and checkoff
programs. The USDA should reject any new requests for marketing orders
and checkoff programs to the extent authorized by law and eliminate
existing programs when possible. While the programs work differently,
there are often petition processes and other ways that make it difficult for
affected parties to get rid of the marketing orders and checkoff programs,106
and the USDA itself may not even be required to honor requests toterminate a program.107 The USDA should make the process easier. Further,
the USDA should reject any effort to bring back volume controls to limit
supplies of commodities.
Work with Congress to eliminate marketing orders and checkoff
programs. These programs should be eliminated, and if industry actors
want to collaborate, they should do so through private means, not using thegovernment to compel cooperation.
Promote legislation that would require regular votes. There should
be regular voting for parties subject to checkoff programs and marketingorders. For example, the voting should occur at least every five years, todetermine whether a marketing order or checkoff program should continue.
The USDA should be required to honor the results of such a vote. Throughregular voting, parties can demonstrate their support for a marketing order
or checkoff program and ensure that those administering them will be held
accountable.

Focus on Trade Policy, Not Trade Promotion. The USDA’s Foreign Agricultural Service (FAS) covers numerous issues, including “trade policy,” which
is a reference to removing trade barriers, among other things, to ensure an environment conducive to trade.108 It also covers trade promotion.109 This includes
programs like the Market Access Program110 that subsidizes trade associations,— 306 —

2025 Presidential Transition Projectbusinesses, and other private entities to market and promote their products
overseas. FAS should play a proactive and leading role to help open upmarkets
for American farmers and ranchers. There are numerous barriers, such as sanitary and phytosanitary measures, blocking American agricultural products fromgaining access to foreign markets.111 However, FAS should not help businesses andindustries promote their exports, something these businesses and industries canand should do on their own.
The next Administration should:lPush legislation to repeal export promotion programs. The USDA
should work with Congress to repeal market development programs like theMarket Access Program and similar programs.

Remove Obstacles for Agricultural Biotechnology. Innovation is critical toagricultural production and the ability to meet future food needs. The next Administration should embrace innovation and technology, not hinder its use—especiallybecause of scare tactics that ignore sound science. One of the key innovations inagriculture is genetic engineering. According to the USDA, “[C]urrently, over 90
percent of U.S. corn, upland cotton, and soybeans are produced using GE [genetically engineered] varieties.”112
Despite the importance of agricultural biotechnology, in 2016, Congress passed
a federal mandate to label genetically engineered food.113 This legislation was arguably just a means to try to provide a negative connotation to GE food. There areother challenges as well for agricultural biotechnology. For example, Mexico plans
to ban the importation of U.S. genetically modified yellow corn.114
The next Administration should:lllCounter scare tactics and remove obstacles. The USDA should strongly
counter scare tactics regarding agricultural biotechnology and adopt
policies to remove unnecessary barriers to approvals and the adoption of
biotechnology.
Repeal the federal labeling mandate. The USDA should work with
Congress to repeal the federal labeling law, while maintaining federal
preemption, and stress that voluntary labeling is allowed.
Use all tools available to remove improper trade barriers against
agricultural biotechnology. The USDA should work closely with the Officeof the United States Trade Representative to remove improper barriers
imposed by other countries to block U.S. agricultural goods.

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Mandate for Leadership: The Conservative Promise

Reform Forest Service Wildfire Management. The United States Forest
Service is one of four federal government land management agencies that administer 606 million acres, or 95 percent of the 640 million acres of surface land area
managed by the federal government.115 Located within the USDA, the Forest Service
manages the National Forest System, which is comprised of 193 million acres.116
As explained by the USDA, “The USDA Forest Service’s mission is to sustain thehealth, diversity, and productivity of the nation’s forests and grasslands to meetthe needs of present and future generations.”117
The Forest Service should focus on proactive management of the forests andgrasslands that does not depend heavily on burning. There should be resilient
forests and grasslands in the wake of management actions. Wildfires have becomea primary vegetation management regime for national forests and grasslands.118
Recognizing the need for vegetation management, the Forest Service has adopted“pyro-silviculture” using “unplanned” fire,119 such as unplanned human-caused fires,to otherwise accomplish vegetation management.120
The Forest Service should instead be focusing on addressing the precipitous
annual amassing of biomass in the national forests that drive the behavior of
wildfires. By thinning trees, removing live fuels and deadwood, and taking otherpreventive steps, the Forest Service can help to minimize the consequencesof wildfires.
Increasing timber sales could also play an important role in the effort to change
the behavior of wildfire because there would be less biomass. Timber sales andtimber harvested in public forests dropped precipitously in the early 1990s andstill remain very low. For example, in 1988, the volume of timber sold and harvested
by volume was about 11 billion and 12.6 billion board feet (BBF), respectively.121 In
2021, timber sold was 2.8 BBF and timber harvested was 2.4 BBF.
In 2018, President Donald Trump issued Executive Order 13855 to, among
other things, promote active management of forests and reduce wildfire risks.122
The executive order stated, “Active management of vegetation is needed to treat
these dangerous conditions on Federal lands but is often delayed due to challenges
associated with regulatory analysis and current consultation requirements.”123 It
further explained the need to reduce regulatory obstacles to fuel reduction inforests created by the National Environmental Policy Act and the Endangered
Species Act.124
The next Administration should:lChampion executive action, consistent with law, and proactive
legislation to reduce wildfires. This would involve embracing Executive
Order 13855, building upon it, and working with lawmakers to promote
active management of vegetation, reduce regulatory obstacles to reducing
fuel buildup, and increase timber sales.

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2025 Presidential Transition Project

Eliminate or Reform the Dietary Guidelines. The USDA, in collaboration
with HHS, publishes the Dietary Guidelines every five years.125 For more than 40
years, the federal government has been releasing Dietary Guidelines,126 and during
this time, there has been constant controversy due to questionable recommendations and claims regarding the politicization of the process.
In the 2015 Dietary Guidelines process, the influential Dietary Guidelines Advisory Committee veered off mission and attempted to persuade the USDA and HHS
to adopt nutritional advice that focused not just on human health, but the healthof the planet.127 Issues such as climate change and sustainability infiltrated theprocess. Fortunately, the 2020 process did not get diverted in this manner. However, the Dietary Guidelines remain a potential tool to influence dietary choices toachieve objectives unrelated to the nutritional and dietary well-being of Americans.
There is no shortage of private sector dietary advice for the public, and nutritionand dietary choices are best left to individuals to address their personal needs. This
includes working with their own health professionals. As it is, there is constantly
changing advice provided by the government, with insufficient qualifications on
the advice, oversimplification to the point of miscommunicating important points,
questionable use of science, and potential political influence.
The Dietary Guidelines have a major impact because they not only can influence
how private health providers offer nutritional advice, but they also inform federal
programs. School meals are required to be consistent with the guidelines.128
The next Administration should:llWork with lawmakers to repeal the Dietary Guidelines. The USDA
should help lead an effort to repeal the Dietary Guidelines.
Minimally, the next Administration should reform the Dietary
Guidelines. The USDA, with HHS, should develop a more transparent
process that properly considers the underlying science and does notoverstate its findings. It should also ensure that the Dietary Guidelines
focus on nutritional issues and do not veer off-mission by focusing on
unrelated issues, such as the environment, that have nothing to do withnutritional advice. In fact, if environmental concerns supersede or water
down recommendations for human nutritional advice, the public would
be receiving misleading health information. The USDA, working withlawmakers, should codify these reforms into law.

ORGANIZATIONAL ISSUES

Based on the recommended reforms identified as ideal solutions, the USDA
would look different in many respects. One of the biggest changes would be a USDA
that is not focused on welfare, given that means-tested welfare programs would— 309 —

Mandate for Leadership: The Conservative Promise

be moved to HHS. The Food and Nutrition Service that administers the food andnutrition programs would be eliminated.
The Farm Service Agency, which administers many of the farm subsidy programs, would be significantly smaller in size if the ideal farm subsidy reforms
were adopted.
Most important, a conservative USDA, as envisioned, would not be used as agovernmental tool to transform the nation’s food system, but instead would respect
the importance of efficient agricultural production and ensure that the government
does not hinder farmers and ranchers from producing an abundant supply of safe
and affordable food.
For a conservative USDA to become a reality, and for it to stay on course withthe mission as outlined, the White House must strongly support these reforms andinstall strong USDA leaders. These individuals almost certainly will be faced with
opposition from some in the agricultural community who would fight changing
subsidies in any fashion, although many of the reforms would likely be embracedby those in agriculture.
There would be strong opposition from environmental groups and others whowant the federal government to transform American agriculture to meet their ideological objectives. Finally, there would be opposition from left-of-center groups
who do not want to reform SNAP and would expand welfare and dependency—suchas through universal free school meals—as opposed to reducing dependency.
Reducing the scope of government and promoting individual freedom may notalways be easy, but it is something that conservatives regularly should strive for.
The listed reforms to the U.S. Department of Agriculture would help to accomplish these objectives and are well worth fighting for to achieve a freer and more
prosperous nation.
CONCLUSION

This chapter started with a discussion of the incredible success of American
farmers and American agriculture in general. This is how the chapter should close
as well. Americans are blessed with an agricultural sector, and a food system ingeneral, which are worthy of incredible respect. A conservative USDA should
appreciate this while recognizing that its role is to serve the interests of all Americans, not special interests. By being a champion of unleashing the potential of
American agriculture, a conservative USDA would help to ensure a future with
an abundant supply of safe and affordable food for individuals and families in the
United States and across the globe.
AUTHOR’S NOTE: The author would like to thank all the contributors for their assistance, expertise, and insight

into the development of this chapter. In addition, special thanks are due to Rachael Wilfong, who was instrumental
in getting the chapter ready for submission.

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ENDNOTES

1.
2.
3.
4.
5.

6.
7.
8.
9.

10.
11.
12.

13.
14.

15.

16.
17.

U.S. Department of Agriculture, Fiscal Year 2023 Budget Summary, p.1, https://www.usda.gov/sites/default/
files/documents/2023-usda-budget-summary.pdf (accessed December 14, 2022).
See, for example, U.S. Department of Agriculture, “Transforming the U.S. Food System,” https://www.usda.
gov/fst (accessed December 14, 2022).
U.S. Department of Agriculture, Fiscal Year 2023 Budget Summary, p.1.
U.S. Department of Agriculture, “USDA Celebrates 150 Years,” https://www.usda.gov/our-agency/about-usda/
history (accessed December 16, 2022).
The law stated, “[T]here is hereby established at the seat of government of the United States a Departmentof Agriculture, the general designs and duties of which shall be to acquire and to diffuse among the peopleof the United States useful information on subjects connected with agriculture in the most general andcomprehensive sense of that word, and to procure, propagate, and distribute among the people new andvaluable seeds and plants.” Gladys L. Baker et al., Century of Service: The First 100 Years of the United States
Department of Agriculture, (Washington, DC: U.S. Government Printing Office, 1963) p. 13, https://babel.
hathitrust.org/cgi/pt?id=uc1.b4254098&view=1up&seq=33 (accessed December 16, 2022).
U.S. Department of Agriculture, Fiscal Year 2023 Budget Summary, p. 2.
Ibid., p. 2.
U.S. Department of Agriculture, Strategic Plan: Fiscal Years 2022–2026, p. 3, https://www.usda.gov/sites/
default/files/documents/usda-fy-2022-2026-strategic-plan.pdf (accessed December 14, 2022).
News release, “USDA Announces Framework for Shoring Up the Food Supply Chain and Transforming theFood System to Be Fairer, More Competitive, More Resilient,” U.S. Department of Agriculture, June 1, 2022,
https://www.usda.gov/media/press-releases/2022/06/01/usda-announces-framework-shoring-food-supplychain-and-transforming (accessed December 14, 2022).
U.S. Department of Agriculture, “Transforming the U.S. Food System.”U.S. Department of Agriculture, Strategic Plan: Fiscal Years 2022–2026, pp. 1–2.
U.S. Department of Agriculture, “Background on the U.S. Approach to the 2021 UN Food Systems Summit,”
August 4, 2021, https://www.usda.gov/sites/default/files/documents/Background-on-US-approach-2021-UNFood-Systems-Summit.pdf (accessed December 14, 2022).
U.S. Department of Agriculture, “UN Food Systems Summit,” https://www.usda.gov/oce/sustainability/unsummit (accessed December 14, 2022).
Mark Bittman et al., “How a National Food Policy Could Save Millions of American Lives,” The Washington
Post, November 7, 2014, https://www.washingtonpost.com/opinions/how-a-national-food-policy-couldsave-millions-of-american-lives/2014/11/07/89c55e16-637f-11e4-836c-83bc4f26eb67_story.html (accessed
December 14, 2022); Daren Bakst and Gabriella Beaumont-Smith, “No, We Don’t Need to Transform theAmerican Food System,” The Daily Signal, February 26, 2021, https://www.dailysignal.com/2021/02/26/
no-we-dont-need-to-transform-the-american-food-system/ (accessed December 14, 2022); and Daren
Bakst, “Biden’s Food Conference Should Put People First, Not Environmental Extremism,” The Daily Signal,
September 22, 2022, https://www.dailysignal.com/2022/09/22/bidens-food-conference-should-put-peoplefirst-not-environmental-extremism/ (accessed December 14, 2022).
News release, “USDA to Invest Up to $300 Million in New Organic Transition Initiative,” U.S. Department ofAgriculture, August 22, 2022, https://www.usda.gov/media/press-releases/2022/08/22/usda-invest-300million-new-organic-transition-initiative (accessed December 14, 2022).
Gary Baise, “Sri Lanka’s Green New Deal Was a Disaster,” Farm Futures, November 14, 2022, https://www.
farmprogress.com/commentary/sri-lankas-green-new-deal-was-disaster (accessed December 16, 2022).
See, for example, Catherine Greene et al., “Growing Organic Demand Provides High-Value Opportunities for Many
Types of Producers,” Economic Research Service, U.S. Department of Agriculture, February 6, 2017, https://www.
ers.usda.gov/amber-waves/2017/januaryfebruary/growing-organic-demand-provides-high-value-opportunitiesfor-many-types-of-producers/#:~:text=ERS%20research%20shows%20that%20many,flavor%20desired%20
by%20the%20consumer (accessed December 14, 2022), and Andrea Carlson, “Investigating Retail Price Premiums
for Organic Foods,” Economic Research Service, U.S. Department of Agriculture, May 24, 2016, https://www.ers.
usda.gov/amber-waves/2016/may/investigating-retail-price-premiums-for-organic-foods/ (accessed December
16, 2022). Further, there are many myths, such as those regarding the alleged health benefit of organic food. One— 311 —

Mandate for Leadership: The Conservative Promisemeta study found that “[t]he published literature lacks strong evidence that organic foods are significantly more
nutritious than conventional foods.” Crystal Smith-Spangler et al., “Are Organic Foods Safer or Healthier Than
Conventional Alternatives,” Annals of Internal Medicine, Vol. 157, No. 5 (September 4, 2012), pp. 348–366, https://www.acpjournals.org/doi/epdf/10.7326/0003-4819-157-5-201209040-00007 (accessed December 16, 2022).
18. Steve Savage, “USDA Data Confirm Organic Yields Significantly Lower Than With Conventional Farming,”
Genetic Literacy Project, February 16, 2018, https://geneticliteracyproject.org/2018/02/16/usda-data-confirmorganic-yields-dramatically-lower-conventional-farming/ (accessed December 16, 2022).
19. See, for example, U.S. Department of Agriculture, “Notice: Climate-Smart Agriculture and Forestry
Partnership Program, Request for Comments,” USDA–2021–0010, October 21, 2021, https://www.regulations.
gov/document/USDA-2021-0010-0001 (accessed December 16, 2022).
20. Inflation Reduction Act of 2022, Public Law 117–169.
21. U.S. Department of Agriculture, Economic Research Service, “Productivity Growth in U.S. Agriculture(1948–2019),” https://www.ers.usda.gov/data-products/agricultural-productivity-in-the-u-s/productivitygrowth-in-u-s-agriculture-1948-2019/ (accessed December 14, 2022).
22. U.S. Department of Agriculture, Economic Research Service, “Total Food Budget Share Increased from 9.4
Percent of Disposable Income to 10.3 Percent in 2021,” July 15, 2022, https://www.ers.usda.gov/data-products/
chart-gallery/gallery/chart-detail/?chartId=76967 (accessed December 14, 2022).
23. U.S. Department of Labor, Bureau of Labor Statistics, “Quintiles of Income Before Taxes: Annual Expenditure
Means, Shares, and Standard Errors, and Coefficients of Variation, Consumer Expenditure Surveys,” 2021,
Table 1101, https://www.bls.gov/cex/tables/calendar-year/mean-item-share-average-standard-error/cuincome-quintiles-before-taxes-2021.pdf (accessed December 16, 2022), and Daren Bakst and Patrick Tyrrell,“Big Government Policies That Hurt the Poor and How to Address Them,” Heritage Foundation Special Report
No.176, April 5, 2017, p. 7, https://www.heritage.org/sites/default/files/2017-04/SR176.pdf.
24. Daren Bakst and Joshua Sewell, “Congress Should Stop Abrogating Its Spending Power and Rein in the USDA
Slush Fund,” Heritage Foundation Issue Brief No. 6052, February 19, 2021, p. 2, https://www.heritage.org/
budget-and-spending/report/congress-should-stop-abrogating-its-spending-power-and-rein-the-usda.
25. Commodity Credit Corporation Charter Act of 1948, Public Law 80–806.
26. Bakst and Sewall, “Congress Should Stop Abrogating Its Spending Power.”
27. Ibid., p. 3.
28. Daren Bakst, “Comment from Bakst, Darren” on “Notice: Climate-Smart Agriculture and Forestry Partnership
Program, Request for Comments,” USDA–2021–0010, October 21, 2021,” November 1, 2021, https://www.
regulations.gov/document/USDA-2021-0010-0001/comment?filter=bakst (accessed December 16, 2022).
29. U.S. Department of Agriculture, “Notice: Climate-Smart Agriculture and Forestry Partnership Program.”
30. Megan Stubbs, “The Commodity Credit Corporation (CCC),” Congressional Research Service Report forCongress, updated January 14, 2021, https://crsreports.congress.gov/product/pdf/R/R44606 (accessed
December 16, 2022).
31. “Overall, 34 percent of all farms reported receiving some type of Government payment in 2021,” and “[o]verall,
14 percent of U.S. farms participated in Federal crop insurance programs.” Christine Whitt, Noah Miller, andRyan Olver, “America’s Farms and Ranches at a Glance: 2022 Edition,” U.S. Department of Agriculture,
Economic Research Service, pp. 24 and 26, https://www.ers.usda.gov/webdocs/publications/105388/eib-247.
pdf?v=527.4 (accessed March 18, 2023). This data, which apparently does not cover crop insurance, included
payments beyond just commodity payments, such as conservation payments.
32. Randy Schnepf, “Farm Safety-Net Payments Under the 2014 Farm Bill: Comparison by Program Crop,”
Congressional Research Service Report for Congress, August 11, 2017, https://fas.org/sgp/crs/misc/R44914.pdf(accessed December 14, 2022).
33. Although livestock and specialty crop producers do receive some subsidies, former American Farm Bureau
Federation President Bob Stallman captured the subsidy issue well. He “dismisse[d] outright the claim that
farmers couldn’t survive without subsidy money. ‘Why does the livestock industry survive without subsidies?’
he ask[ed]. ‘Why does the specialty crop [fruit and vegetable] industry survive?’” Tamar Haspel, “Why Do
Taxpayers Subsidize Rich Farmers?” The Washington Post, March 15, 2018, https://www.washingtonpost.
com/lifestyle/food/why-do-taxpayers-subsidize-rich-farmers/2018/03/15/50e89906-27b6-11e8-b79df3d931db7f68_story.html (accessed March 18, 2023).

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34. U.S. Department of Agriculture, Farm Service Agency, “ARC/PLC Program,” https://www.fsa.usda.gov/
programs-and-services/arcplc_program/index (accessed December 16, 2022).
35. Ibid.
36. U.S. Department of Agriculture, Economic Research Service, “Crop Insurance at a Glance,” May 31, 2022,
https://www.ers.usda.gov/topics/farm-practices-management/risk-management/crop-insurance-at-a-glance/(accessed December 16, 2022).
37. U.S. Department of Agriculture, “Agriculture Risk Coverage (ALC) & Price Loss Coverage (PLC),” Farm
Service Agency Fact Sheet, August 2019, https://www.fsa.usda.gov/Assets/USDA-FSA-Public/usdafiles/
FactSheets/2019/arc-plc_overview_fact_sheet-aug_2019.pdf (accessed December 16, 2022).
38. See, for example, U.S Department of Agriculture, Farm Service Agency, Agriculture Risk Coverage and Price
Loss Coverage Handbook, last amended October 5, 2020, https://www.fsa.usda.gov/Internet/FSA_File/1arcplc_r01_a10.pdf (accessed March 18, 2023); Mesbah Motamed, “Federal Commodity Programs Price Loss
Coverage and Agriculture Risk Coverage Address Price Yield Risks Faced by Producers,” U.S. Departmentof Agriculture, Economic Research Service, August 6, 2018, https://www.ers.usda.gov/amber-waves/2018/
august/federal-commodity-programs-price-loss-coverage-and-agriculture-risk-coverage-address-priceand-yield-risks-faced-by-producers/ (accessed March 18, 2023); and Taxpayers for Common Sense, “Shallow
Loss Agriculture Programs 101,” https://www.taxpayer.net/agriculture/shallow-loss-agriculture-programs-101/(accessed March 18, 2023).
39. Ibid.
40. Stephanie Rosch, “Federal Crop Insurance: A Primer,” Congressional Research Service Report for Congress,
February 18, 2021, p. 1, https://crsreports.congress.gov/product/pdf/R/R46686 (December 14, 2021).
41. Congressional Budget Office, Options for Reducing the Deficit, 2023 to 2032: Volume II; Smaller Reductions,
December 2022, p. 6, https://www.cbo.gov/system/files/2022-12/58163-budget-options-small-effects.pdf(accessed December 14, 2022).
42. Rosch, “Federal Crop Insurance: A Primer,” p. 17.
43. “Farm Bill Primer: Sugar Program,” Congressional Research Service In Focus, updated May 15, 2018, https://www.everycrsreport.com/files/2018-05-15_IF10689_42900e56be67f5cfa17e40953ad9acb54561d3db.pdf(accessed December 16, 2022).
44. See, for example, Agralytica, “Economic Effects of the Sugar Program Since the 2008 Farm Bill & Policy
Implications for the 2013 Farm Bill,” June 3, 2013, p. 1, https://fairsugarpolicy.org/wordpress/wp-content/
uploads/2018/03/AgralyticaEconomicEffectsPaperJune2013.pdf (accessed December 16, 2022).
45. U.S. Department of Labor, “Quintiles of Income Before Taxes,” and Bakst and Tyrrell, “Big Government Policies
That Hurt the Poor and How to Address Them.”
46. Congressional Budget Office, Options for Reducing the Deficit, 2023 to 2032, p. 3. See also Congressional
Budget Office, “Reduce Subsidies in the Crop Insurance Program,” in Congressional Budget Office, “Options
for Reducing the Deficit: 2021 to 2030,” December 9, 2020, https://www.cbo.gov/budget-options/56815(accessed December 14, 2022).
47. Congressional Budget Office, Options for Reducing the Deficit, 2023 to 2032, p. 6.
48. “Reduce Premium Subsidies in the Federal Crop Insurance Program,” Budget Blueprint for Fiscal Year 2023,
https://www.heritage.org/budget/pages/recommendations/2.350.171.html.
49. Congressional Budget Office, “Reduce Subsidies in the Crop Insurance Program.”
50. Ibid.
51. Congressional Budget Office, Options for Reducing the Deficit, 2023 to 2032, p. 6.
52. U.S. Department of Agriculture, Food and Nutrition Service, “Center for Nutrition Policy and Promotion(CNPP),” https://www.fns.usda.gov/cnpp (accessed December 16, 2022), and U.S. Department ofAgriculture, “About CNPP,” Food and Nutrition Service, https://www.fns.usda.gov/about-cnpp (accessed
December 16, 2022).
53. Dietary Guidelines for Americans, “Purpose of the Dietary Guidelines,” https://www.dietaryguidelines.gov/
about-dietary-guidelines/purpose-dietary-guidelines (accessed December 16, 2022).
54. Robert Rector and Vijay Menon, “Understanding the Hidden $1.1 Trillion Welfare System and How to Reform
It,” Heritage Foundation Backgrounder No. 3294, April 5, 2018, https://www.heritage.org/welfare/report/
understanding-the-hidden-11-trillion-welfare-system-and-how-reform-it.

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55. U.S. Department of Agriculture, “SNAP Data Tables,” Food and Nutrition Service, December 9, 2022, https://www.fns.usda.gov/pd/supplemental-nutrition-assistance-program-snap (accessed December 16, 2022).
56. Ibid.
57. U.S. Department of Agriculture, Food and Nutrition Service, “SNAP Work Requirements,” May 2019, https://www.fns.usda.gov/snap/work-requirements#:~:text=Work%20at%20least%2080%20hours,least%2080%20
hours%20a%20month (accessed December 16, 2022).
58. 7 U.S. Code § 2015, https://www.law.cornell.edu/uscode/text/7/2015 (accessed December 16, 2022).
59. Ibid.
60. 7 U.S. Code § 2015(o)(4). The USDA has approved nearly all waivers under the “lack of sufficient jobs” option.
61. Federal Register, Vol. 84, No. 234 (December 5, 2019) p. 66782, https://www.govinfo.gov/content/pkg/FR2019-12-05/pdf/2019-26044.pdf (accessed December 14, 2022).
62. Ibid., p. 66795.
63. Ibid., pp. 66807–66810.
64. District of Columbia, et al. v. U.S. Department of Agriculture, 496 F. Supp. 3d 213 (2020), https://oag.dc.gov/
sites/default/files/2020-10/SNAP-ABAWD-Opinion.pdf (accessed December 16, 2022).
65. Ibid. On December 16, 2020, the Trump Administration appealed the District Court decision. See, for example,
News release “Fudge Slams Administration for Appealing ABAWD Ruling,” House Committee on Agriculture,
December 16, 2020, https://agriculture.house.gov/news/documentsingle.aspx?DocumentID=2069 (accessed
December 16, 2022).
66. News release, “Statement by Agriculture Secretary Tom Vilsack on D.C. Circuit Court’s Decision
Regarding ABAWDs Rule,” U.S. Department of Agriculture, March 24, 2021, https://www.usda.gov/media/
press-releases/2021/03/24/statement-agriculture-secretary-tom-vilsack-dc-circuit-courts (accessed
December 16, 2022).
67. U.S. Department of Agriculture, “SNAP Employment and Training Screening and Referral Guidance,” July 13,
2022, https://www.fns.usda.gov/snap/et-screening-and-referral-guidance (accessed December 16, 2022).
68. U.S. Department of Agriculture, Food and Nutrition Service, “Regulatory Reform at a Glance: Proposed Rule;
Revision of SNAP Categorical Eligibility,” July 2019, https://www.usda.gov/sites/default/files/documents/
BBCE_Fact_Sheet_%28FINAL%29_72219-PR.pdf (accessed December 14, 2022).
69. 7 Code of Federal Regulations § 273.8 (1978), https://www.law.cornell.edu/cfr/text/7/273.8 (accessed
December 16, 2022).
70. Kristina Rasmussen, “How Millionaires Collect Food Stamps,” Wall Street Journal, January 15, 2018, https://www.wsj.com/articles/how-millionaires-collect-food-stamps-1516044026 (accessed December 14, 2022).
71. Federal Register, Vol. 84, No. 142 (July 24, 2019), pp. 35570–55581, https://www.federalregister.gov/
documents/2019/07/24/2019-15670/revision-of-categorical-eligibility-in-the-supplemental-nutritionassistance-program-snap (accessed December 14, 2022).
72. News release, “USDA Modernizes the Thrifty Food Plan, Updates SNAP Benefits,” U.S. Department ofAgriculture, August 16, 2021, https://www.usda.gov/media/press-releases/2021/08/16/usda-modernizesthrifty-food-plan-updates-snap- (accessed December 14, 2022).
73. Phillip L. Swagel, Director, Congressional Budget Office, letter to Congressman Jason Smith, June 23, 2022, p.
2, https://www.cbo.gov/system/files/2022-06/58231-Smith.pdf (accessed December 14, 2022).
74. Congressional Budget Office, “H.R. 2, as Passed by the House of Representatives and as Passed by the Senate,”
July 24, 2018, https://www.cbo.gov/publication/54284 (accessed December 16, 2022).
75. News release, “Republican AG Committee Leadership Urge GAO Review of USDA Thrifty Food Plan Scheme,”
U.S. House Committee on Agriculture, August 13, 2021, https://republicans-agriculture.house.gov/news/
documentsingle.aspx?DocumentID=7013 (accessed December 14, 2022).
76. “The 2014 Farm Bill: Changing the Tradition of LIHEAP Receipt in the Calculation of SNAP Benefits,” updated
February 12, 2014, Congressional Research Service Report for Congress R42591, https://crsreports.congress.
gov/product/pdf/R/R42591/24 (accessed March 18, 2023).
77. Federal Register, Vol. 84, No. 192 (October 3, 2019), pp. 52809–52815, https://www.govinfo.gov/content/pkg/
FR-2019-10-03/pdf/2019-21287.pdf (accessed December 16, 2022).
78. U.S. Department of Agriculture, “Special Supplemental Nutrition Program for Women, Infants, and Children(WIC) Data Series, 2018 to 2022,” https://www.fns.usda.gov/pd/wic-program (accessed December 14, 2022).

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79. U.S. Department of Agriculture, Food and Nutrition Service, “WIC Data Tables,” December 9, 2022, https://www.fns.usda.gov/pd/wic-program (accessed December 16, 2022).
80. U.S. Food and Drug Administration, “Regulations and Information on the Manufacture and Distribution of
Infant Formula,” May 16, 2022, https://www.fda.gov/food/infant-formula-guidance-documents-regulatoryinformation/regulations-and-information-manufacture-and-distribution-infant-formula (accessed
December 14, 2022).
81. U.S. Department of Agriculture, Food and Nutrition Service, “History of the National School Lunch Program,”
January 17, 2008, https://www.fns.usda.gov/nslp/program-history (accessed December 14, 2022).
82. U.S. Department of Agriculture, Food and Nutrition Service, “School Breakfast Program History,” July 24,
2013, https://www.fns.usda.gov/sbp/program-history (accessed December 14, 2022), and U.S. Department ofAgriculture, Food and Nutrition Service, “History of the National School Lunch Program.”
83. Crystal FitzSimons, “Free School Meals for All Is the Key to Supporting Education and Health Outcomes,”
Journal of Policy Analysis and Management, Vol 41, No. 1 (2022), pp. 358–364, https://econpapers.repec.org/
article/wlyjpamgt/v_3a41_3ay_3a2022_3ai_3a1_3ap_3a358-364.htm (accessed December 14, 2022).
84. Jonathan Butcher and Vijay Menon, “Returning to the Intent of Government School Meals: Helping Students
in Need,” Heritage Foundation Backgrounder No. 3399, March 22, 2019, https://www.heritage.org/sites/
default/files/2019-03/BG3399.pdf.
85. Daren Bakst and Jonathan Butcher, “A Critical Fix to the Federal Overreach on School Meals,” Heritage
Foundation Issue Brief No. 4976, July 11, 2019, https://www.heritage.org/hunger-and-food-programs/report/
critical-fix-the-federal-overreach-school-meals.
86. Ibid., and U.S. Department of Agriculture, Food and Nutrition Service, “Community Eligibility Provision,” April
19, 2019, https://www.fns.usda.gov/cn/community-eligibility-provision (accessed December 16, 2022).
87. See Payment Accuracy, https://www.paymentaccuracy.gov/ (accessed December 16, 2022).
88. Payment Accuracy, “Payment Integrity Scorecard,” https://www.cfo.gov/wp-content/uploads/2022/Q3/
FNS%20National%20School%20Lunch%20Program%20(NSLP)%20Payments%20Integrity%20Scorecard%20
FY%202022%20Q3.pdf (accessed December 14, 2022).
89. U.S. Government Accountability Office, “School Meals Programs: USDA Has Reported Taking Some Steps to
Reduce Improper Payments But Should Comprehensively Assess Fraud Risks,” GAO–19–389, May 21, 2022,
https://www.gao.gov/products/gao-19-389 (accessed December 14, 2022).
90. Payment Accuracy, “Payment Integrity Scorecard.”
91. White House, “Fact Sheet: The American Families Plan,” April 28, 2021, https://www.whitehouse.gov/
briefing-room/statements-releases/2021/04/28/fact-sheet-the-american-families-plan/ (accessed
December 14, 2022).
92. Universal School Meals Program Act of 2021, S. 1530, 117th Cong., 1st Sess., https://www.congress.gov/
bill/117th-congress/senate-bill/1530 (accessed December 14, 2022).
93. See, for example, U.S. Department of Agriculture, “Find Meals for Kids When Schools Are Closed,” Food andNutrition Service, September 22, 2022, https://www.fns.usda.gov/meals4kids (accessed December 16, 2022),
and U.S. Department of Agriculture, Food and Nutrition Service, “Seamless Summer and Other Options for
School,” July 16, 2013, https://www.fns.usda.gov/sfsp/seamless-summer-and-other-options-schools (accessed
December 16, 2022).
94. Tom Driscoll, “From the Field: Farmers Are the Original Conservationists,” National Farmers Union, August30, 2017, https://nfu.org/2017/08/30/from-the-field-farmers-are-the-original-conservationists/ (accessed
December 16, 2022).
95. U.S. Department of Agriculture, Farm Service Agency, “Conservation Programs,” https://www.fsa.usda.gov/
programs-and-services/conservation-programs/index (accessed December 16, 2022), and U.S. Department ofAgriculture, Natural Resources Conservation Service, “Programs and Initiatives,” https://www.nrcs.usda.gov/
programs-initiatives (accessed December 16, 2022).
96. U.S. Department of Agriculture, Farm Service Agency, “Conservation Reserve Program: About theConservation Reserve Program (CRP),” https://www.fsa.usda.gov/programs-and-services/conservationprograms/conservation-reserve-program/ (accessed December 16, 2022).

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97. American Bakers Association et al., letter to U.S. Department of Agriculture Secretary Tom Vilsack, March 23,
2022, https://www.dropbox.com/s/yfyv04ilkom11zd/USDA%20Letter%20to%20Secretary%20Vilsack%20on%20
Tools%20to%20Address%20Global%20Commodity%20Supply%20Challenges%203.23.22_.pdf?dl=0 (accessed
December 15, 2022). It is also necessary to increase food production to mitigate high food inflation. Approximately
25 percent of idled land is considered prime farmland. Therefore, one-quarter of idled land is merely idling,
not producing food—and this does not include other land that may viably be used for food production. The
Conservation Reserve Program should be eliminated. There are also two issues connected to property rights andfairness that should be addressed: challenging NRCS determinations and problems with USDA easements. To be
eligible for many USDA programs, farmers must comply with certain conservation provisions enforced by NRCS.
Conservation compliance of wetlands and highly erodible lands consist of federal restrictions that prevent farmers
from using parts of their property. If farmers plant crops or modify the areas federal officials deem protected,
farmers can lose all access to USDA programs and support. For farmers, there are real, practical concerns tochallenging NRCS determinations, including the time and costs of challenging the federal bureaucracy. NRCS isempowered to declare areas wetlands and highly erodible areas, which are therefore off limits for farming. If thesewetland-or-erodible-declared areas are used in a manner deemed unacceptable by federal officials, NRCS may
revoke access to federal resources and subsidies by making technical determinations that carry potential penalties.
There must be a fair and reasonable process for farmers to challenge such actions. See Daren Bakst, “Food Price
Inflation Continues to Worsen. Here’s What Should Be Done About It,” The Daily Signal, April 25, 2022, https://www.dailysignal.com/2022/04/25/food-price-inflation-continuing-to-worsen-heres-what-should-be-doneabout-it/ (accessed December 15, 2022); American Bakers Association et.al., letter to Vilsack; U.S. Department ofAgriculture, Natural Resources Conservation Service, “Conservation Compliance Appeals Process,” https://www.
nrcs.usda.gov/getting-assistance/compliance/conservation-compliance-appeals-process (accessed December 15,2022); and Chris Bennett, “Regulatory Hell: Farmer and Veteran Wins 10-Year Wetlands Fight With Government,”
AG Web, August 30, 2021, https://www.agweb.com/news/crops/crop-production/regulatory-hell-farmer-andveteran-wins-10-year-wetlands-fight (accessed December 15, 2022).
98. Fortunately, there are already resources available to help states establish their own wetlands conservation
programs. One particular example, the American Legislative Exchange Council’s Wetlands Mapping andProtection Act model policy, is available for states to define the procedures, guidelines, and administration of
wetlands programs. American Legislative Exchange Council, “Wetlands Mapping and Protection Act,” November
16, 2017, https://alec.org/model-policy/wetlands-mapping-and-protection-act/ (accessed December 16, 2022). The
new Administration should focus on best practices instead of imposing prescriptive federal practices. It should
support the policies contained within the “NRCS Wetland Compliance and Appeals Reform Act” and modify NRCS
compliance rules to protect farmers and ranchers by adding protections against regulatory overreach—such as
banning the practice of re-engaging farmers in new technical determinations appeals processes for the same
areas of their farms. See NRCS Wetland Compliance and Appeals Reform Act, S. 4931, 117th Cong., 2nd Sess.,
https://www.congress.gov/bill/117th-congress/senate-bill/4931?s=1&r=8 (accessed December 15, 2022).
99. Ibid100. See, for example, Daren Bakst and Jeremy Dalrymple, “Reducing Federal Barriers for the Sale of Meat,”
Heritage Foundation Issue Brief No. 5078, June 1, 2020, https://www.heritage.org/agriculture/report/
reducing-federal-barriers-the-sale-meat, and U.S. Department of Agriculture, Food Safety and Inspection
Service, “State Inspection Programs,” updated January 12, 2023, https://www.fsis.usda.gov/inspection/stateinspection-programs (accessed December 15, 2022).
101. U.S. Department of Agriculture, Food Safety and Inspection Service, “Cooperative Interstate Shipping
Program,” September 7, 2022, https://www.fsis.usda.gov/inspection/state-inspection-programs/cooperativeinterstate-shipping-program (accessed December 15, 2022).
102. U.S. Department of Agriculture, “State Inspection Programs.”
103. The Senate bill removes obstacles for both meat and poultry. The House version does not appear to cover
poultry. New Markets for State-Inspected Meat and Poultry Act of 2021, S. 107, 117th Cong., 1st Sess., https://www.congress.gov/bill/117th-congress/senate-bill/107#:~:text=This%20bill%20allows%20meat%20and,be%20
sold%20in%20interstate%20commerce (accessed December 15, 2022), and Expanding Markets for StateInspected Meat Processors Act of 2021, H.R. 1998, 117th Cong., 1st Sess., https://www.congress.gov/bill/117thcongress/house-bill/1998 (accessed December 15, 2022).

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2025 Presidential Transition Project104. U.S. Department of Agriculture, Agricultural Marketing Service, “Specialty Crops Marketing Orders &Agreements,” https://www.ams.usda.gov/rules-regulations/moa/fv (accessed December 15, 2022).
105. See, for example, U.S. Department of Agriculture, Agricultural Marketing Service, “Commodities Coveredby Marketing Orders,” https://www.ams.usda.gov/rules-regulations/moa/commodities (accessed March
18, 2023), and Elayne Allen and Darren Bakst, “How the Government Is Mandating Food Waste,” August 19,
2016, https://www.dailysignal.com/2016/08/19/how-the-government-is-mandating-food-waste/ (accessed
March 18, 2023).
106. U.S. Department of Agriculture, Agricultural Marketing Service, “Frequently Asked Questions Regarding the
Beef Checkoff Program Petition Process,” https://www.ams.usda.gov/rules-regulations/research-promotion/
beef/petition (accessed December 16, 2022); “Beef Producers: Do You Want to Vote on the Checkoff?” Beef
Magazine, July 28, 2020, https://www.beefmagazine.com/marketing/beef-producers-do-you-want-votecheckoff (accessed December 16, 2022); and Steve White, “Group Seeking Beef Checkoff Referendum Asks forAccess to Producer Database,” Nebraska TV, May 4, 2021, https://nebraska.tv/news/ntvs-grow/group-seekingbeef-checkoff-referendum-asks-for-access-to-producer-database (accessed December 16, 2022). As reported,“There has not been a referendum of the mandatory National Beef Checkoff Program in 35 years.”
107. See, for example, Federal Register, Vol. 86, No. 213 (November 8, 2021), p. 61718, https://www.govinfo.gov/
content/pkg/FR-2021-11-08/pdf/2021-24301.pdf (accessed December 16, 2022).
108. U.S. Department of Agriculture, Foreign Agricultural Service, “Topics,” https://www.fas.usda.gov/topics(accessed December 15, 2022).
109. Ibid.
110. U.S. Department of Agriculture, Foreign Agricultural Service, “Market Access Program (MAP),” https://www.fas.
usda.gov/programs/market-access-program-map (accessed December 16, 2022).
111. To learn about trade barriers for food and agricultural products, see, for example, News release, “USTR
Releases 2022 National Trade Estimate Report on Foreign Trade Barriers,” Office of the U.S. Trade
Representative, March 31, 2022, https://ustr.gov/about-us/policy-offices/press-office/press-releases/2022/
march/ustr-releases-2022-national-trade-estimate-report-foreign-trade-barriers (accessed
December 16, 2022).
112. U.S. Department of Agriculture, Economic Research Service, “Recent Trends in GE Adoption,” September 14,
2022, https://www.ers.usda.gov/data-products/adoption-of-genetically-engineered-crops-in-the-u-s/recenttrends-in-ge-adoption/ (accessed December 15, 2022).
113. National Bioengineered Food Disclosure Standard, Public Law 114–216.
114. Noi Mahoney, “Trade Dispute Arising Over Mexico’s Plan to Block Imports of Genetically Modified Corn,”
Freight Waves, November 22, 2022, https://www.freightwaves.com/news/trade-dispute-arising-overmexicos-plan-to-block-imports-of-gm-corn (accessed December 15, 2022), and News release, “Grassley, Ernst,
Urge USTR to Intervene In Mexico’s Ban on American Corn,” Office of Chuck Grassley, November 14, 2022,
https://www.grassley.senate.gov/news/news-releases/grassley-ernst-urge-ustr-to-intervene-in-mexicos-banon-american-corn (accessed December 15, 2022).
115. “The Federal Land Management Agencies,” Congressional Research Service In Focus, updated February 16,
2021, https://sgp.fas.org/crs/misc/IF10585.pdf (accessed December 16, 2022).
116. Ibid.
117. U.S. Department of Agriculture, U.S. Forest Service, Fiscal Year 2023: Budget Justification, March 2022, p. 1,
https://www.usda.gov/sites/default/files/documents/30a-2023-FS.pdf (accessed December 16, 2022).
118. Forests and Rangelands, The National Strategy: The Final Phase in the Development of the National Cohesive
Wildland Fire Management Strategy, April 2014, https://www.forestsandrangelands.gov/documents/strategy/
strategy/CSPhaseIIINationalStrategyApr2014.pdf (accessed December 16, 2022).
119. U.S. Department of Agriculture, U.S. Forest Service, “Unplanned Fires,” https://www.fs.usda.gov/detail/inyo/
landmanagement/resourcemanagement/?cid=stelprd3804071 (accessed December 16, 2022).
120. See, for example, Sherry Devlin, “A Conversation with Jim Hubbard: Unplanned Wildfires Rule West’s
Forests,” TreeSource, March 28, 2017, https://treesource.org/news/lands/jim-hubbard-forest-service-wildfires/(accessed December 16, 2022).

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121. U.S. Department of Agriculture, U.S. Forest Service, “FY 1905–2021 National Summary Cut and Sold Data
Graphs,” https://www.fs.usda.gov/forestmanagement/documents/sold-harvest/documents/1905-2021_Natl_
Summary_Graph_wHarvestAcres.pdf (accessed December 16, 2022), and U.S. Department of Agriculture, U.S.
Forest Service, “Forest Products Cut and Sold from the National Forests and Grasslands,” https://www.fs.usda.
gov/forestmanagement/products/cut-sold/index.shtml (accessed December 16, 2022).
122. Donald J. Trump, “Promoting Active Management of America’s Forests, Rangelands, and Other Federal Lands
to Improve Conditions and Reduce Wildfire Risk,” Executive Order 13855, December 21, 2018, https://www.
govinfo.gov/content/pkg/DCPD-201800866/pdf/DCPD-201800866.pdf (accessed December 16, 2022).
123. Ibid.
124. Ibid.
125. Dietary Guidelines for Americans, https://www.dietaryguidelines.gov/ (accessed December 16, 2022).
126. Dietary Guidelines for Americans, “History of the Dietary Guidelines,” https://www.dietaryguidelines.gov/
about-dietary-guidelines/history-dietary-guidelines (accessed December 16, 2022).
127. Daren Bakst, “Extreme Environmental Agenda Hijacks Dietary Guidelines: Comment to the Advisory
Committee,” The Daily Signal, July 17, 2014, https://www.dailysignal.com/2014/07/17/extreme-environmentalagenda-hijacks-dietary-guidelines-comment-advisory-committee/ (accessed December 16, 2022).
128. Healthy, Hunger-Free Kids Act of 2010, S. 3307, 111th Cong., 2nd Sess., https://www.congress.gov/bill/111thcongress/senate-bill/3307/text (accessed December 16, 2022), and Dietary Guidelines for Americans, “Current
Dietary Guidelines,” https://www.dietaryguidelines.gov/usda-hhs-development-dietary-guidelines (accessed
December 16, 2022).

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