EQUITY COMMISSION

Shaping Change at USDA

2024

FINAL

REPORT

RECOMMENDATIONS MADE

TO THE U.S. DEPARTMENT

OF AGRICULTURE TO

ADVANCE EQUITY FOR ALL

www.usda.gov/equity-commission
Final Report | Page 1 

 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

Letter to the Secretary 

February 22, 2024

Thomas J. Vilsack

Secretary, U.S. Department of Agriculture 

1400 Independence Ave., SW 

Washington, D.C. 20250 

Dear Secretary Vilsack:

The USDA Equity Commission recognizes the progress the Department has made in its 

commitment to equity since January 2021, when President Biden signed Executive Order 

13985 On Advancing Racial Equity and Support for Underserved Communities Through the 

Federal Government. In acknowledgement of this commitment, we appreciate the 

opportunity to make the enclosed recommendations to further advance equity at USDA. At 

the outset we must also acknowledge and express our gratitude for your personal 

commitment and actions to address equity issues at USDA. 

In preparation for this final report, the Equity Commission held six public meetings: 

• February 28, 2022

• May 10-11, 2022

• September 21-22, 2022

• January 31 – February 2, 2023

• June 27-29, 2023

• October 24-26, 2023

At each of the public meetings, input was gathered from the public through written and oral 

comments. The comments were shared with members of the Equity Commission for their 

consideration and are posted on the public Equity Commission website. 

Appendix A includes a list of USDA Staff from whom the Equity Commission members 

received briefings from during their tenure. 

Additionally, USDA provided a library of resources to the Equity Commission including 

relevant Executive Orders, American Rescue Plan documents, Government Accountability 

Office (GAO) Reports and Findings, USDA internal reports and findings, USDA advisory 

committee reports and findings, and USDA strategic plans and Equity Action 

Plans. Appendix B is a list of these resources. 

The attached final report includes our set of 66 recommendations, 32 of which were included 

in our interim report, and all of which were approved unanimously at the sixth public 

meeting. 

Our goal was not to duplicate the significant efforts already underway at USDA, but to 

identify additional steps for embedding equity into USDA’s policies, practices, and 
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processes. Many of the issues and recommendations we identified are not new. However, 

they will require renewed commitment from USDA to improve its customer-facing business 

processes and address historical inequities whose impacts continue to the present moment. 

Our recommendations are rightfully focused on underserved farmers, ranchers, rural 

communities, and other eligible USDA program recipients. We also strongly emphasize that 

our work is ultimately aimed at making USDA a better institution for every American. The 

Commission was unified in its view that the needs and concerns of farmworkers, immigrants, 

and their families are of vital importance to the highly productive and successful U.S. farm 

economy and rural development in general. Agricultural policy makers must begin to make 

consideration of these critical issues a regular part of their discussions going forward. 

Since the interim report, we have spent time researching and further refining 

recommendations while also working with the Rural Community Economic Development 

Subcommittee to develop an additional set of recommendations. It is an honor to be a part of 

this important work. 

On behalf of our fellow Commission members, we want to thank you again for the 

opportunity to help advance equity at USDA. 

Sincerely,

_____________________________ _____________________________ 

Ertharin Cousin 

Co-Chair, 

USDA Equity Commission

Arturo S. Rodríguez

Co-Chair, 

USDA Equity Commission 
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Equity Commission Members 

Asterisks (*) indicate Special Government Employees (SGE). SGEs provide temporary service to the 

Government, not to exceed 130 days during any period of 365 consecutive days with or without compensation.

• Shorlette Ammons*, Farm Aid

• Dr. Jewel Bronaugh, Former USDA Deputy Secretary (Co-Chair 2021-2023) 

• Todd Corley*, Carhartt 

• Ertharin Cousin, Food Systems for the Future 

• Derrick Johnson*, NAACP

• Yvonne Lee*,U.S. Commission on Civil Rights (Retired) 

• Elizabeth Lower-Basch*, Center for Law and Social Policy 

• Dr. Mireya Loza*, Georgetown University 

• Dr. Ronald Rainey*, University of Arkansas 

• Charles Rawls*, USDA (Retired)

• Dr. Hazell Reed, National Black Growers Council (Retired)

• Arturo S. Rodríguez*, United Farm Workers 

• Shirley Sherrod, Southwest Georgia Project for Community Education 

• Poppy Sias Hernandez*, State of Michigan 

• Rick Smith, Dairy Farmers of America (Retired)

• Toni Stanger-McLaughlin, Native American Agriculture Fund 

Agriculture Subcommittee Members

• Erica Lomeli Corcoran, United Farm Workers Foundation 

• Dr. Gina Eubanks*, Louisiana State University AgCenter 

• Janssen Hang, Hmong America Farmers Association 

• Phillip Johnson (P.J.) Haynie, III, Haynie Farms LLC 

• Savonala “Savi” Horne*, North Carolina Association of Black Lawyers Land Loss 

Prevention Project

• Michelle A.T. Hughes, National Young Farmers Coalition 

• Kari Jo Lawrence, Intertribal Agriculture Council

• Gary Matteson, Farm Credit Council 

• Dr. Alexis Racelis*, University of Texas Rio Grande Valley

• Russell Redding, State of Pennsylvania 

• Shari Rogge-Fidler, Farm Foundation 

• Dr. Jennie Stephens, Center for Heirs’ Property Preservation

• Sarah Vogel, Sarah Vogel Law Office 

Rural Community Economic Development Subcommittee Members

• Calvin Allen, MDC Rural Forward Initiatives 

• Valerie Beel, Valerie Enterprises LLC

• David Carrasquillo-Medrano, ¡Planifiquemos! 

• Shonterria Charleston, Housing Assistance Council 

• Nils Christoffersen, Wallowa Resources 
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• Cheryal Hills, Region Five Development Commission & North Central Economic 

Development Association 

• Larry Holland, Holland Hills Farm

• LaTonya Keaton, CoBank 

• Doug O’Brien, National Cooperative Business Association 

• Terry Rambler, San Carlos Apache Tribe 

• Lakota Vogel, Four Bands Community Fund 

• Curtis Wynn, SECO Energy 

Staff 

The Commission would like to express appreciation and gratitude to the Designated Federal 

Officer Cecilia Hernandez and the supporting staff. 

Federal Staff

• Catherine Doyle-Captiman (2023-2024) 

• Dallas Selle (2023-2024) 

• Tanika Whittington (2023-2024) 

• Jessica Medina (2023) 

• Karen Patyk (2023) 

• Laura Crowell (2022) 

• Courtney Niegocki (2021-2022) 

Contract Support Team – Star Cypress Partners

• Amanda Dell 

• Brittany Doucette 

• Heidi Jackson Everett 

• Nisha Galione 

• Margaret Graves 

• Zach Huebschman 

• Madison Loura 

• Elizabeth McDonald

• Marisa Rudolph 

• Linus Savage 

• Duane Tolson 

• George Logan Vega

• Beth Williams

• Lucy Williams
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Table of Contents 

I. Executive Summary....................................................................................................................... 8

II. Support of the Federal Government’s Focus on Equity .............................................................. 10

III. Historical Context ........................................................................................................................ 11

IV. About the Commission and its Subcommittees ........................................................................... 16

V. Goals of the Commission and its Subcommittees....................................................................... 17

VI. Commission Workplan ................................................................................................................ 19

VII. Promoting Accountability and Transparency: Compilation of Historical Recommendations .... 20

VIII. Advancing Department-wide Equity ........................................................................................... 21

Recommendation 1: Institutionalize Equity ..................................................................................... 21

Recommendation 2: Legislation to Ensure Accountability for Equity ............................................. 21

Recommendation 3: Elevate the Office of Tribal Relations ............................................................. 23

Recommendation 4: Language Access ............................................................................................. 23

Recommendation 5: Customer Experience ...................................................................................... 24

Recommendation 6: Annual Compliance Reviews .......................................................................... 24

Recommendation 7: Equity Audits .................................................................................................. 25

Recommendation 8: Office of the Assistant Secretary for Civil Rights ........................................... 25

Recommendation 9: Private-Public Partnerships ............................................................................. 26

Recommendation 10: Procurement .................................................................................................. 27

Recommendation 11: Biennial Research Report .............................................................................. 29

Recommendation 12: Strategic Outreach ......................................................................................... 29

IX. Working with Farmers and Ranchers Day-to-Day....................................................................... 30

Recommendation 13: Heirs’ Property and Fractionated Land ......................................................... 30

Recommendation 14: Land Access.................................................................................................. 31

Recommendation 15: Conservation ................................................................................................. 32

Recommendation 16: Technical Assistance and Outreach ............................................................... 33

Recommendation 17: Subsistence Farmers ...................................................................................... 35

Recommendation 18: Farm Service Agency Loan Programs........................................................... 35

Recommendation 19: Base Acres Modernization ............................................................................ 36

Recommendation 20: County Committees ....................................................................................... 37

Recommendation 21: Office of Small Farms ................................................................................... 40

X. Supporting Farmworkers and Their Families .............................................................................. 41

Recommendation 22: Staffing Farmworkers’ Work ........................................................................ 41

Recommendation 23: Interagency Farmworker Service Council ..................................................... 41

Recommendation 24: Farmworker Nutrition ................................................................................... 42
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Recommendation 25: Farmworkers’ Access to USDA Programs ................................................... 42

Recommendation 26: Funding for Farmworkers ............................................................................. 42

XI. Strengthening Research and Extension Programs........................................................................ 44

Recommendation 27: The Federally Recognized Tribal Extension Program .................................. 44

Recommendation 28: 1890s Institutions Matching Requirements .................................................. 45

Recommendation 29: Cooperative Extension Service Programming .............................................. 45

Recommendation 30: Cooperative Agreements and Competitive Grants ....................................... 45

Recommendation 31: Distinctions that Allow Access to Endowments and Appropriations ........... 46

XII. Ensuring Equitable Nutrition Assistance for Those in Need ....................................................... 47

Recommendation 32: Supplemental Nutrition Assistance Program (SNAP) .................................. 47

Recommendation 33: Thrifty Food Plan (TFP) ............................................................................... 48

Recommendation 34: Customer-Centered Service of the Supplemental Nutrition Assistance 

Program (SNAP) .............................................................................................................................. 48

Recommendation 35: Review of Vendor Access in Nutrition Programs......................................... 48

XIII. Recognizing Immigrants and Their Families ............................................................................... 50

Recommendation 36: A Pathway to Citizenship ............................................................................. 51

Recommendation 37: Right to Access Agricultural Land ............................................................... 52

Recommendation 38: Equitable Compensation and Protection for Agricultural and Food System 

Workers ............................................................................................................................................ 53

Recommendation 39: Equitable Access to Rural Housing Service (RHS) Programs ...................... 53

XIV. Revitalizing Rural America: A Path to Equitable Growth ........................................................... 54

XV. Enhancing Rural Development Operations .................................................................................. 57

Recommendation 40: Staffing ......................................................................................................... 57

Recommendation 41: Staff Skillset.................................................................................................. 57

Recommendation 42: Partnership Models....................................................................................... 58

Recommendation 43: RD State Advisory Committee ..................................................................... 59

Recommendation 44: Demographics of Funding/Lending Recipients ............................................ 59

Recommendation 45: Measures of Success ..................................................................................... 60

Recommendation 46: Environmental Justice ................................................................................... 61

Recommendation 47: Using Technology to Increase Access to Rural Development Programs ..... 62

Recommendation 48: Office of Coordinated Community Response ............................................... 63

XVI. Supporting Rural Communities ................................................................................................... 65

Recommendation 49: Housing as Infrastructure .............................................................................. 65

Recommendation 50: Program Standards for Single Family Housing ............................................ 66

Recommendation 51: Equitable and High-Quality Affordable Multi-Family Housing .................. 66
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Recommendation 52: 502 Loan Product .......................................................................................... 67

Recommendation 53: 504 Grant Program........................................................................................ 68

Recommendation 54: Broadband ..................................................................................................... 68

Recommendation 55: Improve Support for Underserved Communities Through Rural Utilities .... 69

Recommendation 56: Edge-of-Grid Lending ................................................................................... 70

Recommendation 57: Prevent Displacement through Equitable Land Zoning and Community 

Participation ...................................................................................................................................... 71

Recommendation 58: Expanded Financing Options for Community Facilities Projects ................. 72

Recommendation 59: Community Facilities Direct and Guaranteed Loan and Grant Program ...... 72

Recommendation 60: Removing Barriers for Community Facilities Direct and Guaranteed Loan 

and Grant Programs .......................................................................................................................... 73

XVII. Strengthening Rural Economies ................................................................................................. 76

Recommendation 61: Matching Waivers for RD Programs and Grants .......................................... 76

Recommendation 62: Rural Business Loans - Financing for Native Agricultural Producers by 

Microenterprise Development Organizations (MDOs) .................................................................... 76

Recommendation 63: Loan Loss Reserve Requirement ................................................................... 77

Recommendation 64: Equitable Lending Frameworks .................................................................... 77

Recommendation 65: Investing in Cooperatives.............................................................................. 78

Recommendation 66: Rural Energy for America Program .............................................................. 78

XVIII. Conclusion ................................................................................................................................ 80

Appendix A .......................................................................................................................................... 81

Appendix B........................................................................................................................................... 82

Appendix C........................................................................................................................................... 87
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USDA EQUITY COMMISSION

I. Executive Summary 

In the pursuit of a more equitable food, agricultural, and rural landscape, the USDA Equity 

Commission presents its final recommendations – a comprehensive guide for long-lasting 

change within USDA programs, policies, and procedures. Mandated by Section 1006 of the 

American Rescue Plan Act (ARP), as amended by Section 22007 of the Inflation Reduction 

Act (IRA), the Commission has systematically researched a plethora of documents, including 

historical reports and audits, analyzed hundreds of public comments, and engaged with 

numerous USDA leadership and program staff to develop a total of 66 recommendations. 

This final report marks the culmination of these efforts and builds on the Interim Report

findings submitted to Secretary Vilsack in February 2023. These recommendations, each 

approved unanimously by the Commission, outline actionable steps the Commission suggests 

both USDA and Congress take to address documented historic discrimination, eliminate any 

and all barriers to accessing Department programs, and ensure equity for all Americans 

touched by USDA. 

Informed by Executive Orders on racial equity and diversity (EO 13985, EO 14035), the 

Commission remains steadfast in guiding USDA’s efforts to address historic and current 

discrimination and promote equity. This final report serves as a roadmap for meaningful and 

lasting change, setting the stage for a more inclusive, just, and responsive USDA. The 

subsequent sections of this report provide detailed insights into the Commission’s mission 

and structure, historical context, and the 66 specific recommendations to the Secretary with 

justifications. 

The recommendations focus on the following areas for near and long-term action: 

1. Advancing Department-wide Equity 

2. Working with Farmers and Ranchers Day-to-Day

3. Supporting Farmworkers and their Families 

4. Strengthening Research and Extension Programs 

5. Ensuring Equitable Nutrition Assistance to those in Need

6. Recognizing Immigrants and their Families 

7. Enhancing Rural Development Operations 

8. Supporting Rural Communities 

9. Strengthening Rural Economies 

These recommendations represent the Commission’s interpretation of the priority issues 

affecting the equitable access and availability of USDA services and programs. The 

reexamination of past actions as well as briefings on the USDA present and ongoing 

Department-wide equity related changes informed the Commission’s critical and exhaustive 

review of existing USDA structures, programs, and services. The Commission recognizes the 

USDA is about the people – the tens of thousands of decent hardworking people serving 

within the Department and the millions served by the Department. The Commission was 

privileged to hear from many of those dedicated public servants throughout our work 

process. While acknowledging the positive ongoing efforts of this Administration, the 

recommendations reflect the Commission’s shared recognition that for too many Americans, 

the collective impact and compounding harm of inequitable past practices endure today. 
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Moreover, it is critical that the Department build the infrastructure for an equitable future, 

across leadership and administrations.

This Commission committed to and now proudly recommends sweeping and generational 

change. The recommended changes seek to interrupt the perpetuation of any and all USDA 

discriminatory and unfair systems, operations, policies and actions. Equity is not about one 

versus another; it is about ensuring ALL receive equitable treatment. The operational 

changes thoughtfully recommended by the Commission reflect our shared vision of “the 

People’s Department” – a just and equitable USDA at every level, across every agency now 

and for the future. The Commission hopes that Congress and the Department embrace the 

recommendations as a roadmap to that future. 
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II. Support of the Federal Government’s Focus on Equity 

In January 2021, President Biden signed Executive Order 13985 On Advancing Racial 

Equity and Support for Underserved Communities Through the Federal Government and 

committed to creating an Equity Commission as part of his rural agenda and commitment to 

closing the racial wealth gap by addressing longstanding inequities in agriculture. 

In March 2021, Section 1006 of the American Rescue Plan (ARP) (as amended by Section 

22007 of the Inflation Reduction Act of 2022) directed USDA to establish the Equity 

Commission and provided funds sufficient to ensure the Commission is well staffed and 

positioned to deliver on its charge. A report on the implementation of the ARP provides 

details on how each Federal Agency, including USDA, has taken steps to ensure that equity 

was part of the fabric of the program. Additionally, each Federal Agency was required to 

submit an Equity Action Plan to the White House.

To inform USDA’s Equity Action Plan, the Department issued a request for information

(RFI) on June 16, 2021, which sought information from the public to help identify 

opportunities in current USDA policies, regulations, and guidance that would be useful in 

addressing systemic inequities. USDA received more than 400 public comments from 

individuals, advocacy organizations, Tribal entities, state, and local governments, and more. 

These submissions informed USDA’s Equity Action Plan, published February 10, 2022, 

which states a clear and strong commitment to equity in the programs and operations of the 

Department, and provides a roadmap, in broad terms, for the equity work of the Department 

and each of its Agencies for the future. 

The Commission supports and applauds ongoing USDA Equity initiatives including, but not 

limited to:

• USDA Equity Action Plans 

• Mission Area and Program Initiatives 

• Diversity, Equity, Inclusion, and Accessibility (DEIA) Strategic Plans 

• Creation of a USDA DEIA Office and hiring of a Chief Diversity and Inclusion 

Officer

• ARP and IRA Funding and Implementation 
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III. Historical Context

The Commission applauds the recent Administration’s actions on equity to address historical 

and systemic discrimination. It is clear that Secretary Vilsack is striving to make USDA a 

leader in this challenging work. The Commission considers its primary equity charge to be 

forward looking: What data is useful to detect and document disparities in USDA programs 

and personnel so that it can move forward in a more equitable way? What barriers can we 

identify and eliminate to improve access and availability of USDA programs and services for 

all eligible Americans moving forward? 

Across America and many parts of the world, dedicated individual employees of USDA do 

important work to accomplish the Department’s many missions. A report on these various 

programs and activities and their successes would fill many volumes. USDA feeds millions 

of food insecure Americans every day, ensures a safe and wholesome food supply, provides 

clean water to thousands of rural communities, conducts vital research, provides critical 

solutions for plant and animal diseases, provides quantifiable soil and water conservation and 

forest management for a better environment, promotes markets for U.S. agricultural products, 

and provides stability and an economic safety net for America’s farmers and ranchers. 

USDA serves the American public every day in hundreds of ways. Therefore, it is vital that 

its programs are delivered equitably, efficiently, and fairly. Studies, listening sessions, and 

personal testimony informed the Commission, confirming that discrimination and unfair 

treatment has existed in numerous USDA programs—loans, grants, and services—as well as 

internally within hiring and promotion practices. Unfortunately, many inequities continue 

still today.

Historic injustices have created barriers to access to USDA programs which have caused 

present day challenges regarding wealth disparity, heirs’ property issues, lack of awareness 

and use of innovative technology, and relatively smaller farm sizes. Unfortunately, some 

individuals who have interacted with USDA have come away with the belief that 

discrimination, bias, or unfairness played a role in limiting their access to services and 

benefits. Such issues have been the subject of USDA Commission reports and class action 

lawsuits. 
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The United States has long recognized Tribes as sovereigns, negotiating numerous treaties 

and agreements in exchange for land and peace. Nearly 200 treaties have agriculture related 

provisions and include such things requiring the U.S. government to provide agricultural 

products and other assistance on farming. Throughout history, however, Federal laws and 

policies did not consistently foster a nation-to-nation relationship with Tribes. Tribal land 

loss is a staggering historical reality; it encompasses the reduction of lands originally 

possessed by American Indians and Alaska Natives from millions of square miles to roughly 

56 million acres—or about 220,000 square kilometers—managed in trust by the United 

States for various tribes and individuals by the dawn of the 21st century.1 This dramatic 

contraction signifies a loss exceeding 98 percent of their ancestral territories. Moreover, 

contemporary conditions reveal that a significant portion of Tribal agricultural land, totaling 

26.44 percent, is currently leased to non-native producers.2

Up until 1990, USDA informed Tribal communities that they should pursue Department of 

the Interior programs for conservation resources. In 1990, there was a Congressional 

directive for USDA to provide these funds and services across Indian Country. Historically, 

USDA policies and eligibility requirements often supported western models of agriculture 

and did not reflect Indigenous Knowledge or practices. For example, most Tribal lands are 

held by the federal government in trust for the benefit of a Tribe or Tribal members. USDA 

historically categorized these lands as “federal lands” and, therefore, were deemed ineligible 

for certain agriculture resources and grazing permits. Additionally, although Tribal and 

Native people were America’s first producers, their traditional practices and agricultural 

education was typically excluded from the national network of agricultural extension, as their 

academic institutions were not viewed as being included as land-grants until 1994. 

Since the founding of USDA, historical exclusionary practices and policies have 

disproportionately impacted minority groups. As a result, generations of these groups have 

been placed at a disadvantage. Several months after President Abraham Lincoln signed the 

legislation that created the USDA, he would issue the Emancipation Proclamation. And from 

the onset, USDA neglected to support aspiring African American farmers and rarely 

addressed the additional challenges they faced. From enslaved labor toiling on plantations to 

Black farmers who pushed for the unfulfilled promise of “40 acres and a mule,” African 

Americans have faced additional hurdles to participate in agriculture. 

1 U.S. Department of the Interior, Bureau of Indian Affairs. “Land Area of American Indian Reservations.” BIA Annual Report, U.S. 

Department of the Interior, 2021.

2 Village Earth. “Lost Agriculture Revenue Database: Quantifying Disparities in Agricultural Revenue on Native Lands.” Native Land 

Information System, July 16, 2022, https://nativeland.info/explore-topics/lost-agriculture-revenue-database/
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Beyond the creation of the USDA, President Lincoln deepened the nation’s commitment to 

agriculture by signing the Morrill Act in 1862 which would create the land grant college 

system focused on teaching agriculture through a three-pronged approach: teaching, research, 

and extension. And while the USDA supported research and teaching of agriculture at 

historically white land grant universities, they provided very little support to African 

American universities. It was not until 1890 that the Second Morrill Act selected and funded 

historically black colleges and universities to become land-grant institutions. Racially 

excluded from many farmer organizations, Black farmers created their own organizations 

during the late 19th century including Colored Farmers’ National Alliance and New Farmers 

of America (NFA) to keep young African American students invested and learn about 

agriculture. 

While the size of Black farmland grew from the 1860s-1920s, during the remainder of the 

20th century there was a rapid decline in both the number of Black farmers and their land. 

Public data provides irrefutable evidence that between 1910 and 1997 Black farmers lost 

nearly 90 percent of their valuable farmland (See Figure 1).3 The declining number of Black 

farmers and the loss of farmland is often erroneously framed as solely a result of the great 

migration and a declining interest within the Black community to farm. While Black farmers 

have lost their farms at a disproportionately higher rate than white farmers, it is also clear 

that farms across the nation have declined rapidly since the turn of the century. This decline 

is in no small part due to policies that have made it increasingly difficult for all small and 

mid-sized producers to compete. 

Figure 1. Farms by Race of Principal Operator, 1900 to 20224 

3 The issue of black land loss is pervasive, encompassing a broad range of factors and consequences throughout the United States (see 

generally Francis et al.). Francis, Dania V., et al. “Black Land Loss: 1920−1997.” AEA Papers and Proceedings, vol. 112, 2022, pp. 38-42. 

DOI:10.1257/pandp.20221015. 4 United States Department of Agriculture. 1840-2021. “USDA Census of Agriculture Historical Archive.” USDA Census of Agriculture 

Historical Archive. Washington, DC: United States Department of Agriculture. https:// agcensus.library.cornell.edu/. 

0 

1,000,000 

2,000,000 

3,000,000 

4,000,000 

5,000,000 

6,000,000 

7,000,000 

1997 2002 2007 2012 2017 2022

adj 

1900 1910 1920 1930 1935 1940 1945 1950 1954 1959 1964 1969 1974 1978 1982 1987 1992 1997

All farm operators White-operated farms Black and other races operated farms 
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Policies such as the Agricultural Adjustment Act (AAA) of 1933 led to the displacement of 

many Black tenant farmers and sharecroppers. AAA also gave local committees (also known 

as county committees) the power to implement policies, and these local committees, by and 

large, were composed of white farmers who had little to no interest in supporting Black 

farmers. Equitable representation of minorities on these influential committees that control 

access/eligibility to a number of USDA programs is a struggle that continues in 2024. AAA 

policies also favored large scale commercial farmers over smaller more diverse agricultural 

operations. Programs initiated by the AAA often failed to address the needs of Black farmers 

and exacerbated the disparities within the agricultural sector. Black farmers who participated 

in the civil rights movement often faced violence and intimidation tactics which also played 

out within county committees who withheld resources from Black farmers who called for 

social justice, civil rights, and political change. And many Black farmers documented their 

experience with discriminatory county committee practices by writing to USDA officials 

who too often ignored their requests and continued with the status quo. 

Additionally, well-documented data confirms the long-lasting impact of the Chinese 

Exclusion Act of 1882,5 Alien Land Laws and the internment of Japanese Americans during 

World War II which resulted in a loss of Asian agriculture ownership from the late 19th to 

mid-20th century. While difficult to quantify, the data also substantiates that inequitable 

practices have harmed the success and contributed to the loss of farms for Hispanic and 

Indigenous farmers. Anecdotal and recorded evidence substantiates the fact that limited 

access to credit and unreasonable bureaucratic requirements are persistent barriers to 

economic development and success for Native American and Native Hawaiian producers. 

Recorded data also verifies that the lack of access to language services, outreach, and 

nutrition programs negatively impact Asian American and Hispanic farmers and other 

immigrant farmworkers and their families.

When nearly all other American workers won the right to organize into unions, and to be 

paid a minimum wage and overtime under the New Deal in the 1930s, farmworkers were—

and remain—excluded. Economic benefits accrue to landowners as a result of exclusionary 

policies on health and workplace safety available to all other workers in the U.S. Undeniably 

there is a strong element of racial discrimination involved. While Hispanic farmworkers have 

dominated in the West and are now nationally disbursed, African American farmworkers 

were largely concentrated in the South. 

5 United States. Congress. “An Act to Execute Certain Treaty Stipulations Relating to the Chinese.” Enrolled Acts and Resolutions of 

Congress, 1789-1996, 6 May 1882, General Records of the United States Government; Record Group 11, National Archives. National 

Archives, www.archives.gov/milestone-documents/chinese-exclusion-act. 
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During the 1950s- ‘60s civil rights movement, Filipino workers joined the Agricultural 

Workers Organizing Committee founded by Phillip Vera Cruz, Larry Itliong, and other 

leaders. In 1965, they began the historic Delano grape strike and asked the Latino National 

Farm Workers Association, led by Cesar Chavez, Dolores Huerta, and Gilbert Padilla, to join 

them. The two unions merged in 1966 to form the United Farm Workers. The five-year grape 

strike and a three-year international boycott of California table grapes—backed by millions 

of consumers—convinced grape growers to sign their first union contracts in 1970, creating 

the first enduring farm worker union in U.S. history. Solidarity between the races was a key 

factor with little support from USDA on behalf of workers. 

This long history of systemic discrimination has left an indelible mark on many communities 

across the country. The “Get Big or Get Out” USDA mantra has pushed many programs and 

policies that have further strained marginalized communities and influenced our existing 

agricultural structure. In fact, since January 1981, 536,000 farms and 165 million acres of 

farmland have been lost.6 This trend cannot continue. To shape a better tomorrow, we must 

recognize the past and acknowledge the numerous practices and policies that have, 

intentionally or inadvertently, left many farmers, producers, and their communities at a 

disadvantage in the current American landscape. 

6 United States Department of Agriculture. 2022 Census of Agriculture: United States Summary and State Data, Volume 1, Chapter 1. 

National Agricultural Statistics Service, 2022. U.S. Department of Agriculture, chromeextension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.nass.usda.gov/Publications/AgCensus/2022/Full_Report/Volume_1,_Chapter_

1_US/usv1.pdf Accessed 19, February 2024.
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IV. About the Commission and its Subcommittees

The purpose of the Equity Commission is to advise the Secretary of Agriculture by (1) 

providing USDA with an analysis of how its programs, policies, systems, structures, and 

practices contribute to systemic discrimination, construct barriers to inclusion or access, and 

exacerbate or perpetuate racial, economic, health and social disparities, and (2) 

recommending corrective actions. The Equity Commission is subject to the requirements of 

the Federal Advisory Committee Act (FACA) and its membership and charge are established 

under a charter, as required by FACA.

The Equity Commission includes a Subcommittee on Agriculture, and a Rural Community 

Economic Development (RCED) Subcommittee (See Figure 2 below). The recommendations 

of the Agriculture Subcommittee in this report address issues and concerns specifically 

related to agriculture and conservation. The recommendations of the RCED Subcommittee 

address issues and concerns related to rural housing, rural utilities, and rural business and 

community development, persistent poverty, and underserved communities. 

Figure 2. Structure of the Commission and its Subcommittees

In September 2021, the Federal Register Notice called for nominations for the Equity 

Commission and its Subcommittee on Agriculture. Members were appointed by the Secretary 

in accordance with the membership balance plan in February 2022. Nominations for the 

RCED Subcommittee were solicited in the Federal Register in April 2022, with members 

named in August 2022. 

Under its charter, the duties of the Commission are solely advisory. Commission 

recommendations will aid USDA in achieving its goals by helping the Department improve 

access to programs and services for all Americans and serve all its diverse stakeholders with 

greater fairness and equity. 

Equity Commission 

(15 voting members, 

including 2 co-chairs) 

Subcommitee on 

Agriculture 

(13 non-voting members)

Rural Community 

Economic Development 

(RCED) Subcommitee

(12 non-voting members)
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

V. Goals of the Commission and its Subcommittees

Based on stakeholder engagement and former recommendations, the following goals for the 

Equity Commission and its Subcommittees were established by USDA. 

Equity Commission Goals: 

• Identify and recommend actions to remove barriers to equitable access and use of 

USDA programs, policies, systems, structures, and practices, including impediments 

that are internal, external, discretionary, or statutory. 

• Recommend actions and solutions that address racial equity issues, expand assistance, 

and provide support for historically underserved customers and communities needed 

for equitable access to USDA programs and services. 

• Recommend actions and solutions that address broader and more systemic equity 

issues at USDA.

• Recommend actions that will ensure USDA is a modern, competitive workplace with 

an organizational culture that prioritizes diversity, equity, inclusion, and access for its 

staff and customers alike. 

Subcommittee on Agriculture Goals: 

• Improve technical assistance necessary for navigating USDA programs and services.

• Improve access to capital.

• Improve access to programs and services related to agriculture and land use.

• Implement programs and services to mitigate effects of climate change, including 

improvements in risk management, conservation, and forestry programs.

• Address access to land, including financing programs and addressing unique issues 

related to heirs’ property, fractionated land, and other land access/retention issues.

• Increase market access to facilitate expanded access for value added opportunities 

(e.g., processing, trade, and marketing). 

• Enhance customer service via improved USDA staffing, training, and transformation 

of the organizational culture within USDA. 

• Review supporting functions such as county committees, conservation districts, and 

advisory boards. 

• Improve use of data and technology both to ensure access and to increase 

accountability. 

• Improve USDA performance measurement and program evaluation so that 

implemented recommendations can be monitored, tracked, and reported with real 

outcomes. 

• Make recommendations for ways to hold USDA accountable by requesting an 

implementation strategy and an action plan on recommendations. 
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USDA EQUITY COMMISSION

Rural Community Economic Development Subcommittee Goals: 

• Improve technical assistance, capacity building, and place-based economic 

development strategies necessary for navigating and accessing USDA programs and 

services. 

• Improve access to capital for business growth and development in rural and Tribal 

communities. 

• Improve USDA’s program delivery strategy to ensure investments are equitable now 

and into the future, including data-driven outreach and program design. 

• Reduce climate pollution, implement environmental justice standards, and ensure 

better management of natural resources. 

• Minimize disproportionate effects of climate change by increasing infrastructure 

resilience and economic support to rural and Tribal communities. 

• Improve access to high-speed internet for all rural and Tribal residents. 

• Ensure equitable access to safe, affordable housing. 

• Ensure equitable access to safe, affordable, and resilient water and wastewater 

infrastructure. 

• Improve equitable and sustainable access to natural resources, including recreational 

facilities.

• Enhance customer service via improved USDA staffing, training, IT modernization, 

and transformation of the organizational culture within USDA. 

• Improve use of data and technology both to ensure access to programs and services 

and to increase accountability. 

• Improve USDA performance measures and program evaluation so that the 

implementation of recommendations can be monitored, tracked, and reported with 

real outcomes. 

• Make USDA accountable by requesting an implementation strategy and an action 

plan on recommendations. 
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VI. Commission Workplan

The Equity Commission and Agriculture Subcommittee members were appointed and the 

first public meeting was held in February 2022. In accordance with FACA guidelines, the 

public was given the opportunity to provide comments for consideration to committee 

members in written and oral form. All public meetings were streamed virtually to allow 

maximum participation.

During the first public meeting the members were given their goals as stated above and 

subsequently grouped into three focus areas: Access, Service, and Performance. Following 

that meeting, members expressed the need to know where USDA implementation or 

consideration stood on the many equity-related recommendations that other committees and 

reports made over the years. In response, the Department started a Compilation of Historical 

Recommendations initiative based on relevant reports identified by the Commission. Further 

discussion of the initiative is included in Part VII of this report.

During the second public meeting held in May 2022, members received historical 

perspectives from USDA leadership and updates about current equity work being done at the 

Department. Members brainstormed a list of potential recommendations to explore further 

and collaborated on next steps for developing the Interim Report. Following the meeting, 

Farmworker, Nutrition, and Department-wide focus areas were added and subsequent 

workgroups were formed to align to the themes. Additionally, an Interim Report writing team 

was formed leveraging the varied expertise and stakeholder representation from the 

members.

During the third public meeting held in September 2022, members presented draft 

recommendations from the workgroups to ensure collective clarity and understanding of each 

recommendation. The Equity Commission members deliberated and voted on each 

recommendation to be included in the Interim Report. Other recommendations were deferred 

for further review and possible action during future meetings. 

During the fourth public meeting held in February 2023, members revisited the interim 

recommendations as some changes were made since the previous public meeting vote.

Members presented, deliberated, and voted to include the 32 recommendations within the 

Interim Report. One recommendation was tabled for further research and deliberation. 

During the fifth public meeting held in June 2023, members heard from USDA leadership on 

the implementation status of Interim Report recommendations. The RCED subcommittee 

members presented recommendations related to rural development, persistent poverty, and 

underserved communities. The Commission deliberated and voted to include an additional 22 

recommendations from the RCED in the final report. They tabled an additional three for 

further refinement and consideration. 

During the sixth public meeting held in October 2023, members heard from USDA 

leadership on the implementation status of interim recommendations. Members presented on 

new recommendations and refinements to previously passed recommendations. The

Commission deliberated and voted on 66 recommendations to include in the Final Report. 
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USDA EQUITY COMMISSION

VII. Promoting Accountability and Transparency: Compilation of 

Historical Recommendations

The recommendations of the Commission are forward looking. However, at the beginning of 

the Commission’s formation, members recognized the benefits of knowing the status of the 

various recommendations that have been made in the past on—or closely related to—equity 

issues at USDA. Reports dating back to 1965, beginning with the Equal Opportunity in Farm 

Programs Report, demonstrate concerns with inequality at USDA. In response, USDA staff 

supporting the Commission conducted a department-wide review process documented as a 

“compilation of historical recommendations” (CHR). 

The Commission received a preliminary briefing on the summary of findings of the CHR at 

its third public meeting in September 2022. As part of this effort, 748 historical 

recommendations from 11 reports were compiled by the staff into a single inventory and 

assigned to the relevant mission areas and agencies for review and comments related to 

implementation status. 

Recurring issues identified for the Commission included lack of workforce diversity, 

cumbersome program processes, lack of technical assistance, county committee adverse 

impacts, and civil rights accountability and program complaints. Common challenges or 

obstacles to implementing past recommendations included lack of clear USDA ownership 

and authority to act, budgetary resources needed for implementation, and the need for metrics 

to measure and track progress. The briefing also noted the lack of standardized practices that 

would enable USDA to systematically incorporate stakeholder input, historical reports, and 

the outcomes of program evaluations into strategic planning, policy design, and regulatory 

development in a cohesive way. 

While not final, the Commission is grateful for the significant work produced by USDA, and 

for the cooperation demonstrated by the various offices and agencies that participated in the 

review. This effort will be an important legacy of the Commission.
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

VIII. Advancing Department-wide Equity

The structure of the Department and how it serves the Nation has changed significantly over 

time; however, some structures, policies and cultural norms have persisted that no longer 

serve the American people and in fact have perpetuated inequity or widened the gaps that 

existed among Americans over time. USDA is currently made up of 29 agencies spread 

across the United States and overseas, serving more than 4,500 locations. The Equity 

Commission recognizes and applauds USDA for restoring a standalone Office of Tribal 

Relations and appointing a Senior Advisor for Racial Equity in the Office of the Secretary. 

The following recommendations outline proposals for department-wide change that affects 

the Department’s structure, leadership responsibilities, and overarching accountability and 

data collection.

Recommendation 1: Institutionalize Equity 

Lasting and long-term organizational change requires consistent leadership attention, 

adequate resources, and accountability. The Equity Commission understands that USDA has 

experienced uneven levels of commitment and success related to equity over the years, 

especially across changes in administration. We are making this recommendation to 

establish leadership responsibility and organizational accountability within the Office of the 

Deputy Secretary to ensure that equity efforts are institutionalized throughout the 

Department.

1. Institutionalize equity within the Department to drive compliance, 

accountability, and culture change across all of USDA.  

a) Utilize existing leadership structures with line authority to provide consistent 

leadership attention for institutional change and organizational accountability.  

b) Task the Deputy Secretary, through a Departmental regulation, to review Agency 

equity plans and ensure, through the annual budget process, that those plans are 

faithfully carried out and senior executives are accountable for making 

measurable improvements in equity in programs and services.   

c) The Deputy Secretary should use any staff and resources under its control beyond 

the Mission Areas, including operational, budgetary, administrative, financial, and 

economic analysis functions to carry out these responsibilities.  

d) Support workforce diversity and cultural competency by enhancing and 

improving job descriptions and hiring requirements. This should include utilizing 

specialized experience and selective placement in recruitment actions to prioritize 

demonstrated experience with target populations, where applicable.  

e) Conduct an Annual Convening on Equity to have data available to inform the 

ongoing work of the Equity Commission.  

Recommendation 2: Legislation to Ensure Accountability for Equity

There have been many studies, reports, and recommendations over time across several 

groups outlining the need for change within USDA; however, the Equity Commission 

recognizes the need for a sustainable and consistent framework within USDA that is 

transparent to the public, USDA staff, USDA customers, and partners. 
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USDA EQUITY COMMISSION

For all equity efforts outlined in this report and those currently taking place across USDA to 

be successful, there is a need to enact legislation and policy to ensure that continued work 

towards equity in programs and services is a priority of USDA leadership over time. More 

importantly, USDA should be measured and held accountable for its progress against 

impacting populations most affected by unfair or inequitable programs, services, or 

practices. 

2. Support legislation to provide standing authority and accountability for the 

Secretary and senior leadership to carry out a continuous program to improve 

the equitable availability and distribution of services and program benefits to all 

eligible American residents. 

Key elements of the legislation would include the following:

a. The Secretary shall be responsible for directing and carrying out a continuous 

program to ensure all applicants and participants have equitable access to services 

and program benefits at USDA.   

b. The Secretary shall collect data, information, and conduct studies and analysis to 

understand and document the extent to which underserved communities are not 

participating equitably in the programs and benefits provided or administered by 

the Department, including those administered through state or local agencies, 

County Commissions, or nonprofit organizations. This shall include research and 

information sharing on the best ways to collect demographic information that do 

not rely on third-party visual observations, including both best practices for 

encouraging voluntary provision of demographic information and statistical 

methods to incorporate missing data. 

c. Use data to evaluate programs and policies to identify and understand 

communities in need, where the funding is distributed, and who benefits. 

Participants benefitting from funding distributions should align with communities 

in need so that the investing efforts effectively reduce disparities. 

d. The Secretary shall provide a publicly available annual report to Congress and the 

American public that provides details on the data collection and studies 

conducted, and the results thereof. The report shall also include discussion of 

efforts to implement necessary improvements to equity so identified, including 

metrics and timelines.   

e. Performance evaluations of Agency heads and senior executives shall reflect an 

individual’s appropriate and direct efforts to improve equity in the programs and 

services within their span of control or authority.   

f. If the Secretary identifies an opportunity to improve equity in a particular 

program or service but lacks authority to make the necessary changes, Congress 

shall be notified and provided a recommendation for a legislative change. If the 

Secretary identifies the need for additional resources to improve equity, Congress 

shall be notified and provided an explanation of the needed resources.  

g. Revise definitions as needed: Such as “Equity,” “Equitable,” and “Underserved 

Communities” as defined from the Executive Order. 

h. Funds and staff required to implement these provisions shall be from within 

existing budgets and appropriations.  
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

Recommendation 3: Elevate the Office of Tribal Relations

The Equity Commission agrees with a repeated recommendation from the 2021 RFI (Request 

for Information) Listening Sessions about the need for USDA to respect Tribal nations’ 

sovereignty. By elevating the Office of Tribal Relations to the Assistant Secretary level and 

providing dedicated resources, USDA can strengthen the Nation-to-Nation relationship with 

Indian Tribes and help improve support for Tribal ownership, protection, and conservation 

of land. In addition, the Tribal Liaison positions throughout USDA should have direct access 

to senior decision-makers in their agencies and mission areas or offices and, moreover, be a 

combination of both career and appointed positions to ensure appropriate oversight and 

continuity over time.7

3. Elevate the Office of Tribal Relations from its current office to become The 

Office of the Assistant Secretary of Tribal Affairs.  

a. Establish the Assistant and Deputy Assistant Secretary of Tribal Affairs 

positions. 

b. Align or create Tribal Liaison positions within each Agency, Mission Area, and 

Offices that have access to the highest ranking official within those areas; some of 

these positions already exist, some may need to be created, some should be 

elevated within their area to serve as the highest ranking official or career leader 

(example: Senior Executive Service [SES], Assistant Secretary, Administrator or 

Chief). These positions should also have the authority to coordinate and work 

with the Office of Tribal Relations or newly elevated Office of the Assistant 

Secretary of Tribal Affairs. 

c. Dedicate a Tribal Affairs attorney (GS-15 or SES) within the Office of General 

Counsel (OGC) to act as a support for the office and Agency-level Tribal 

Relations staff. 

Recommendation 4: Language Access 

The Equity Commission recognizes language as a barrier for linguistically and culturally 

diverse communities trying to access USDA programs and services. It also recognizes 

language access as a key element of the U.S. Department of Justice Policy Guidance 

“Enforcement of Title VI of the Civil Rights Act of 1964 - National Origin Discrimination 

Against Persons with Limited English Proficiency” (LEP Guidance). The Commission 

appreciates USDA’s release of an updated Language Access Plan on November 15, 2023. By 

adhering to these policies and improving language accessibility, USDA can become a more 

equitable, inclusive, and culturally competent Department.

4. Ensure equitable language and culturally competent access to USDA services.  

a. Designate an executive level career staff member to be responsible for Language 

Access guidance, compliance, and oversight.  

7 Native Farm Bill Coalition. “Legislative Proposal for Exempting the USDA Assistant Secretary of Tribal Affairs from Senate

Confirmation.” Native Farm Bill Coalition’s Recommendations for the Upcoming Farm Bill. Native Farm Bill Coalition, 2023. The Native 

Farm Bill Coalition intends to propose legislative amendments in the upcoming Farm Bill, advocating that the position of Assistant 

Secretary of Tribal Affairs within the USDA should not require Senate confirmation. This move aligns with changes to other federal 

positions, simplifying the appointment process and potentially allowing for a more efficient response to the needs of Tribal nations. The 

Coalition’s goal is to streamline the integration of Tribal insights into agricultural policy-making and reinforce the government-togovernment relationship between the United States and Tribal nations. Currently, the following Presidential Nominations that no longer 

require Senate Confirmation within USDA are Assistant Secretary for Administration, Department of Agriculture, Rural Utilities Service 

Administrator, Department of Agriculture and The Directors (7) of the Commodity Credit Corporation. 
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USDA EQUITY COMMISSION

b. Cultivate a sustainable department-wide culture of equity and inclusion by 

investing in long term financial partnerships with women and Black, indigenous, 

and people of color (BIPOC) servicing educational institutions and Tribal, 

territorial and community service organizations to build Language Access 

capacity for current and next generation of agricultural partners, farmworkers, 

agricultural workers, stakeholders, and department workforce. 

c. Increase funding for technical assistance to be linguistically and culturally 

appropriate and invest in local community serving organizations and communities 

through cooperative agreements with tribes, acequias, and organizations. 

Recommendation 5: Customer Experience 

The Equity Commission has identified the need for USDA to improve its customers’ 

experience and establish consistent and high-quality service across all agencies. By 

institutionalizing a routine, robust, and coordinated customer feedback loop into USDA’s 

programs and services, USDA can improve its efforts to provide more equitable and 

consistent services to all individuals that seek service from and engage with USDA.

5. Improve Customer Experience through institutionalizing customer feedback, 

service delivery, and program design. 

a. Establish an enterprise-wide feedback loop for all USDA agencies and offices to 

hear from stakeholders through multiple mechanisms such as evaluations, 

surveys, dial-in calls, QR Codes, newspaper advertising, radio, etc. 

b. Ensure feedback opportunities and responses are provided in multiple languages. 

c. Provide specific feedback opportunities for individuals with lived experience and 

compensate them for their time and expertise. 

d. Train USDA staff to be culturally sensitive, understand their constituents and 

include community-based organizations in USDA language contracts to interpret 

and translate with more accuracy and cultural competence. 

e. Increase staff knowledge of farmer and rancher customer profiles to adequately 

match relevant services and programs with USDA’s customers. 

Recommendation 6: Annual Compliance Reviews 

The Equity Commission supports the USDA’s adherence and execution of Section 14006 of 

the Food, Conservation, and Energy Act of 2008 (2008 Farm Bill) that mandates USDA 

prepare an annual report on each of its agencies’ civil rights complaints, resolutions, and 

actions. By designating a responsible party for administering reports, providing the related 

data to inform compliance and customer service, and authorizing funding to conduct audits, 

USDA can increase trust, transparency, and accountability to its stakeholders.

6. Fund, establish, and maintain accountability for the execution or conduct of 

annual civil rights compliance reviews across all USDA agencies. 

a. Complete and execute annual civil rights compliance reviews across all USDA 

agencies as mandated by the 2008 Farm Bill (section 14006), starting FY 2023. 

b. Ensure reports and related data are accessible to the public and shared with 

Congress.  
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

c. Designate a responsible party for administering reports by the end of each fiscal 

year.   

d. Annually collect and publicly report program application and participation data 

for socially disadvantaged farmers or ranchers. 

Recommendation 7: Equity Audits 

The Equity Commission reviewed reports and stakeholder input that detailed problems with 

the program complaint system such as the timeliness, complexity, and lack of transparency of 

the results of audits and reports. The Commission agrees with the 2021 Office of the 

Inspector General (OIG) determination that USDA needs to develop a stronger internal 

control environment over its civil rights program complaints processing to ensure that 

complaints and findings are timely, appropriately handled, and made publicly available. By 

complying with the existing statutory audit requirements, USDA can leverage targeted 

research and analysis of existing publicly available data to identify and address patterns of 

complaints, discrimination, and systemic issues.

7. Under existing authorities, conduct periodic system-wide audits to look at equity 

across USDA’s services. Publish results on the USDA website and release 

underlying data to independent researchers. Analyze program complaints and 

make use of findings.  

a. Hire a third party to conduct an analysis of all program complaints received over 

the past five years and identify patterns for complaints, looking for programs, 

specific offices, and types of discrimination that have been alleged. These patterns 

should be used as a basis for identifying immediate fixes that can be made (e.g., 

making buildings and websites accessible, translating materials into additional 

required languages), prioritizing audits and statistical analysis of disparities in 

services received.  

b. Conduct periodic audits across USDA system-wide to look at service of 

underserved customers. Publish results on USDA website. Release underlying 

data (with personally identifiable information removed) for independent 

researchers to replicate and build on official audits.  

Recommendation 8: Office of the Assistant Secretary for Civil Rights 

The Office of the Assistance Secretary for Civil Rights (OASCR) has received much attention 

through testimony and reports from organizations such as the U.S. Commission on Civil 

Rights, U.S. Equal Employment Opportunity Commission, USDA’s Office of Inspector 

General, and the Government Accountability Office. The Equity Commission notes that 

oftentimes relief is found through class-action lawsuits versus working through the OASCR 

process due to backlog, capacity issues, and lack of expediency. Concerns persist around 

addressing backlogged complaints, processing times of incoming complaints, and capacity 

and staffing within OASCR. Ensuring program participants can effectively navigate the 

complaint process and receive timely resolutions will be instrumental in USDA’s ability to 

achieve its equity goals. 
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USDA EQUITY COMMISSION

Customers of USDA must have immediate access to a fair and workable solution for 

addressing perceived discrimination and filing civil rights issues within USDA. We applaud 

the recent advancements and innovations advancing customer service within the OASCR 

such as successfully eliminating the backlog of program complaints and establishing a new 

processing timeframe to ensure complaints are addressed in a timely manner. In order to 

continue building trust among customers across USDA, those advancements must be 

continued. We hope that continued efforts will seek to expand options for farmers/ranchers to 

seek clear and efficient resolutions to their grievances. 8

8. Transform and adequately fund the Office of the Assistant Secretary for Civil 

Rights (OASCR). 

a. Allocate necessary funding to ensure OASCR capacity to deal with ALL civil 

rights violations in a timely manner. 

b. Provide adequate funding and resources to OASCR so they can process customer 

cases within 180 days. 

c. Explore alternative program complaints models, including changing rules and 

regulations (consider using parts of the National Appeals Division as a model). 

Recommendation 9: Private-Public Partnerships 

The Equity Commission supports increasing the role of the private sector in advancing 

farming and agriculture programs. By piloting “private-public” partnerships, with 

organizations that have strong DEIA plans on file, both USDA and the partners can benefit 

from mutual learning and expanded access to capital with the intention of building out 

programs that garner longevity and sustainability for communities served.

9. Enhance private-public partnership authorities that empower program leaders 

across thousands of offices and in headquarters to pursue innovation 

independently and rapidly, but with a central mechanism to manage funding, 

monitor results, and disseminate and scale best practices to create a shared 

responsibility. Such an authority can be established as a new program through 

Congress and Secretarial authority, and/or by leveraging existing authorities. 

The Secretary shall explore opportunities to: 

a. Pilot a “private-public” partnership whereby the private sector partner (with more 

than 1,000 full-time employees) matches at a minimum of $20,000 per award 

from USDA to a nonprofit or community-based organization that is serving 

members of a distressed community and has a diversity, equity, and inclusion plan 

on file with USDA’s office of equity. Prior to the partnership, private sector 

partners will be evaluated for credibility by way of interviews and any other 

necessary avenues. Nonprofit or community-based organizations may also be 

evaluated on credibility and commitment to serving distressed communities. 

b. Pilot a “private-public” partnership whereby the private sector partner (with more 

than 1,000 full-time employees) matches each $20,000 award from USDA to a 

nonprofit, community-based organization or college/university that is helping 

8 Discussed at length during USDA Equity Commission public meetings was the proposal for an integrated dispute resolution process. This 

streamlined approach would combine NAD, OASCR, and mediation methods to enhance efficiency and fairness in handling civil rights 

claims, although a conclusive vote was deferred. 
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

farmers and ranchers create farm management plans that generate more output 

while conserving water resources and rebuilding soil health.   

c. Pilot a “private-public” partnership whereby the private sector partner provides 

financial assistance (e.g., renewable tuition-scholarship) to a scholarship fund to 

assist an admitted student attending a land grant university; federally designated 

Minority Serving Institution (MSI); or a Hispanic Serving Agriculture College 

and University (HSACU). USDA and said private sector partner will select the 

student recipients.  

d. Pilot a “private-public” partnership whereby the private sector partner is strongly 

encouraged to leverage its social media platforms to highlight their support of 

USDA programs and opportunities that advance equity; create brand 

activations/cause-related campaigns (e.g., “Giving Tuesday”) that increase public 

support and engagement for USDA programs and opportunities that advance 

equity; and promote existing and recognized efforts in the public sector, like 

Challenge.gov in order to stimulate innovative ideas and solutions. 

Additional opportunities USDA should consider:

e. Small Business Innovation Research (SBIR) – USDA, as a large Research & 

Development sponsor, posts hundreds of opportunities annually for small business 

participation. Thousands of companies across the U.S. have been created through 

SBIR, often in partnership with higher education. The Commission suggests a 

portion of SBIR funding be directed towards projects that impact the equity 

recommendations. 

Recommendation 10: Procurement 

The Equity Commission recognizes USDA’s supplier and procurement contracting programs 

are vital for small agriculture businesses to build on generational wealth and experience that 

could sustain and expand their businesses. Systemic racism and historical discrimination 

have excluded Native, BIPOC, and women owned agricultural businesses from accessing 

and qualifying for USDA programs. By focusing on procurement and supplier diversity, 

USDA can rectify the generational exclusionary practices that have effectively precluded 

disadvantaged businesses. Procurement systems and culture need to change simultaneously 

to ensure there is greater opportunity for funding organizations who are not historically 

funded each year. 

10. Establish a dedicated team within the USDA Office of Procurement and 

Contracting focused on procurement and supplier diversity, specifically 

collaborating with the socially and economically disadvantaged agricultural 

businesses from underserved and underrepresented agricultural communities. 

To build the requisite capacity and experience for equitable access to the 

USDA’s supplier and procurement programs: 

a. Create set-aside programs for minority, Tribal, and women-owned small 

agricultural businesses. 

b. Create a special 8(a) category for minority, Tribal and women farm, 

agricultural and food businesses by lowering the threshold for entry to the 

program. 
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USDA EQUITY COMMISSION

i. Provide technical and financial assistance to support socially 

disadvantaged small agricultural and food businesses to meet 

necessary standards toward successful participation to the 8(a) 

program. 

ii. Increase 8(a) set aside programs for qualified small agricultural 

businesses; partner with the SBA to explore ways to ease the entry 

criteria into the program for minority, Tribal and women owned 

farm/agricultural businesses. 

iii. Partner with nonprofit, community service organizations to provide 

technical assistance to support socially disadvantaged small 

agricultural and food businesses to qualify for the 8(a) program. 

iv. Collaborate with external stakeholder organizations to formulate a 

resource guide and host workshops to help them document their 

individual social disadvantage narratives. 

c. Establish limited competition programs within each of these categories. 

d. Incentivize major contractors to form partnerships with underserved and 

disadvantaged small agricultural businesses as subcontractors. 

e. Partner with the SBA to establish a database of minority, Tribal and womenowned small agricultural businesses who are eligible for subcontractor 

opportunities. 

f. USDA should enter a Memorandum of Understanding (MOU) with 

professional community organizations such as the National Minority Supplier 

Development Council to build up the base of Minority Business Enterprises 

(MBEs) in agriculture for government procurement. 

g. Create a federal advisory council specializing in small business and the 

agricultural industry. 

h. Update the Agriculture Acquisition Regulation (AGAR) to disqualify vendors 

with serious labor violations. 

i. Coordinate with the SBA to maintain an updated list of firms known to 

have breached workplace health and safety regulations, committed 

unfair wage practices, provided inadequate housing, and engaged in 

other unethical behaviors like child labor. Until these issues are 

addressed, these firms should be ineligible for government contracts. 

ii. Engage with the Interagency Task Force to Combat Child Labor 

Exploitation regardless of the child’s place of birth. 

i. Release and update a roster of eligible prime and secondary contractors from 

the USDA, detailing past awards. 

j. The USDA Office of Inspector General should implement a tracking system 

ensuring prime contractors collaborate with listed subcontractors post contract 

awards. 

k. The USDA Office of Ombudsman should curate a resource guide focusing on 

the confidential reporting of potential government contract abuses. This guide 

should accompany all published procurement and contracting opportunities. 

l. Initiate a 3-year pilot project within the Food and Nutrition Service (FNS). 

i. This project should select five municipalities based on their consumer 

and agricultural business diversities. These municipalities should 
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

commit that at least 25 percent of school meal and pantry program 

purchases come from local underserved agricultural businesses 

familiar with the cultural practices and dietary needs of their 

communities. By the project’s conclusion, the aim is for 50 percent of 

contract funds to benefit underserved and socially disadvantaged 

agricultural businesses. 

a. FNS should offer technical assistance, reimbursement 

flexibilities, and additional funding to address extra costs. 

b. FNS should collaborate with local or regional stakeholders, 

including agricultural businesses and community 

organizations, to pinpoint and assist qualified vendors. 

m. Annually release a report and maintain a publicly accessible live database that 

shows recipients of USDA funds. This database should be transparent, userfriendly, and should detail contract awards and financial distributions 

(subsidies, grants, etc.). Additionally, it should incorporate award information 

about both prime contractors and subcontractors. 

Recommendation 11: Biennial Research Report

The Equity Commission believes that the creation of a biennial research process assessing 

the state of BIPOC producers would offer tremendous insights into the impacts various 

policies, fundings and programs have on the viability of BIPOC producers. The intensity of 

focus would be on greater inclusion within agriculture and significant resources targeting 

BIPOC communities. This study would be undertaken by key organizations providing 

financing and capacity-building support, sharing field-based observations and quantitative 

assessments that could correlate to the efficacy of policies focused on creating an enabling 

environment for farmers of color, and providing an assessment of the progress as it pertains 

to financial and ecological outcomes, resulting from capital and resource allocations across 

public and private sector players.

11. Create and publish a biennial research report assessing the state of BIPOC 

producers focused on identifying insights into the impacts that USDA policies, 

funding and programs have on the viability of BIPOC producers.

Recommendation 12: Strategic Outreach

The Equity Commission has appreciated the transparency and frequency of the updates that 

USDA has provided regarding its efforts to advance equity. To ensure information about the 

initiatives, programs, and services have the greatest level of impact, the American public 

must know about the advancements being made. Dedicated outreach grounded in 

transparency and inclusion helps the USDA equip diverse constituencies to advance the 

mission of equity. Communication is not an afterthought, but an integral strategy to gain 

backing, expertise, and accountability as recommendations shift from words into civil rights 

in action. Intentional and continual public engagement will accelerate an arc towards 

justice.

12. Increase visibility of USDA’s equity-focused initiatives, programs, and services, 

designed to impact stakeholders, through coordinated marketing and strategic 

outreach activities. 
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USDA EQUITY COMMISSION

IX. Working with Farmers and Ranchers Day-to-Day 

The work of the Equity Commission is to address broad-reaching and systemic issues that 

prevent equitable access and use of USDA programs and services. The Equity Commission 

and Subcommittees focused several recommendations on supporting the farmers, ranchers, 

and producers that make up today’s agricultural industry. The Commission and 

Subcommittee on Agriculture were informed by the current USDA structures, policies, laws, 

lived experiences, and public comments submitted to the Commission or shared during 

public meetings to form the body of recommendations. Furthermore, the Commission was 

given preparatory briefings on the current ongoing USDA activities that promote equity in 

agriculture which include relending programs and other support for underserved farmers. The 

Commission applauds these efforts and offers the following recommendations to further 

advance equity for farmers, ranchers, and producers. 

Recommendation 13: Heirs’ Property and Fractionated Land 

The Equity Commission recognizes that heirs’ property, as defined in the Uniform Partition 

Heirs Property Act, and fractionated land are barriers that prevent historically underserved9

producers, farmers, ranchers, and other landowners from accessing USDA programs, such 

as loans offered by Farm Service Agency (FSA) and Rural Development (RD), and costshare programs offered by Natural Resources Conservation Service (NRCS) and the Forest 

Service (FS). Currently, the only USDA option for heirs’ property owners/producers to 

resolve their title issues to access USDA programs is the use of the loans through the FSA 

Heirs’ Property Relending Program (HPRP). The HPRP provides loans through third-party 

intermediaries such as community development financial institutions (CDFIs) that in turn 

makes loans to individuals to cover estate and/or succession plans and the cost to acquire 

legal counsel to resolve their title issues. Historically underserved/limited resource heirs’ 

property producers have difficulty receiving cost-share program funds from programs such 

as Environmental Quality Incentive Program (EQIP) and Conservation Stewardship 

Program (CSP), because they must compete with more experienced producers who have 

higher rankings. 

13. Provide non-loan options for producers to prevent the creation of heirs’ 

property and fractionated land that would reduce the barriers this type of land 

ownership encounters when accessing USDA programs.  

a. Appropriate funds for grants and cooperative agreements for community-based 

nonprofit organizations to address and resolve heirs’ property and fractionated 

land issues for underserved producers through the delivery of legal technical 

assistance, education, and drafting of estate plans. 

b. Provide multi-year grants and/or cooperative agreements to 501c3 organizations 

to deliver legal technical assistance and education that will prevent the creation of 

heirs’ property and remedy title issues which caused heirs’ property and 

9 The Agriculture Improvement Act of 2018 (2018 Farm Bill) outlines four groups defined by USDA as “Historically Underserved,” 

including farmers or ranchers who are: Beginning; Socially Disadvantaged; Veterans; and Limited Resource, socially disadvantaged, 

beginning, limited resource, and veteran farmers and ranchers. The Equity Commission acknowledges that the definitions as currently 

written in the Farm Bill and other USDA policy may add to existing barriers to access programs and funding and continues to assess this 

and other definitions related to requirements to access funds, programs, or services.
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

fractionated land. These 501c3 organizations must have at least five years of 

experience delivering legal services to indigent persons. 

c. Require all state Natural Resources Conservationists establish separate allocated 

funding of 10-15 percent of Environmental Quality Incentives Program (EQIP) 

cost-share funds for heirs’ property owners and socially disadvantaged producers 

(i.e., historically underserved minority producers). Currently, the requirement is 5 

percent, but these landowners must compete with the more experienced producers 

who will receive a higher-ranking score. Creating a designated funding pool 

allows for more equitable competition and increases chances that disadvantaged 

producers will receive funding. Currently, the state conservationists in Alabama 

and South Carolina have used their discretion to establish such a pool for these 

producers. 

Recommendation 14: Land Access 

The Equity Commission recognizes that USDA land-related programs have not been 

accessible to all, including farmers who are young, new and beginning; women; and BIPOC, 

and farmworkers. By funding community-led land access and transition projects, USDA will 

increase access to all farmers and ranchers, and increase engagement in programs and 

initiatives that can improve their land security, which is their greatest need to ensure a viable 

future for the agriculture industry. 

14. Ensure equitable funding to community-led land access and transition projects. 

a. Continue to direct funding to community-led land access projects designed to 

create land security for farmers. This USDA funding should be available to a wide 

variety of entities, such as tribes, municipalities, nonprofits, and cooperatives, 

with priority for projects led by and benefitting underserved farmers and ranchers. 

This funding should be available as a line of credit or grant prior to purchase, 

enabling eligible entities to act quickly in the real estate market.  

b. Amend and fund the Land Access and Farmland Ownership Data Collection Land 

Tenure data collection as authorized in the 2018 Farm Bill to require the National 

Ag Statistics Service to include in the Tenure, Ownership and Transition of 

Agricultural Land (TOTAL Survey) survey questions relating to which land is 

held in absentee ownership; and in heirs property land held in undivided interests 

and no administrative authority; and the impact of these farmland ownership 

trends on the successful entry and viability of beginning farmers and ranchers and 

the impact of land tenure patterns, categorized by race, gender, and ethnicity; 

and state, county and region.  

c. Amend and fund the Commission on Farm Transition established in the 2018 

Farm Bill to study land access and transition to inform policy setting that 

facilitates equitable access to land.   

d. Provide the Office of Tribal Relations (OTR) with the authority to immediately 

appoint a Designated Federal Officer from OTR to help facilitate the nomination 

process for seating the Tribal Advisory Committee authorized in the 2018 Farm 

Bill. This committee will provide advice to USDA on Tribal-related issues and 

policies throughout the Department.   
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USDA EQUITY COMMISSION

e. Increase investments in the Heirs’ Property Relending Program as the program 

grows and expand funding eligibility to include administration of program funds 

by relending entities.   

f. Provide direct family loans to close heirs’ property estates and be inclusive of 

legal costs.  

g. Maintain and expand the level of funding and technical assistance related to the 

Highly Fractionated Indian Land Loan Program, created by the 2014 Farm Bill.   

h. Engage with Indigenous10 and community-based organizations and other 

interested entities in ensuring that heirship issues also address “fractionization” 

issues that Tribal communities face.   

i. Ensure USDA land-related programs are accessible to all young, new and 

beginning, women, and BIPOC farmers specifically, and next generation farmers 

as a whole, by accommodating eligibility for collective, cooperative, and 

communal non-family entities, and tracking and publicly reporting demographics 

data on program participants.    

j. Provide continued funding for cooperative agreements with community-based 

organizations, such as the Natural Resources Conservation Service Cooperative 

Agreements for Racial Justice and Equity.   

k. Implement thorough racial equity informed evaluation and reporting requirements 

to not only measure who is benefitting, but also to measure program effectiveness 

in facilitating secure land tenure for young, new and beginning, women, and 

BIPOC farmers.  

Recommendation 15: Conservation 

The Equity Commission recognizes that USDA climate programs have historically targeted 

large-scale producers and have not supported traditional sustainable practices. By including 

equitable climate justice actions, USDA can ensure Indigenous practices are integrated into 

the Natural Resources Conservation Services’ (NRCS) sustainable agriculture programs and 

support smaller, non-traditional farmers in accessing Environmental Quality Incentives 

Program (EQIP) funding and other environmental programs. 

15. Include equitable climate actions in USDA conservation programs to address 

environmental justice.  

a. Increase incentive payments for implementation of climate-resilient practices to 

ensure limited-resource farmers can participate in cost-share programs. 

Automatically provide EQIP advance payments for historically underserved 

producers. The Commission recommends that NRCS reduce the required number 

of years a producer must be in production on a particular parcel of land to qualify 

for EQIP.    

b. Adjust EQIP and Conservation Reserve Program (CRP) practice standards to 

better integrate, and to equitably compensate for, the use of Indigenous 

knowledge and land management practices. Federal conservation programs 

should streamline support for producers embodying these practices, not create a 

10 Please note that within the United States, the terms "Indigenous" and "Tribal" carry distinct definitions and implications. When the term 

"Indigenous community" appears in this report, it should be interpreted in the context of the specific Tribal community it denotes. Each 

Tribal community operates as a sovereign nation with its own unique governance structures. The intent of this report is to bolster these 

Tribal governments, which hold the authority to represent their citizens.
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

barrier to accessing NRCS. The Commission recommends that USDA take into 

consideration non-traditional methods of agriculture (i.e., subsistence farming, 

aquaculture/fishing) for disaster relief purposes and other assistance programs 

offered by the Agency. 

c. Prioritize research that helps small-scale, diversified farmers implement climatesmart conservation practices and measure their climate mitigation impacts 

through methods with a proven track record of success, which should include 

traditional or historical agricultural practices.  

d. Increase funding for technical assistance to be linguistically and culturally 

appropriate and invest in local experts and communities through cooperative 

agreements with tribes, acequias, and other experts.  

e. Support climate justice solutions that target resources to women and BIPOC 

farmers and protect farmworkers from hazardous working conditions due to 

climate change.  

f. Require an analysis of the voluntary producer demographic data on an annual 

basis to identify any trends in the utilization of conservation programs by young, 

new and beginning, women, and BIPOC producers.   

g. Develop science-based climate-smart agriculture definitions that include Tribal 

Ecological Knowledge and further prioritize practices that afford the greatest 

climate benefit, such as incorporating cover crops, perennial crops, managed 

grazing of perennial pasture, and other investments in soil health. 

h. Codify the new Micro Farm program through the Risk Management Agency to 

improve access to crop insurance for operations that are diversified, organic, 

and/or selling in local, regional, and specialty markets. 

i. Expand direct marketing prices within the Noninsured Crop Disaster Assistance 

Program (NAP) or allow all farmers to use their own yields and historic pricing 

data to more equitably serve farmers who sell direct-to-consumer or receive a 

premium on their crops.   

j. Administer NAP as an on-ramp to more holistic risk management programs such 

as the Whole Farm Revenue Protection program and the Micro Farm program.   

k. Increase the maximum allowable farm revenue for historically underserved 

applicants to the Micro Farm program.  

l. Mandate NRCS provides the public with an impact report on how EQIP funding 

has been used, and the impact those dollars have had on the environment. 

Recommendation 16: Technical Assistance and Outreach

The Equity Commission has heard from multiple stakeholders that navigating USDA 

programs and services can be an impediment and, in some instances, impossible for certain 

stakeholders. By allocating funding for third-party organizations to provide technical 

assistance, mediation services, and/or legal services, USDA can ultimately help applicants 

get the tools and resources they need to submit competitive applications for programs.
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USDA EQUITY COMMISSION

Furthermore, the existing outreach and engagement structures in USDA across mission 

areas, offices, and programs need to have a centralized hub to better identify, reach, and 

align USDA programs and services with those stakeholders requiring technical assistance. In 

doing so, USDA will be better equipped to respond, cross-coordinate, and plan for ongoing 

stakeholder needs across mission areas, offices, and programs and provide stakeholders and 

customers a more seamless experience across USDA’s technical assistance portfolio of 

support.

16. Establish and/or ensure USDA’s external engagement office has the necessary 

capacity, resources, and skillsets to operate in a robust and centralized manner 

that will enhance the Department’s role and financial investment in 

organizations (nonprofit, non-governmental, community-based) to provide 

technical assistance.  

a. Increase the Department’s institutional bandwidth, both technically and 

financially, to increase support for young, new and beginning, small-scale, 

underserved, and specialty crop farmers.   

b. Invest in early mediation and technical services for farmers transitioning and 

accessing land, in particular Heirship and Trust or Restricted property.  

c. Develop and implement innovative, culturally responsive communication 

platforms and outreach strategies, including mobile technologies to engage young, 

new and beginning, small-scale, underserved, and specialty crop farmers on 

starting and maintaining a successful agricultural enterprise while facilitating 

strong, consistent connections with USDA personnel. 

d. Provide cooperative agreements to organizations offering effective agricultural 

business management tools, such as the Center for Farm Financial Management, 

to strategically engage in expanded, targeted outreach and offer technical 

assistance tools to young, new and beginning, small-scale, underserved, and 

specialty crop farmers. 

e. Develop a dashboard of nonprofit organizations and institutions of higher 

education that provide technical assistance to young, new and beginning, smallscale, underserved, and specialty crop farmers so USDA can provide information 

and updates to these entities as well as request for feedback on programs and 

potential opportunities to partner with USDA. 

f. Provide targeted technical assistance trainings and coaching to nonprofit 

organizations that serve underserved producer communities by focusing on 

understanding USDA grant programs, funding technical assistance efforts, and 

enhancing capacity to submit quality, competitive grant proposals. 

g. Provide technical assistance to USDA-funded, nonprofit organizations serving 

young, new and beginning, small-scale, underserved, and specialty crop farmers 

to increase their internal capacity for effective nonprofit organizational 

management. 
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

Recommendation 17: Subsistence Farmers 

The Equity Commission is concerned that the Census of Agriculture does not fully account 

for subsistence farmers who rely on trading and/or sharing resources. The current 

farmers/ranchers included in the census–whether rural or urban–count if $1,000 or more of 

agricultural products were produced and sold, or normally would have been sold, during the 

census year. The Native farming community believes that the Census of Agriculture data on 

Native farmers is incomplete, making policymakers and USDA staff believe the community is 

smaller than it is and therefore ineligible to receive program benefits. 

17. Direct the National Agricultural Statistics Service (NASS) to include the varying 

types of farmers and ranchers in the next Census of Agriculture to account for 

the nature of many traditional forms of how agriculture products are produced, 

sold, or exchanged. In addition, NASS should evaluate the threshold used to 

quantify a qualifying farmer and provide education on alternative forms of 

documentation that can be used for eligibility. The Secretary should also direct 

NASS to research and consider changing the definition of a farm.11 

Recommendation 18: Farm Service Agency Loan Programs 

Existing Farm Service Agency (FSA) loan programs and processes challenge the ability of 

underserved individuals to access credit. Because FSA is seen as an entry point for those 

seeking assistance from USDA, the Equity Commission believes that transforming FSA’s 

culture to a customer service centered approach will lead to increased access to capital for 

programs and services in a more equitable way. Responding to the borrowing needs of 

underserved individuals with clarity of eligibility, simplicity of process, flexibility in 

administration—all delivered in a timely manner—will further equitable engagement more 

than any other effort. 

18. Transform FSA into a customer service organization that provides equitable 

treatment for all. 

a. Examine FSA loan processes and use plain language and clearly describe 

eligibility criteria regarding loan programs and processes to improve equitable 

access to underserved populations of both new and experienced farmers and 

ranchers. 

b. Provide additional flexibility regarding the timing and processing of loans, 

including the ability to offer an initial statement of eligibility or accept 

preliminary paperwork before an application is submitted. Additional flexibility 

regarding loan terms and conditions should be available when structuring 

financial packages for underserved farmers and ranchers. 

c. Identify gaps between FSA loans and USDA grant programs intended for 

underserved populations to assure that Inflation Reduction Act (IRA) and USDA 

initiatives can be effectively combined to meet the needs of underserved 

individuals. 

11 The Council for Native American Farming and Ranching made this recommendation to the Secretary in February of 2013. 

“Recommendations from the USDA Council for Native American Farmers and Ranchers.” U.S. Department of Agriculture, updated June 

2018, https://www.usda.gov/sites/default/files/documents/cnafr-recommendations.pdf. 
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USDA EQUITY COMMISSION

d. Define “distressed borrower” to include those that have not yet entered 

delinquency yet are under financial stress that may prevent them from continuing 

farm operations.  

e. Develop cooperative agreements with community-based organizations who work 

as agents of and advocates for individual borrowers with their permission to allow 

examination of individual borrower applications and loan decisions. 

Recommendation 19: Base Acres Modernization

Through the course of its work the Equity Commission was made aware of instances where 

the implementation of agricultural programs was not done in a fair and careful manner to 

avoid discriminatory outcomes. For example, the Commission devoted significant energy to 

understanding how payments for “crop acreage bases” (CABs) or base acres has locked in 

historical inequities and discrimination, in ways that cause significant lasting economic 

harm to underserved producers. It is important to modernize base acres policies in ways that 

address disparities. 

Starting with the Agricultural Adjustment Act of 1933 (New Deal), USDA has deployed 

various strategies to subsidize farmers producing covered commodities. From the 1930s to 

the early 1990s, these payments were closely tied to the farmer’s production, a process which 

was largely monitored and regulated by the Farm Service Agency through county 

committees. In the 1996 Farm Bill (the Food, Agriculture Improvement and Reform Act), 

farm program payments were decoupled from actual plantings, instead based on the 

historical production. This system of paying farmers via crop acreage bases (CABs), which is 

the established acreage and yields of eligible commodities, has become an important part of 

an operation’s cash flow, especially in times of low crop prices or challenging production 

environments. CABs are used to calculate annual subsidies paid to producers and 

landowners (with crop share leases).  

The critical years for establishing these CAB components were 1981-1985, when farmers 

were allowed to report annual planted acreage and average yields, excluding the years with 

the highest and lowest yield. During this period, covered crops included wheat, corn, 

sorghum, barley, oats, upland cotton, and rice, and subsequent farm bills utilized these CABs 

as the foundation for making future payment modifications. The 2002 Farm Bill (Farm 

Security and Rural Investment Act) continued decoupled payments, but allowed soybeans, 

peanuts, and other oilseeds (sunflower, canola, rapeseed, mustard, flaxseed, Crambe, and 

sesame) to be added to uncommitted acreage. In nearly all cases, growers elected to add 

these oilseeds to eligible uncommitted acreage, a process which strengthened the safety net 

but did little to address disparities among producers. Subsequent opportunities to modify 

CABs provided some assistance, but still did not properly address large discrepancies, 

according to recent data.
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

USDA reports and congressional testimony have provided evidence of huge discrepancies in 

subsidies paid to underserved producers in comparison to their neighbors, with some reports 

showing them receiving only 20-25 percent of the per acre subsidies received by their 

neighbors. Admitted discrimination during the critical period (1981-1985) for establishing 

CABs likely played a role in certain farmers only being able to secure funding to produce 

lower yields of lower value crops. Farmers who were privy to loans were able to install 

irrigation, improve drainage, adopt technology, and make other infrastructure improvements 

that allowed them to increase yields, diversify crops, and expand acreage. Contrarily, many 

underserved farmers still operate acres that need improvements as they can only produce 

lower yields of lower value crops (e.g., winter wheat or oats and non-irrigated summer 

crops). The disparate annual subsidies, currently Agriculture Risk Coverage and Price Loss 

Coverage (ARC/PLC) payments, distributed annually only exacerbate these longstanding 

problems. 

19. Modernize base acre policies to address the concern of producers’ inability to 

receive necessary program payments that help stabilize on-farm revenue during 

economic downturns with commodity markets. 

a. Review base acre farm program payment calculations and consider redistribution 

of base acreage to address disparities among farmers. Determine commodity 

specific base acres on lands historically not included in the initial base acre 

establishment. 

b. Allow cost-shared improvements such as land leveling, installing irrigation 

systems, and providing resources to improve overall acre production to inferior 

base acres based on their base calculation and acreage discrepancies in 

comparison to neighboring farms to significantly inferior base acres in a 

prioritized format. 

c. Allow re-establishment of crop acreage bases (CABs) after improvements are 

completed. As an alternative, allow significantly inferior base acres to qualify for 

an annual revenue adjustment based on county or regional discrepancies. 

Recommendation 20: County Committees 

The Equity Commission heard powerful testimony that County Committees in many states 

have not fairly represented their minority farmers and ranchers. In addition, the Commission 

heard that the powers afforded to County Committees have in some cases resulted in 

decisions that have crippled the economic livelihood of minority farmers and ranchers. While 

County Committees have less authority than in the past, as an extension of the FSA, County 

Committees continue to advise and make policy decisions regarding income safety-net loans 

and deficiency payments, conservation payments, emergency programs, and incentive, 

indemnity, and disaster payments for certain commodities. The County Committee’s 

purpose, impact, and general efficacy has continued to be a point of research and reflection 

since its enactment via the Agricultural Adjustment Act of 1933 and throughout the series of 

congressional and legal adjustments made to their scope and operations via the Soil 

Conservation and Domestic Allotment Act of 1936 and subsequent Farm Bills (2002 and 

2008). Continued study and recommendations for reform have been documented in reports 

such as the 1996 D.J. Miller Report, the 1997 Civil Rights Action Team Report, and the 2011 

Jackson Lewis Report.
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USDA EQUITY COMMISSION

Despite the many past recommendations and attempts to alleviate the documented inequities 

associated with the County Committee’s election process and power, addressing County 

Committees continues to be a critical step in advancing equity in USDA’s programs and 

services.

By elevating the voice of minority advisors, bolstering the training of new County Committee 

members, and improving the appeals process, the Equity Commission aims to strengthen the 

accountability and transparency of County Committees. More broadly, the role of County 

Committees in today’s agricultural system should be reassessed and, if required, redesigned 

to ensure more equitable outcomes. 

20. Address historical and present-day inequitable services by making County 

Committees more equitable.

Training:

a. Require diversity training related to African American, Asian, Hispanic, 

American Indian, Alaska Natives, Native Hawaiian, and Pacific Islander issues 

where a high number of diverse communities exist.  

b. Include the appeals process and role of the minority advisor in training for new 

committee members.  

c. Train County Committees to exercise their voting powers and use the tools at 

their disposal to ensure members can vote without retribution or sense of 

retribution for voting actions.  

Representation:

a. Give current minority advisors the same voting rights and terms as elected 

members; where a minority advisor does not currently exist, the Secretary should 

appoint a minority VOTING member. 

b. Consider a minimum percentage of representation required that is reflective of 

population for County Committee member vote. For example, if 10 percent of the 

county population consists of minority farmers and ranchers, approximately at a 

minimum, 10 percent of the County Committee representation should consist of 

voting minority farmers and ranchers reflective of that population. 

c. Ensure equitable opportunities for individuals interested in serving on County 

Committees are available by reducing the complexities of the nomination and 

election process and increasing awareness about opportunities to serve on County 

Committees through multiple mechanisms, including but not limited to online 

outlets. Use the NASS Census outreach process as a way to notify all farmers of 

County Committee election and voting process and eligibility. 

d. Given the nature of Tribal Governments and their membership/citizenship, 

specific outreach should be created and implemented to provide awareness of the 

opportunity to serve through focused outreach.  

e. The Secretary should explore the feasibility to change the eligibility of County 

Committee elections to expand efforts and allow nominations from the following 

categories: 
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

i.Community-Based Organizations with relevant expertise 

ii.1890 and 1994 Land Grant Institutions 

iii.Hispanic Serving Agricultural Colleges and Universities 

Accountability:

a. Establish a USDA County Committee Liaison responsible for identifying and 

instituting diverse representation on County Committees. 

b. Increase transparency and accountability for County Committee staff by 

establishing performance metrics with controls and mechanisms to ensure they 

adhere to equitable standards and have access to USDA resources. The County 

Executive Director (CED) and County Committee staff should be subject to 

oversight and evaluation by FSA with civil rights, equity, and demographic 

indicators included as metrics. 

c. Immediately implement a process to ensure that County Committee minority 

advisors have access to the FSA Administrator to bring in real time issues or 

concerns within the county and an annual report or accounting to the 

Administrator on how that committee is operating.  

d. Provide more transparency on FSA elections by making reports and contact 

information available to the public in a timelier manner. Reports should include 

demographic information of the members. 

e. Conduct a biannual assessment on performance measures that indicate equitable 

outcomes for County Committees. Should the above recommendations not yield 

the desired equitable outcomes, conduct an external analysis and study on the 

equity disparities of the County Committees and a potential reform of the County 

Committee system to a more equitable alternative for ALL farmers. The analysis 

should include the current role of the County Committee creating disparities for 

women and BIPOC farmers, both the historical role of the County Committee 

system and the current displacement of women and BIPOC farmers.   

f. The Secretary shall establish at the federal level an advisory or support group 

composed of internal and external individuals to serve as advocates for producers 

to understand their complaint and appeals options. The group should establish 

standard operating procedures (SOPs) for County Committees including the 

preclusion of access to customer financial and sensitive information. The SOPs 

shall be made publicly available and updated annually. Performance metrics 

should be established and reviewed during the quarterly strategic reviews held by 

the Deputy Secretary. 

i.In order to enhance accountability, the County Executive Director should 

be hired by and report directly to the District Director. 

ii.The County Executive Director shall be prohibited from providing 

customer financial and sensitive information to the Committee members. 

iii.The role of the County Committee must focus on advisory activities 

particularly communicating local needs. The County Committee shall 

serve as the representative body for all farmers and ranchers. 
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USDA EQUITY COMMISSION

Recommendation 21: Office of Small Farms

Through the course of its work, the Equity Commission came to identify the disparity of 

USDA program benefits, research, conservation, and other support provided to small farms 

as a significant equity concern. By program design and implementation, large operations 

receive the vast majority of USDA resources. In January 1998, the USDA A TIME TO ACT: 

A Report to the USDA National Commission (1998 Commission) on Small Farms made eight 

recommendations to protect small farms. Yet there is little evidence that the 1998 

Commission’s recommendations have been implemented.

Small acreage farms are defined as those with fewer than 180 acres. The office would be 

tasked with: (1) Assessing the needs of small operations, evaluating the Department’s 

current ability to serve them, and recommending improvements to USDA program policies, 

design, and delivery. (2) Providing, or coordinating through cooperative agreements, direct 

technical assistance and/or grants of up to $25,000 to small farms for equipment, uninsured 

losses, business planning assistance, conservation practice adoption, down payments for 

land, and more.

This focus would be a win‐win‐win: it would help the Department better accomplish its 

mission of serving farmers of all types and scales, ensure that small-scale farmers can 

benefit from the full suite of USDA programs, and help secure a more resilient food system 

for all Americans.

21. Create an Office of Small Farms focused on small farms with gross sales under 

$250,000. The office would be located within the Farm Production and 

Conservation (FPAC) Mission Area to include liaisons from other relevant 

Mission Areas/Agencies. The Office of Small Farms should help ensure that 

small farms, ranches, and forest operations have full access to USDA programs.
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

X. Supporting Farmworkers and Their Families

The Commission and Subcommittees recognize that among the most vulnerable populations 

within the agricultural sector are farmworkers and their families. Farmworkers are often not 

directly served, protected, nor eligible for programs, services or benefits provided to the 

larger agricultural community. This is due to factors including immigration and labor laws, 

inequitable structural incentives and barriers, and lack of focus on improving inclusion. New 

vulnerabilities of agricultural jobs due to the increasing impacts of climate change are also a 

significant challenge for farmworkers and their families. Farmworkers are disproportionately 

people of color. The Commission commends USDA for their recent initiatives that provide 

support and financial relief to farmworkers such as the Farm and Food Workers Relief Grant 

Program. The Commission and Subcommittees propose the following recommendations to 

enhance support to farmworkers and their families. 

Recommendation 22: Staffing Farmworkers’ Work 

The Equity Commission recognizes that USDA has not treated farmworkers consistently as a 

specific constituency over time. By funding and elevating roles for professional staff 

dedicated to farmworkers, USDA can drive coordination, compliance, and culture change at 

a systems level to protect farmworkers from inequities. Although there is currently a position 

for a Farmworker Coordinator, it has not been adequately funded and sustained. 

22. Institutionalize equity compliance and culture change across all of USDA by 

appointing a senior official with dedicated staff (career or political) with 

decision-making authority and access to senior level officials and the resources 

needed to serve farmworkers, their families, and the organizations that serve 

them. The senior official would serve as the USDA representative to interagency 

workgroups regarding farmworkers and associated issues.  

Recommendation 23: Interagency Farmworker Service Council 

The Equity Commission recognizes the value and need for farmworkers to be consistently 

recognized as a specific constituency within intergovernmental processes, programs, 

services, and policies. Establishing an Interagency Farmworker Service Council will help 

USDA drive accountability, coordination, compliance, and culture change at a systems level 

to protect farmworkers from continued inequities.

23. Issue a recommendation from the Secretary that the White House pursue the 

establishment of an Interagency Farmworker Service Council for infrastructure 

coordination on intergovernmental work processes. The Council should be 

convened by USDA and include the Department of Health and Human Services, 

the Department of Labor, the Department of Education, the Environmental 

Protection Agency, the Department of Homeland Security, the Department of 

Justice, the Department of Treasury, and private sector partners.  
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USDA EQUITY COMMISSION

Recommendation 24: Farmworker Nutrition

The Equity Commission recognizes that many farmworkers and their families have incomes 

under or near the federal poverty line and experience food insecurity. By improving 

language access, developing targeted outreach, and making distribution programs and 

application sites more accessible, USDA can ensure farmworkers and their families are able 

to access nutrition programs available to them.

24. Ensure farmworkers and their families have access to all USDA food and 

nutrition programs.  

a. Improve language access.   

b. Mandate creation and distribution of targeted outreach materials with a required 

annual cadence for updating and distributing. 

c. Develop inclusive and accessible distribution programs and application sites.  

d. Ensure farmworkers and their families are encouraged to apply for and receive 

nutritional supports by not requiring a social security number. 

Recommendation 25: Farmworkers’ Access to USDA Programs 

The Equity Commission recognizes that farmworkers have been underrepresented and 

underserved by USDA. By requesting, supporting, and analyzing data and reports, USDA 

can better understand the needs of farmworkers to improve working conditions and create 

potential pathways for them to transition from farmworkers to farmers.

25. Direct the USDA Office of the Inspector General (OIG) to conduct a report or a 

joint report from USDA and Department of Labor (DOL) on farmworker living 

and working conditions that are essential to understanding the needs of 

farmworker populations. The report shall also look at farmworker access to 

USDA programs. OIG and DOL should consult with farmworker organizations 

and farmworkers themselves, and they must use innovative research methods to 

ensure anonymity, accurate data, and protection against retaliation.  

a. The report should be funded, conducted, and published bi-annually to ensure 

compliance and systems level changes for farmworkers, their families, and 

organizations.  

Recommendation 26: Funding for Farmworkers 

The Equity Commission recognizes farmworkers face widespread violations of the few rights 

they possess, high injury and fatality rates, and poverty, including food insecurity. By 

prioritizing farmworkers in USDA’s programs, policies, and resources, USDA would help 

not only farmworkers but also provide broader societal benefits, including improved food 

safety, healthier and stronger rural communities, and a level playing field for law-abiding 

employers. 

26. Pursue legislation and utilize existing authority to ensure funding that benefits 

farmworkers and their families. 

a. Support an initial minimum funding of $5 billion for farmworker organizations to 

improve farm labor working conditions, labor protections, healthcare, wages, 

access to justice, supply and stability, services, and safety and training.     
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b. Leverage existing and ongoing funding and resources to promote improved 

farmworker living and working conditions, workplace safety compliance and 

farmworker economic opportunities through funding opportunities, funding 

requirements, penalties, and incentives.   

c. Ensure that spending for employer grants and procurement promotes improved 

farmworker living and working conditions by requiring that employers throughout 

the supply chain demonstrate labor law compliance and meet “high road” 

workplace standards, such as collective bargaining and other metrics for improved 

workplace protections, to qualify for such funding or procurement. 

d. Take action to ensure that additional funding opportunities such as existing and 

ongoing grants or other programs include requirements and incentives regarding 

farmworker living and working conditions.  

e. Take executive action to ensure funding for farmworker organizations to help 

ensure improved farmworker working and living conditions and to ensure 

farmworker access to economic opportunities.   

f. Ensure that farmworkers, their families, and their organizations are equally 

included in any funding intended to address the impact of pandemics, natural 

disasters, and climate change, including extreme weather, wildfires, droughts, 

etc. 

g. This recommendation is intended to support farmworkers and their organizations 

and not farm labor contractors. 
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XI. Strengthening Research and Extension Programs 

Research and Extension USDA coordinates and conducts research, education, and extension 

with scientists and researchers across sectors including the Federal Government, universities, 

and private partners. The 1862 Morrill Act created the original land-grant colleges and 

universities with a mission to provide agricultural education for the working class. While this 

legislation did not explicitly discriminate by race, many of the institutions in practice were 

white only, and it is undeniable that the benefits of land-grant institutions excluded people of 

color for generations. In 1890, a second round of land grant institutions– Historically Black 

Colleges and Universities – were funded. Tribally controlled colleges did not receive land 

grant funding until 1994. However, historically, 1890 and 1994 minority-serving land-grant 

institutions have not received USDA funding comparable to 1862 land-grant colleges and 

universities. The Commission applauds the recent investment of over $21.8 million to build 

the capacity of 1890 Historically Black Colleges and Universities (HBCUs) in the land-grant 

network to deliver innovative solutions that address emerging agricultural challenges 

impacting diverse communities. The following recommendations aim to strengthen research, 

extension, and teaching in the food and agricultural sciences at all minority-serving 

institutions across the country. 

Recommendation 27: The Federally Recognized Tribal Extension Program 

The Equity Commission understands that one of the most significant inequities faced by 

Tribal producers is a lack of access to technical assistance when compared to other 

producers. The land grant extension system, meant to serve all producers, has historically 

left Tribal producers behind. The Federally Recognized Tribal Extension Program (FRTEP) 

was created to solve that issue; however, the program has not had an influx of funding since 

1990, and although the 2018 Farm Bill did add 1994 Tribal Colleges and Universities as 

eligible sites for FRTEP, no new funding came with this. Currently, 38 FRTEP agents across 

the country are intended to serve as many as 2,000 producers per person, while their 

counterparts in the land grant extension system each serve approximately 200.12 This results 

in inequitable service to Tribal producers. The Commission recommends USDA allocate a 

set aside, using a similar formula method used in County Extension, for the FRTEP to bring 

equity between the extension programs. 

27. Seek increased funding for the Federally Recognized Tribal Extension Program 

(FRTEP) and remove the competitive nature of the current application process 

to allow for more collaboration across Tribal extensions.  

a. Increase funding for the FRTEP program to $50 million. The current funding 

requires FRTEP agents to serve as many as 2,000 producers per person, while 

their counterparts in the land extension program only need to serve 200. The 

competitive funding is static for FRTEP and the 1994s. As new programs 

compete and are added, all existing programs in Tribal Nations suffer from further 

reduced funding. This type of competitive funding is not found in County 

12 Holden, Lexie. “Advocating for the Federally Recognized Tribes Extension Program.” National Hunger Clearinghouse, National AntiHunger & Opportunity Corps, 2021, www.hungercenter.org/wp-content/uploads/2021/03/Advocating-for-the-Federally-Recognized-TribesExtension-Program_Lexie-Holden_NAAF.pdf. 
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Extension programs. County Extension is based on a formula, and we recommend 

Tribal extension be based on this formula. 

Recommendation 28: 1890s Institutions Matching Requirements 

The Equity Commission recommends USDA address the historical inequities in funding 

provided by the 1862 and 1890 Morrill Acts to make agricultural research, outreach, and 

technical assistance more equitable. The Commission recognizes the need to make the 

matching requirements consistent across institutions and address the fact that the 1890 

institutions never received their equitable allocation of land, the primary funding mechanism 

for the institutions. The Commission appreciates the letters sent from Secretary of 

Agriculture and Secretary of Education to 16 state governors that emphasized the disparity 

in funding between land-grant Historically Black Colleges and Universities (HBCUs) and 

their non-HBCU land-grant peers in their states.

28. Address disparities and difficulties with 1:1 matching requirement for 1890s 

land grant universities.  

a. The Governor of the State for the eligible institution must submit any request for a 

waiver for matching requirements. 

b. Allow for a variety of non-federal funding matches (i.e., private donations, 

endowments, etc.). 

Recommendation 29: Cooperative Extension Service Programming 

Given their experience serving small and specialty crop producers and non-traditional 

farmers, the Commission recognizes that 1890 Land Grant colleges, 2008 Hispanic Serving 

Agricultural Colleges and Universities (HSACUs), and 1994 Tribal Land Grant College and 

Universities (TCUs) are the best equipped to conduct agricultural research, outreach, and 

provide technical assistance to the diversity of constituencies.

29. Increase funding and support to expand Cooperative Extension Service 

programming to marginalized communities through cooperative agreements and 

more descriptive language within Requests for Applications (RFAs) for 

competitive funding to facilitate collaboration with minority serving agricultural 

colleges and universities.

Recommendation 30: Cooperative Agreements and Competitive Grants 

Given their experience and relationships with their constituencies, the Equity Commission 

recognizes that 1890 Land Grant colleges, 2008 Hispanic Serving Agricultural Colleges and 

Universities (HSACUs), and 1994 Tribal Land Grant College and Universities (TCUs) are 

best positioned to reach marginalized communities. 

30. Increase financial support (in the form of cooperative agreements and 

competitive grants) and allocate equitable funding to federally designated 

minority serving institutions (including 1890 Land Grant colleges, 1994 TCUs, 

HSACUs, and community-based organizations). 

a. Mandate program managers to be specific, intentional, and equitable in how 

funding is dispersed to research and extension by adding detailed language that 
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USDA EQUITY COMMISSION

targets diverse clientele and encourages collaborations across types of institutions 

and community-based organizations. 

b. Encourage collaboration and cooperation with minority serving 

institutions/organizations through evaluation criteria. The Request for Application 

(RFA) language should be transparently linked to proposal evaluation rubrics to 

promote service to marginalized communities. 

c. Appropriate funding that equals an increase of at least 20 percent over the next 

five years. 

Recommendation 31: Distinctions that Allow Access to Endowments and Appropriations 

The Equity Commission recognizes there is a growing gap among different constituencies 

across the U.S. in degree attainment and access to research, education, and outreach related 

to food, agriculture, and natural resources. In an effort to reach a broader constituency of 

underserved publics and to build a workforce required to enhance and strengthen American 

agriculture, investments must be made in institutions recognized for this work.

31. Recognize minority serving agricultural institutions who are making important 

contributions towards equitable access to information, education, and capacity 

to underserved (minority) students, farmers, ranchers, etc. The distinction 

should allow access to endowments and annual appropriations available to other 

land grant universities—resources intended to support and enhance regionally 

relevant research, access to education and other capacity building, and 

community engagement (extension). 

a. Enhance the legislative authority given in The Food, Conservation, and Energy 

Act of 2008 (PL 110-246) that included a federal designation for Hispanic 

Serving Institutions (HSIs) offering associate, bachelors, or other accredited 

degree programs in agriculture and related fields that became the Hispanic 

Serving Agricultural Colleges and Universities (HSACUs). An enhanced 

distinction should name a select few HSACUs that are strategically and most 

effectively meeting the mission of USDA and that have a demonstrated record of 

contributing to research, education, and extension/community engagement related 

to food, agriculture, and natural resources related sciences. This distinction should 

allow for appropriated funding that allows investment in these institutions 

through access to appropriated funding or through collaborations with USDA 

Agencies (NRCS, ARS, APHIS, etc.) that allows for cooperative agreements or 

partnerships akin to those at land grant colleges. 

b. Create a new distinction for Minority-serving Agricultural College or Universities 

that meet specific, clear benchmarks for (a) access to education: offering 

underserved (minority) students associate, bachelors, or other accredited degree 

programs in agriculture and related fields (higher than existing 25 percent 

benchmark), (b) access to research: are conducting regionally relevant research 

supported by the USDA or other competitive funding mechanisms; (c) capacity 

building: have a clear and demonstrated track record of outreach, extension, or 

community engagement. These Minority Serving Agricultural Colleges and 

Universities (MSACUs) will benefit investments in research, education, 

extensions through USDA competitive grants eligibilities, a MSACU Fund in 

U.S. Treasury with appropriated funding. 
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XII. Ensuring Equitable Nutrition Assistance for Those in Need

The Equity Commission recognizes the opportunity to not only address inequitable access to 

farm programs among underserved communities, but also access to nutrition programs and 

services that have historically left some in America unable to receive assistance. Addressing 

these barriers to access and inclusion directly impacts families and fosters healthier 

communities. Increasing participation in nutrition assistance programs also benefits 

producers through increased demand for their products. Producers in turn can better serve 

consumers and positively impact the food system by participating in nutrition assistance 

programs with greater reach and impact. The Commission is aware of and applauds the many 

initiatives USDA is already addressing related to systemic disparities in food security and 

nutrition assistance such as Summer Electronic Benefit Transfers (EBT) and investments and 

modernization in the Supplemental Nutrition Assistance Program (SNAP). However, the 

Commission continues to recommend updates to several programs that would allow for even 

greater access for underserved individuals and families. 

Recommendation 32: Supplemental Nutrition Assistance Program (SNAP) 

The Equity Commission has identified several policies that explicitly limit nutrition program 

access based on residency and immigration status as well as other policies that have a 

disparate impact on BIPOC access to nutrition programs because of the ways that BIPOC 

people have been marginalized through the labor market and other forces. Many of the 

restrictions have been in place since 1996. By supporting legislative actions to remove select 

eligibility restrictions on Supplemental Nutrition Assistance Program (SNAP), USDA can 

ensure all communities have access to healthy and nutritious foods. 

32. Support legislative action to remove eligibility restrictions on the Supplemental 

Nutrition Assistance Program (SNAP) that disproportionately limit access to 

nutrition supports by BIPOC, including: 

a. The restrictions on receipt based on immigration status. 

b. The denial of standard SNAP benefits to residents of Puerto Rico and other 

insular territories (they receive limited nutritional support from the Nutrition 

Assistance Program). 

c. The prohibition on receiving SNAP benefits and food from the Food Distribution 

Program on Indian Reservations (FDPIR) in the same month.13 

d. The time limit on benefit receipt for unemployed people who are not living with 

dependent children and the option to deny benefits for failure to participate in 

SNAP Employment and Training programs (mandatory SNAP E&T).  

e. The ban on SNAP assistance for people with previous drug felony convictions. 

13 United States. Food & Nutrition Act of 2008. Pub. L. 110-246, 7 USC § 2013(b)(c). 2008. Government Information Office, Jan. 2024, 

https://www.govinfo.gov/content/pkg/COMPS-10331/pdf/COMPS-10331.pdf. 
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Recommendation 33: Thrifty Food Plan (TFP) 

The Equity Commission notes that there have long been concerns that the Thrifty Food Plan 

(TFP) is unrealistic in its expectations and does not provide recipients with enough benefits 

to purchase an adequate and healthy food supply. The Commission acknowledges the 

significant improvements made by the re-evaluated benefits that went into effect in 2021, as a 

result of the 2018 Farm Bill direction for USDA to reevaluate the TFP by 2022 and every 

five years thereafter. The Commission supports the continuing reevaluation of the TFP and 

urges that additional adjustments be made to the SNAP benefit levels and calculations to 

assist recipients in better meeting their nutritional needs. The Commission also urges 

Congress to continue funding these improvements to the TFP and to allow USDA the 

authority to make necessary revisions.

33. Continue to review and update the Thrifty Food Plan (TFP) to reflect the needs 

of today’s consumers. Support research on whether SNAP enables participants 

to actually purchase a healthy diet and encourage Congress to consider options 

including boosting the minimum benefit, increasing benefits more than annually 

during periods of high inflation, and basing SNAP benefit levels on the Low-Cost 

Food Plan. 

Recommendation 34: Customer-Centered Service of the Supplemental Nutrition Assistance 

Program (SNAP) 

The Equity Commission recognizes there is too often a lack of customer-centered service 

which fails to treat people seeking nutrition assistance with respect and results in reduced 

receipt of benefits. Barriers to access frequently have disproportionate impact on BIPOC 

and other socially marginalized populations. By removing barriers to access for applicants 

and participants, USDA can ensure eligible people have access to available nutrition 

programs. 

34. Continue to encourage state SNAP agencies to administer SNAP in a way that 

treats applicants and participants with dignity and respect and to consult with 

those with lived experience of poverty as they administer the programs and 

provide technical assistance on how to do so. USDA should seek legislative 

authority to hold states accountable for barriers to access and require states to 

develop processes for beneficiaries to be involved in program and systems design 

and evaluation. USDA should explore methodologies to report SNAP 

participation data among eligible individuals disaggregated by race and 

ethnicity.

Recommendation 35: Review of Vendor Access in Nutrition Programs 

The Equity Commission recognizes that vendor access to USDA nutrition programs has been 

restrictive and inequitable. By reviewing program access and procurement requirements, 

USDA can address policies that may create barriers to entry for small vendors and local 

farmers. Removing barriers would also make it easier for childcare providers to access and 

procure culturally specific and nutritious foods. The Commission recognizes that there may 

be additional opportunities throughout USDA programs to use procurement to promote 

equity.
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35. Review the nutrition programs at the federal, state, and local levels to identify 

barriers to vendor and procurement opportunities for disadvantaged and 

underrepresented communities; remove barriers within federal control and 

provide technical assistance to states and localities on best practices. 

a. Conduct outreach and support small businesses, especially those owned by 

underrepresented communities in becoming approved SNAP vendors and 

maintaining eligibility. Support innovative approaches to improving access in 

food/SNAP access deserts and promoting local food systems.  

b. Review data-mining algorithms used to identify SNAP retailers as possible sites 

for fraud for bias and disproportionate impact. Provide remediation options to 

avoid creating SNAP access deserts.  

c. Review meal pattern requirements under Child and Adult Care Feeding Program 

(CACFP) to ensure inclusion of culturally appropriate foods, the ability of 

underrepresented community providers to participate as sites, and access by small 

home childcare providers (many of whom come from disadvantaged 

communities). Review and update meal pattern and nutrition standards for school 

meals to reflect the Dietary Guidelines for Americans and in consideration of 

cultural and traditional foods preferred by program participants.  

d. Implement proposed changes to the Special Supplemental Nutrition Program for 

Women, Infants, and Children (WIC) food packages to better support access to 

culturally appropriate foods, in consideration of comments received; and continue 

supporting the participation of underrepresented community providers as WIC 

vendors. Remove barriers to WIC access, including by supporting Congressional 

full funding of WIC and extending waivers of physical presence requirements. 
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XIII. Recognizing Immigrants and Their Families

Throughout America’s agricultural history, immigration has been vital to turning this nation 

into a global agricultural leader. Since the mid-1800’s, immigrants have had a major 

role in developing America’s agricultural landscape as succeeding waves of immigrants were 

imported to work in the fields. California and other major farm states saw the Chinese, 

Japanese, Mexicans, Filipinos, African Americans, the Depression-era Oakies and Arkies, 

Mexicans again, and later Arab and Punjabi workers. These highly skilled laborers worked 

hard under mostly harsh conditions to make U.S. farms productive and profitable, including 

building irrigation systems, harvesting production, and tilling fields for maximum yields 

primarily benefiting farm owners.  Immigrant workforces blasted mountain ridges and built 

the transcontinental railroad, which transformed the movement of American-grown goods. 

By 1880, Asian immigrant farmers and workers were responsible for 70 percent of 

California’s agricultural production. Today, immigrants continue 

to contribute to agricultural advancements and food diversity. For example, Hmong farmers 

and workers have become major players in California’s strawberry industry. 

Historically, during periods of economic downturn, immigrants were no longer welcome. The 

Chinese Exclusion Act of 1882 was the first U.S. immigration law specifically targeting 

a racial group. Subsequent laws expanded restrictions to keep people from most Asian 

countries out while immigrants from European countries remained welcome.  

By the early 1900s, “alien land laws” were enacted specifically to ban non-U.S. citizens from 

owning property including farmland. Many Japanese farmers had arrived as laborers and 

eventually bought their own farms. They were forced to sell their businesses at huge losses or 

transfer the titles to their U.S. born children. Additional restrictions would pass later to 

prohibit American born children of Japanese and other Asian races from holding property. 

Some tried to make private arrangements with business partners or neighbors to manage their 

farms. During World War II, 110,000 Japanese and Japanese Americans were 

unconstitutionally forced into internment camps. When they returned, they found that their 

homes, farms, and businesses were no longer theirs. 

Growers imported more than 100,000 young Filipino immigrants to toil in the fields across 

the western states during the 1920s and ‘30s. Called Manongs, meant as an endearing term of 

respect, they were nevertheless prevented from marrying outside their race by California’s 

anti-miscegenation law and were scapegoated and subjected to racist attacks. Denied the 

right to have families, many men were lifelong bachelors. 

While some progress is being achieved, institutional discrimination has effectively created 

an enduring underclass of Americans in the food and agriculture industry based on their 

ethnicity, language, immigration status and country of origin. Only 

white immigrants could become naturalized citizens until 1954. Without the full rights 

bestowed on U.S. citizens, non-white immigrants who remained in the U.S. had limited rights 

and opportunities. They could not vote or testify against whites, effectively rendering them 

perpetual foreigners subject to legal discrimination and exclusions.
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To address alleged labor shortages during World War II, the U.S. and Mexico governments 

created the “Bracero” Program where Mexican workers were contracted to work in 

U.S. fields. The laborers were exploited with meager wages and substandard working and 

living conditions. Meantime, domestic U.S. workers suffered depressed pay and conditions as 

their jobs were illegally handed over to the more compliant and easy-to-exploit braceros. 

Nonetheless, the program lasted until 1964, when it was ended by Congress. 

Furthermore, Mexican nationals as well as Mexican Americans endure constant 

intimidation and threats from racist and anti-immigrant groups telling them to “go back to 

Mexico.” Like their Asian immigrant counterparts, they are treated as perpetual foreigners. 

Systemic racism and discrimination have created a two-tier system of farmers and 

workers. Perpetual exclusion and restrictive policies and practices have 

forced many immigrants of color to work and live in substandard, unsafe conditions with low 

wages. They have also lacked access to more profitable management and ownership 

opportunities. Yet, while most other American workers avoid the hard work of 

farming, immigrants continue to do the backbreaking labor in hopes of better futures for their 

families. Some have succeeded.  For example, in California’s world-renowned wine 

industry, a new generation of Latinos, many of them children of migrant workers, now own 

or manage award-winning vineyards and wineries. Yet despite their hard work and 

perseverance, there are too few examples of inspirational successes for the immigrants.

As immigration and immigrants remain critical to America’s innovative agricultural 

leadership, the USDA Equity Commission calls for necessary immigration reforms to remove 

unjust inequalities and advance equity for all immigrants regardless of their status or country 

of origin. 

Recommendation 36: A Pathway to Citizenship 

Throughout America’s agricultural history, immigration has been vital to turning this nation 

into a global agricultural leader. As immigrants have been and remain critical to America’s 

global leadership in the agriculture sector, the USDA Equity Commission recommends a 

clear and accessible pathway to citizenship for those so essential to American agriculture. 

Recognizing the significant impact of immigration policies on individuals and families, the 

Equity Commission also strongly supports initiatives such as Deferred Action for Childhood 

Arrivals (DACA), Development, Relief, and Education for Alien Minors (DREAM) and 

Promise Act, and Family Reunification. By supporting policies that clearly articulate an 

accessible pathway to citizenship, the USDA can help immigrants integrate more effectively 

across various aspects of society, including education, housing, health, and community 

engagement, so that they can more immediately add to the resilience and prosperity of 

American agriculture.
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A person’s immigration status determines their path to equitable education, employment, and 

entrepreneurship opportunities. The existence of artificial and formal barriers perpetuates a 

system where immigrants often lack equitable access to opportunities essential for building 

generational wealth. By supporting a clear and accessible pathway to citizenship, USDA can 

break down these barriers and increase stability for undocumented immigrants and their 

families.

36. USDA should support policies that lead to pathways to access citizenship and 

family reunification. 

Recommendation 37: Right to Access Agricultural Land 

Historical racism and discrimination have led to exclusionary laws that restrict immigrants 

from owning U.S. properties. The 1879 Oregon constitution specified that “no Chinaman 

may own property.” In 1913, in response to anti-immigrant forces, California passed 

the Alien Land Law to ban Asian immigrants from purchasing properties including 

farmlands. Subsequent laws extended the ban to include U.S. born children of 

immigrants and restrict land leases. Fifteen more states followed with similar alien land 

laws. It wasn’t until after World War II that the U.S. Supreme Court struck down these laws 

as unconstitutional. 

Today, fueled by anti-immigration sentiments, several states are considering alien land 

legislation to prohibit foreign nationals from certain Asian, 

Central American, and Middle Eastern countries from purchasing agricultural lands, under 

the guise of national security protection. Thirteen states have already passed legislations to 

prohibit Chinese foreign nationals from owning agricultural land or lands within certain 

distance of a U.S. military instillation. Since their arrival, immigrants of color have 

been perceived as perpetual foreigners. These state proposals would put specifically some 

communities, specifically Chinese, under unfair, discriminatory scrutiny and suspicion 

again. 

According to USDA data as of 2021, Chinese entities and individuals owned about 384,000 

acres of U.S. agricultural land, less than 1 percent of all U.S. agricultural land held by 

foreign persons. Thus, the attention and reaction to Chinese ownership of agricultural land 

is not a reaction to a real problem but can be better viewed as actions based on Xenophobic 

stereotypes. 

The Committee on Foreign Investment in the United States (CFIUS), an interagency 

committee chaired by the Secretary of Treasury, has the authority to review, approve, or 

deny any proposed foreign transactions that might raise national concerns, including in the 

food and agricultural sector. Currently, USDA is not a CFIUS member, however, the U.S. 

Treasury may designate USDA as a co-lead in a CFIUS investigation on a case-by-case 

basis. The Equity Commission recommends that USDA serve as a permanent member of the 

committee and request the necessary Congressional appropriations to carry out this role.
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37. The USDA Secretary should serve as a permanent member of the Committee on 

Foreign Investment in the United States (CFIUS). 

a. If the proposed transaction is specifically related to agriculture, the USDA shall 

convene an interagency task force with its federal partners in Treasury, Homeland 

Security, and Defense to ensure that governmental reviews would not cause harm 

to certain Americans because of national origin. 

Recommendation 38: Equitable Compensation and Protection for Agricultural and Food 

System Workers 

Data from investigations show that agricultural and food system workers are frequently 

subjected to exploitative labor practices. Many endure conditions where employers violate 

minimum wage laws, employ child labor, engage in wage theft, subject them to unsafe 

working conditions, and/or force them to live in grossly substandard housing. As immigrants 

remain critical to America’s innovative agricultural leadership, the Equity Commission calls 

for necessary immigration reforms as well as policies and practices to ensure agricultural

and food system workers receive equitable compensation and critical protections.

38. USDA should support a pathway to citizenship, equitable compensation, and 

adequate protections and rights for all agricultural and food system workers.

Recommendation 39: Equitable Access to Rural Housing Service (RHS) Programs 

Housing is foundational to health and well-being. There are certain statutory limits on 

accessing housing subsidies based on immigration status.  This is damaging to both 

immigrants themselves and their families, and to communities, given that nearly 3⁄4 of 

farmworkers in the U.S. are immigrants.

39. Ensure equitable access to Rural Housing Service programs regardless of 

household immigration status. 

a. USDA should support Congressional action to remove legislative restrictions that 

limit access to rural housing based on immigration status.  

b. RHS should review its regulations and sub-regulatory guidance to ensure that they 

are not imposing any restrictions on access to rural housing based on immigration 

status that exceed statutory requirements.  

c. RHS should conduct an education campaign to ensure equitable access to rural 

housing programs, including outreach to immigrant communities and informing 

landlords of their responsibilities under fair housing laws.  
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XIV. Revitalizing Rural America: A Path to Equitable Growth

Rural communities stand as pillars of the U.S. economy and culture. Yet despite substantial 

contributions, rural families have too often been denied the tools for economic mobility and 

prosperity. As the Equity Commission concludes its transformational work, the Rural 

Community Economic Development (RCED) Subcommittee highlights how facts clearly 

demonstrate the need for a transformed federal approach to rural policy centered on 

inclusion. Robust investments guided by rural people themselves can unlock abundant 

potential in America’s countryside.

The Value of Rural America

The diverse communities in rural America contribute intrinsic value as stewards of cherished 

virtues, often stretching back generations. Their importance also stems from tangible, 

indispensable contributions fueling the broader economy. When rural communities thrive, 

America thrives as a result. Rural communities are home to 46 million Americans – 14 

percent of the U.S. population – with increasing diversity. By income, culture, age and other 

measures, rural America encapsulates the nation’s plurality. Rural communities drive the 

agriculture sector, providing food, fiber and other agricultural products critical for national 

security. And they also have an important role in emerging sectors like clean energy 

production, with about 11 percent of clean energy jobs in rural areas in 2021. While 

agriculture and energy are key to many rural economies (accounting for 7 percent of 

nonmetro employment in 2019), other sectors employ more people across rural parts of the 

country: government services (16 percent of nonmetro employment in 2019), manufacturing 

(11 percent), health care and social assistance (10 percent), and retail (10 percent). 

Transporting commodities and products depend upon maintenance of rural transportation 

systems. Effective communications infrastructure is dependent upon rural companies and 

landscapes. Meanwhile, rural landscapes promote environmental conservation while 

protecting essential water, forest, and mineral resources benefiting communities nationwide. 

As the country seeks solutions to the multiple crises caused by climate change, it must first 

look to rural areas where renewable energy can be produced, and carbon can be sequestered. 

Additionally, unparalleled natural assets support vibrant outdoor recreation that generates 

economic activity.
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Systemic Inequality Restricting Potential

Rural communities in the United States are terrifically diverse, with the 2020 Census 

indicating that 24 percent of people in the rural U.S. are people of color; and that number is 

growing, with the median rural county seeing its population of color increase by 3.5 percent

between 2010 and 2020. But for too long, systemic inequality has stifled rural success. 

Barriers spanning generations have obstructed prosperity for marginalized groups while 

growth opportunities lifted other regions. Discrimination continues to yield this unacceptable 

reality. Persistent poverty plagues rural areas, with 85 percent of continually impoverished 

U.S. counties being rural, with concentrations in Black communities in the Southeast, 

Hispanic communities in the Southwest, Tribal communities throughout the country and 

white communities in Central Appalachia. Distress grips nearly 50 percent of rural Black 

residents and 45 percent of rural Native communities. Since 2005, rural communities have 

seen more than 190 hospitals close, with a concentration in counties with significant minority 

populations. Rural minorities face steeper hurdles accessing capital, technical assistance, and 

disaster relief programs despite being as deserving as any American. Housing insecurity in 

rural areas is a particular concern for American Indian and Hispanic households. 

Discrimination endures as an unacceptable reality. Infrastructure gaps create hardship for 

rural groups nationwide. Deficient broadband access restricts market opportunities. 

Crumbling main streets signal economic despair. Such factors fuel youth outward migration 

– a vicious cycle stripping rural communities of their greatest resource – its young people. 

The Pursuit of Rural Equity

Facts clearly demonstrate how an antiquated federal approach has failed rural communities 

resulting in inequality across groups and regions – especially within minority populations 

such as black farmers, Tribal groups, Latinos, and people in territories. With challenges 

crystallized, the pursuit of rural equity surfaces as an economic and moral imperative. 

Within the Equity Commission, the RCED Subcommittee provided a ground level view of 

the barriers holding back rural families. Personal testimonials from rural community leaders, 

farmers, and community economic development professionals exposed how policies fail to 

address the most critical challenges facing marginalized rural groups nationwide.

Black farmers highlighted discrimination severely restricting land ownership and credit 

access for generations. Rural Black leaders described how their marginalization in 

community institutions is exacerbated by federal policy. Tribal representatives shared how 

federal policies have chronically obstructed prosperity on Indigenous lands. Members from 

territories described lacking access to aid and insurance tools that mainland state residents 

readily obtain – despite all being U.S. citizens. 

These voices spotlight nuances within systemic inequality that aggregate statistics alone fail 

to capture. They revealed how seemingly universal programs, when designed for the 

“average” marginal community, can perpetuate inequality by missing the mark for those 

facing the greatest structural barriers.
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Our diversity drove more inclusive, tailored recommendations. We gained support for 

translation assistance, technical assistance, and other targeted interventions alongside broader 

efforts. Territory farmers secured an agreement for assessing expanded programming, with a 

focus on parity. 

Centering Equity for a Thriving Rural America

The path forward is now clear: substantial investments guided by those living in rural 

realities. Coordinated efforts centered on equity will unleash the potential of rural 

communities. This will occur across sectors, from agriculture to clean energy to 

manufacturing and beyond. This must happen because national prosperity depends on rural 

success. The Commission’s extensive engagement with people in rural communities 

produced four pillars for a transformed approach: 

1. Locally Designed Solutions: Bottom-up strategies channeling grassroots insights will 

succeed where bureaucratic one-size-fits all directives falter. Rural Equity Advisory 

Councils can spur continued idea sharing. The solutions should focus on people in 

rural communities owning and controlling the drivers of the local economy that build 

on the foundation of farmer and utility cooperatives. 

2. Inclusive Program Design: Barriers to eligibility must be removed to make existing 

programs genuinely accessible for minority, socially disadvantaged and persistently 

marginalized producers.

3. Assessing Effectiveness: Transparent tracking of outcomes across geographies and 

demographics will reveal where approaches succeed – and where transformation is 

still required. Continual reassessment is essential.

4. Recognizing and Tackling System Discrimination: Territory residents lack access to 

critical aid and programs compared to mainland states. The U.S. Government has

reached agreement with the Territories to comprehensively assess and address some 

of these gaps.

Rural communities have been viewed too long as merely agrarian – instead of as diverse 

economic epicenters powering the economy. With purposeful investments guided by those 

living rural realities, the paths to prosperity through equity have been cleared. The diverse 

voices of the Commission have outlined the course. Action must now follow to secure rural 

America’s future as a national asset.
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XV. Enhancing Rural Development Operations 

The number of staff at the Rural Development Mission Area (RD) has been in consistent 

decline for decades to the point that it is now deeply challenged in meeting its mission of 

serving rural people, and especially those people in historically underserved communities. In 

1994, the Federal Crop Insurance Reform and Department of Agriculture Reorganization Act 

transformed the way RD programs were delivered. This reorganization resulted in the closure 

of 1,200 USDA field offices, a significant portion of which were RD field offices, and the 

loss of about 13 percent of all field staff in just three years. The federal government needs to 

transform its approach to rural community economic development and invest in rural 

capacity building. This will require more federal staff, strategically located investments in

rural intermediaries, and more strategic use of technology. USDA’s programs should also be 

more transparent and continually assessed for effectiveness.

Recommendation 40: Staffing 

Across all programs and services provided by Rural Development, direct connections with 

RD staff are necessary to ensure the equitable distribution of resources. Over time, RD’s 

footprint in rural communities has significantly declined. The Equity Commission agrees 

with the comments received from the public in concluding that the location of RD regional or 

local offices strongly correlates with the distribution of RD investments as opposed to where 

there is greatest need. In turn, USDA must identify the capacity of local staff and re-align its 

resources to ensure underserved communities are receiving RD resources.

40. Ensure the communities with greatest need have access to critical staff resources. 

Specifically, USDA should: 

a. Conduct a full assessment—to include a demographic analysis—of the current 

location of staff and resources available to them.   

b. Following the assessment, quickly act to re-align staff and allocate new resources 

to socially and economically disadvantaged communities as defined by rural data 

and communities with environmental justice concerns as defined by Justice40.   

c. When recruiting, ensure new staff are reflective of the local community they serve 

with an intentional focus on underserved populations within the demographics of 

the community.   

d. Use technology and remote work strategies to improve staff interaction with 

communities. 

Recommendation 41: Staff Skillset

As a result of USDA RD field staff cuts in regional offices across the nation and 

centralization of services within the DC offices, the field staff have increasingly assumed the 

role of compliance officers. They often lack capacity, skills, or time to engage and build 

trusted relationships as community developers who assist communities with design of a 

project/program or funding proposals. This approach leaves service gaps within rural 

communities at a time when additional technical assistance many times determines which 

communities successfully access and utilize USDA programs.  
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41. Increase the skillset of staff (central and field) on community economic 

development, as opposed to only grant management, underwriting, and 

compliance driven tasks. There should be a core of community economic 

development specialists to assist other staff in providing rural communities more 

comprehensive solutions. 

a. Staff work plans and performance metrics should include proactive outreach and 

engagement with underserved communities to build relationships and identify 

needs and opportunities. This will facilitate timely, quality, responses to new 

funding opportunities.  

b. Bolster the skillset of central and field staff to maximize opportunities for 

underserved communities. 

Recommendation 42: Partnership Models

The reduction in RD staff has limited the capacity of RD to provide culturally sensitive and 

tailored assistance to rural communities. Partnerships with local organizations assist RD in 

understanding the needs of the communities they serve. The staff in these programs are 

skilled in building relationships, constructive collaboration, and identifying ways to achieve 

win-win for all involved. Due to systemic under-investment, however, often community 

partners in rural areas themselves also do not have the capacity that larger Community 

Based Organizations (CBO) have, which in turn makes it difficult to reach those in greatest 

need. These organizations need support and funding to advance their goals and targets, 

while building the capacity to sustain the value of the investment and the potential for 

durable improvement in program delivery over time. The following recommendation will 

bolster USDA’s capacity to support community partners and raise cultural awareness of the 

needs of diverse rural communities. 

42. Significantly expand and fund partnerships for historically underserved, lowincome, and remote, sparsely populated communities. In collaboration with 

community organizations and leaders, identify priorities, design solutions and 

secure funds for community priorities. Develop and fund 

partnerships/agreements with local organizations to ensure program readiness. 

a. Cultivate better partnerships within the federal government - both within USDA 

agencies and with other federal departments such as the Department of 

Commerce, Small Business Administration (SBA), Department of Housing and 

Urban Development (HUD), Bureau of Indian Affairs, and Department of Labor 

(DOL) to better understand the needs of the communities they serve. 

b. Leverage high-capacity community-based organizations, particularly local 

organizations serving historically underserved and economically disadvantaged 

communities, to extend USDA’s reach into communities fostering measurable 

outcomes, including deeper connections, equitable distribution of resources, and 

capacity building to ensure more effective support. This should include: 

c. Investing in existing high-capacity CBO partnerships 

d. Establishing new partnerships to serve underserved 

regions/counties/communities. 

e. Fully fund, expand, and institutionalize the Rural Partners Network (navigators 

and implementation practitioners) with a focus on equitable strategic design to 

improve service delivery. To ensure underserved and sparsely populated 
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communities receive the support, expand the network to include at least one 

coordinator per state. Congress should authorize RPN in the next Farm Bill and 

ensure robust funding to support the program. 

f. Engage new partners particularly local organizations serving economically 

disadvantaged households and communities for the equitable distribution of 

resources and to build capacity. 

g. Develop a communication channel to serve as an avenue of shared learning 

between the CBO partnership model with the RPN for complementary, 

coordinated, and mutually reinforcing strategies. 

Recommendation 43: RD State Advisory Committee 

The reduction in RD field offices resulted in a lack of staff’s capacity to build connections 

with and serve rural communities. This created the need for USDA to support State-led 

solutions. Congress and USDA, however, have not effectively enabled States to fill the gaps 

created by the 1994 Federal Crop Insurance Reform and Department of Agriculture 

Reorganization Act. This recommendation aims to address this gap by connecting State RD 

Directors directly to local stakeholders from underserved communities to ensure effective 

implementation of RD programs.

43. Strengthen or establish a state and Tribal advisory committee and to support 

and advise the State RD Director on equitable systems thinking in identifying 

priorities, building partnerships, and monitoring effectiveness.  

a. Ensure strong representation of under-resourced communities by including 

diverse representation within each state. Model after the NRCS State Advisory 

Committees. 

b. Provide the tools and as necessary training that will increase the capacity of 

committee members to provide advice and support to ensure all customers 

particularly those from historically underserved and economically disadvantaged 

communities have equitable access to all USDA RD services. 

c. Delegate authority to USDA RD Directors to utilize these advisory committees in 

translating national program goals and targets into state-specific outcomes.

Recommendation 44: Demographics of Funding/Lending Recipients 

The American Community Survey of the Census Bureau, a major data source for rural and 

Tribal development practitioners, has limited utility in measuring changes in rural places. 

The “left out” rural areas, organizations, and businesses that do not compete successfully 

for funding, or that do not apply at all because of the complexity, often tend to be poorer, 

have a greater number of people of color, and are smaller and more remote. They can easily 

fall off the radar screen of program designers. Additionally, local philanthropic partners and 

States are not aware of direct correlation of USDA RD staffing deficiencies to 

underutilization of USDA programs and investments. USDA needs to address the inherent 

limitations of federal data for communities and Native nations across the rural United States 

so local partners and states can assist in providing outreach and assistance to the “left out” 

rural areas. 
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44. Improve transparency of data gathering and analysis of the distribution of 

grants and investments currently managed by USDA RD. Regularly analyze and 

compare the economic, place, and race demographics of where USDA funding or 

lending is going – and not going. If there is an uneven distribution to some rural 

areas or populations, evaluate reasons why and identify ways USDA RD could 

better serve those communities. 

a. Fund improvements to the Rural Data Gateway by drawing on lessons and usage 

of other National Data tools. At a bare minimum the Rural Data Gateway should 

layer ALL the following inputs on one user friendly map: 

i. Socially vulnerable counties – per the Rural Data Gateway inputs. 

ii. USDA investments made - Ten-year history of USDA investments – 

either by quantity/number or dollar amount of investments in geographic 

area. 

iii. Type of USDA investments - grants or loans and whether or not the 

investments were for capacity building (planning) or implementation. 

iv. USDA RD Staff - # of USDA RD staff overlayed by those who report to 

DC and those that report to a State Director. 

v. Disaggregation of data by demographics. 

b. As these assessments uncover disparities in the distribution of programs, USDA 

should take immediate actions to prioritize investments to areas of high-need and 

low utilization of RD resources, including reassessment of the application process 

for programs that are not equitably benefiting communities. 

Recommendation 45: Measures of Success 

For decades, rural community and economic practitioners have maintained that many 

indicators or measures of “success” that government, philanthropic, and private programs 

and investors ask them to report are not well-suited or relevant to rural places. In some 

cases, investors are looking for raw aggregate numbers to show scale of impact, which 

always places rural places at a disadvantage to urban places; in others, investors focus too 

narrowly on immediate job creation, dollars leveraged, or financial return-on-investment 

rather than the critical human, organizational, civic, and environmental factors that are 

fundamental to producing jobs and financial return over a longer term. What is achievable 

in any effort is dependent to a great extent on conditions, resources, and capacity at the start 

of any initiative. 

Communities should have the opportunity to define their own starting points across critical 

dimensions. A distorted view of people and place happens when expectations result in bias 

that recognizes only needs or deficiencies, while fully recognizing community assets leads to 

a more accurate picture of rural and Tribal conditions. This recognition is a precondition for 

establishing a respectful and productive partnership. This approach will allow for fairer 

comparisons with urban efforts. It will also help surface and learn from innovative rural 

efforts that are often overlooked or ignored because of low raw-number-results potential. 
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Effective planning to reduce inequity requires representation from not just the movers and 

shakers but also for the moved and shaken. A process that includes broad rural geography, 

class, race, and cultural representation in designing a funding or lending program is itself a 

key process indicator – and one that requires attention and commitment. Likewise, all rural 

initiatives should be asked to value and measure that same inclusion in the design of their 

efforts.

45. Revise definitions and measures of success that build upon multiple forms of 

community-based assets including quality of life, social capital, and the 

characteristics of the people they are serving, not just the quantity. USDA 

should: 

a. Ask for, accept, and learn from any (optional) supplemental community-driven 

metrics and encourage rural initiatives to report other measures or indicators that 

they think – or discover – are important. 

b. Conduct a joint analysis across the portfolio to spark new thinking about 

measuring progress and to add to the menu of potential progress indicators. 

c. Measure progress from community starting points, not predetermined program or 

agency ideals of success. Measure assets and opportunities as well as needs. 

d. Gauge rural progress as ratios in relation to the starting point to determine true 

impact. Ask for equity process indicators and measures14. 

Recommendation 46: Environmental Justice 

The Federal Government, through Executive Order 14096 defines environmental justice as 

“the just treatment and meaningful involvement of all people, regardless of income, race, 

color, national origin, Tribal affiliation, or disability, in agency decision-making and other 

Federal activities that affect human health and the environment.” 

The Justice40 Initiative is highlighted as part of the Biden-Harris Administration’s “wholeof-government approach to advancing Environmental Justice.” Justice40 reflects the 

commitment by the Administration “to deliver 40 percent of the overall benefits of certain 

Federal investments [to] disadvantaged communities that are marginalized, underserved, 

and overburdened by pollution.” USDA has identified 65 programs from ten agencies and 

one USDA office as covered under the Justice40 Initiative: Agricultural Research Service, 

Climate Hubs, Farm Service Agency, Forest Service, National Institute of Food and 

Agriculture, Natural Resources Conservation Service, Risk Management Agency, Rural 

Business-Cooperative Service, Rural Housing Service, Rural Utilities Service. The White 

House description of Justice40 notes that “all Justice40 covered programs are required to 

engage in stakeholder consultation and ensure that community stakeholders are meaningfully 

involved in determining program benefits.” This is consistent with the requirement for 

promotion of inclusive regulatory policy and public participation as outlined in the July 2023 

Memorandum Broadening Public Participation and Community Engagement in the 

Regulatory Process.

14 See Appendix C for Potential Measurement Questions
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46. USDA should ensure environmental justice considerations are woven into the 

project lifecycle of all USDA programs to ensure benefits and burdens associated 

with USDA-funded activities are equitably shared among communities. 

a. When designing programs, USDA should include environmental justice 

considerations throughout the design process. USDA should support 

intermediaries such as community-based and direct service organizations, to work 

with communities with environmental justice concerns to promote access to 

USDA programs and services. To ensure USDA programs have a positive impact 

on local communities, USDA should identify and consider the potential impacts 

of the program on communities, inform communities about the program and make 

them aware of notice and comment opportunities, and support impacted 

communities in participating in decision making and funding processes. 

b. To ensure communities with environmental justice concerns are not 

disproportionately impacted by USDA-funded activities, programs that provide 

extra points for the citing of competitive grant funded activities should justify 

how projects would positively impact environmental conditions for local 

communities where the project is placed. For larger projects, more evidence of 

community support is needed. 

c. To ensure that environmental justice analysis is consistently and adequately 

performed during National Environmental Policy Act (NEPA) processes, all 

NEPA practitioners should receive training on environmental justice analysis in 

NEPA.

Recommendation 47: Using Technology to Increase Access to Rural Development 

Programs 

Rural communities, businesses, non-profits, cooperatives, and individuals often miss 

program and funding opportunities offered by USDA due to not receiving adequate 

information or technical assistance. Additionally, customers are not accessing federal 

programs intended to support Rural America due to the complexity of these programs. 

Customers may not know about the wide range of programs that extend beyond single 

agencies. 

In turn, this recommendation calls on USDA to lead government-wide efforts to create online 

tools that reduce barriers and consolidate information for Rural America. Through 

Technical Modernization Funding authorized in the American Rescue Plan, the federal 

government can more effectively support rural communities.

47. Rural Development should take full advantage of the Technology Modernization 

Fund to support the development of new Customer Experience tools for all 

federal rural programs. 

a. Rural Development should coordinate with other rural-serving agencies across the 

federal government to submit a proposal for Technology Modernization Funds.   

b. These funds should be used to revamp Rural.gov to include a Customer 

Experience dashboard that allows customers to access details about programs 

based on the type of customer (Business, Cooperative, Community Development 

Financial Institution, Individual) and contact information for both relevant staff 

and technical assistance organizations in their regions.   
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c. Following the implementation of sub-recommendation’s ‘a’ and ‘b’, all agencies 

with programs targeting rural communities should conduct outreach campaigns to 

increase awareness of this tool.   

d. Continuously evaluate the effectiveness of new and existing Customer Experience 

tools to make improvements based on stakeholder feedback and data on program 

applications/site usage. 

Recommendation 48: Office of Coordinated Community Response 

Smaller, lower-income, and underserved rural communities can experience significant 

problems that emerge from a crisis, such as flooding or other natural disasters, or 

alternatively are the result of longer-term problems, such as sanitation issues due to the lack 

of a functioning water and sewer system. Some of these issues and concerns are properly 

regarded as issues of environmental justice. Executive Order 14008 calls attention to the 

needs of disadvantaged communities that are marginalized, underserved, and overburdened 

by pollution. Regardless of how one categorizes the issue, these communities need help, and 

the USDA often has programs or ways to assist once the problem is identified and can work 

its way through the Department. Unfortunately, many times these problems are not identified 

promptly, and no single agency has the resources or programs to provide a comprehensive 

solution. Larger, more affluent towns and communities can either deal with a problem 

directly on their own, or they have the skills and resources to approach local, state, or 

federal agencies to ask for assistance.

Too often at USDA a single agency does not have the comprehensive programs or authority 

to provide solutions for complex problems. Other federal agencies may also have programs 

that would be of assistance. On occasion, such issues rise to the highest levels of the 

Department, even to the Secretary, where an ad hoc Departmental group can be convened to

coordinate a response. The Commission believes that there is a better way. All Americans, 

regardless of income or status, have a right to fairly access the programs and benefits of 

citizenship and the federal government.

48. Establish an Office of Coordinated Rural Community Response for improved 

coordination of USDA and other Federal resources for timely and 

comprehensive outreach and response to the urgent needs of underserved rural 

communities. 

a. The Secretary should establish an office, reporting to the Chief of Staff, that will 

be responsible for providing immediate and integrated solutions to selected high 

priority problems of underserved rural communities. This Office of Coordinated 

Rural Community Response would maintain a small but critical mass of trained 

program professionals familiar with and access to programs across the 

Department that would be available to conduct analysis and recommend a 

coordinated, integrated relief and long-term investment. The Office would also 

interface, in coordination with the Office of Intergovernmental Affairs, at a 

program level with other Federal Departments and Agencies that have programs 

or assistance that should or could be part of the solution. Finally, this Office 

should conduct analysis of data across the Department and the Federal 

government to identify areas that USDA could conduct proactive work to find 

communities with high levels of need that lack the resources to ask for help. 
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b. Consideration should be given to providing the office, if necessary, by legislation, 

with the authority to utilize, through transfer authority, some small percentage of 

program funding such that immediate, on-the-ground, solutions could be 

implemented quickly and efficiently. 
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XVI. Supporting Rural Communities

USDA must transform its approach to supporting rural community development by adopting 

a “whole-of-household” approach. Households require access to affordable and safe living 

conditions, basic needs like electricity, broadband and water, and robust community 

facilities, including healthcare, emergency services, education, and food systems. Through 

reprioritizing the development of a community’s needs through the “whole-of-household” 

perspective, USDA can improve the quality of life for all Americans, with a focus on 

historically underserved communities.

Rural Housing

Recommendation 49: Housing as Infrastructure 

It is crucial to acknowledge that the right to housing is a human right. The right to housing is 

the economic, social, and cultural right to adequate housing and shelter. Housing is not 

merely a subcategory of focus but an essential aspect of rural and Tribal infrastructure. 

Failure to recognize this critical distinction perpetuates the systemic neglect of housing in 

these communities and undermines USDA’s goal of improving the quality of life. To 

effectively implement the inclusion and adaptation of housing as infrastructure, USDA must 

take a holistic and comprehensive approach that recognizes the significance of safe, 

affordable, and adequate housing for rural and Tribal communities and invest and prioritize 

accordingly. 

49. Amend USDA policies, programs, and funding mechanisms to prioritize 

investment in housing. To do this, USDA should: 

a. Align Strategic Goal 5 of its 2022-2026 Strategic Plan and further permanently 

amend all agency priorities, programs, and funding priorities to include rural 

housing as a priority of USDA infrastructure programs, particularly in historically 

underserved and economically disadvantaged communities. 

b. Prioritize development and repair of rural single family and multifamily housing 

among USDA funded activities and programs, particularly for economically 

disadvantaged households, intentionally raising and signaling the importance and 

necessity of housing as part of the ecosystem of infrastructure. 

c. Holistically amend all language to reflect housing as infrastructure and not 

subdivide it out into a subcategory of focus. 

d. Support legislation to redefine housing as infrastructure following the precedent

of the Housing as Infrastructure Act of 2021 that authorized the Department of 

Housing and Urban Development (HUD) to provide grants, programs, and other 

support related to public housing, affordable housing preservation and 

construction, and mortgage access. 
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Recommendation 50: Program Standards for Single Family Housing 

The Equity Commission has identified redundancies in requirements for Single Family 

Housing programs that most traditional banks do not request of borrowers and that create a 

barrier for underserved communities. Restrictive program qualification standards restrict the 

access of smaller capacity grantees. If program applications are not adjusted to support the 

most marginalized, they will inherently present a barrier to equity in rural housing. For more 

experienced or higher capacity grantees, complex applications and requirements are usually 

not an issue. The Commission believes the single-family housing model needs to be 

responsive to the communities they were created to assist. These communities will also 

benefit from a “whole of government” approach. For example, the Department of Defense 

has developed innovative housing solutions through 3D printed barracks for National Guard 

soldiers in Texas. Rural Housing programs should be more flexible to allow for similar, 

innovative solutions. 

50. Simplify the application process for single family housing. Specifically, USDA 

should: 

a. Provide States15 with the authority to convert or provide waivers on housing 

program qualifications when responding to natural disasters or allow States to 

allocate funding for rural housing as a set-aside for disaster mitigation. 

b. Amend Rural Housing program policies to be more open to alternative and 

innovative forms of housing construction (for example, 3D printed, modular). 

c. In order to target consistently poor households, whether or not within a persistent 

poverty area, provide a waiver for housing programs to ensure receipt of specific 

access and support. 

d. Revise the Self-Help Model to remove stipulation that requires new 523 grantees 

to have buyers in the pipeline. This requirement results in fewer resources 

directed to communities most in need.

Recommendation 51: Equitable and High-Quality Affordable Multi-Family Housing 

Affordable housing is critical to the prosperity of rural communities. Rising housing costs 

and changes to the rural economy have contributed to a need for affordable housing that is 

not currently being met. USDA should prioritize developing new multi-family housing units 

in the rural communities most in need. The Equity Commission commends current rural 

housing staff for their dedication in overseeing USDA’s current multi-family housing 

portfolio. Yet additional resources, capacity, and staff are required to ensure multi-family 

housing projects are developed and managed properly. Through stakeholder engagement, 

the Commission has concluded that affordable multi-family housing units in rural 

communities often fall short of acceptable quality standards.

Through improved physical site inspections, increased accountability and capacity, and 

further investment in maintenance and preservation, the quality of affordable housing in 

rural communities can be improved. Underserved communities are most in need of 

mechanisms to ensure high-quality housing. USDA must prioritize addressing the quality of 

subsidized multifamily housing units to preserve the health of vulnerable communities. 

15 For purposes of this recommendation, the term “States” refers to USDA Rural Development State Offices 
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51. Invest in and ensure equitable and high-quality standards for new construction 

and existing affordable multi-family housing in rural communities particularly 

in historically underserved and economically disadvantaged communities. 

a. USDA should provide adequate incentives to rural developers and ensure 

outreach to and opportunity for historically underrepresented developers to 

successfully participate in new construction projects, including set asides as 

appropriate. 

b. USDA should ensure all new applications for housing projects include 

requirements to maintain quality housing throughout the operations and existence 

of that housing project, not just until mortgages are paid off. 

c. USDA should use existing annual financial audits to assess whether requirements 

for reinvestment into maintaining the quality of housing are being met. This 

expansion should include physical site visits and interviews with tenants. 

d. Invest in existing and new pilot programs to ensure all subsidized units are 

physically inspected once every three years. 

e. USDA should ensure landlords and property managers are held accountable to 

maintain high-quality housing standards by adding financial punishments for not 

complying with quality standards. 

f. Property managers of multi-family housing units receive market rate rents for 

their properties through subsidies from USDA. A portion of these funds should be 

required to be reinvested into maintenance. 

g. Prioritize appropriating funds to ensure the Rural Housing Service’s multi-family 

preservation programs effectively incentivize property managers to maintain 

quality housing.16

h. Increase and invest in building the capacity of multi-family housing staff to 

support adequate oversight and management including equitable access to 

services by all residents and relevant community members. 

i. Establish a working group between HUD and USDA that meets regularly to share 

best practices for affordable multi-family housing programs and maintaining 

quality standards. 

Recommendation 52: 502 Loan Product 

USDA’s investments in the Tribal Communities through the 502 Single Family Housing 

Relending Program have successfully brought additional safe and quality affordable housing 

to Tribal Communities. The extension of the 502 Relending Program to Tribes, however, is 

not permanent. The Equity Commission recommends USDA pursue the authority to 

permanently allow Native Community Development Financial Institutions to access funds 

from the 502 Relending Program.

52. Support Congressional efforts to permanently authorize the Native Community 

Development Financial Institution (CDFI) Relending Program for the 502 Direct 

Home Loan as cited in Title III of S.1369 - the Rural Housing Service Reform 

Act of 2023. 

16 https://www.congress.gov/bill/118th-congress/senate-bill/1490/text
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a. Continue to administer and evaluate the 502-relending demonstration in South 

Dakota and other locations in preparation for developing program guidance for a 

permanent national program.17 

b. Provide training and technical assistance opportunities for Native CDFIs to learn 

about the 502-relending program. 

c. Create an administrative or operating grant program to support Native CDFI 

intermediary lenders operating the relending program. 

d. Institute best practices based on lessons learned from the CDFIs. 

Recommendation 53: 504 Grant Program 

USDA’s 504 grant program is currently only available to those in areas with populations of 

20,000 or less. Although this program is necessary for smaller rural communities, the 

current population restrictions result in many underserved rural communities being unable 

to access this program. To address this problem, the program’s requirements should be 

expanded to serve all low-income, rural communities (as defined by the Census of 

Agriculture).

53. Expand the 504 Grant Program. Specifically, USDA should: 

a. Remove the age restriction and expand beyond those that are 62+ and those that 

are “very” low-income. 

b. Align the grant limit with the Congressional limit of 10 percent of the national 

median home price. 

c. Revise the population requirements to be available to populations of greater than 

20,000 but less than 50,000. Priority should still be given to smaller, underserved 

communities; however, all rural communities should be able to access the 504 

Grant Program. 

d. Reconsider (or allow for waiver of) lifetime limits to address situations that are 

responsive to natural disasters. 

e. To ensure sufficient funding, allocate annually a minimum of $50,000,000. 

Rural Utilities

Recommendation 54: Broadband 

To effectively address the needs of underserved areas, it is essential to examine and refine 

the methodology and rules used to determine the availability of broadband services. 

Currently, the “one-and-done” funding stipulation prohibits some previously funded areas to 

receive additional USDA support for evolving needs. By supporting efforts to improve the 

accuracy of broadband mapping, USDA can identify and serve areas with unmet evolving 

and ongoing needs more equitably and effectively.

54. Enhance broadband mapping and funding to address rural economically 

distressed and underserved census tracts. 

a. Reassess the broadband census tract methodology and rules that determine where 

USDA’s programs believe broadband currently exists to understand if it is 

effectively capturing the needs of underserved areas. 

17 “USDA Expands Local Partnerships to Increase Homeownership Opportunities for Native Americans.” U.S. Department of Agriculture 

Press Release, U.S. Department of Agriculture, 16 Oct. 2023, www.rd.usda.gov/newsroom/news-release/usda-expands-local-partnershipsincrease-homeownership-opportunities-native-americans.
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b. Eliminate the current “one-and-done” funding stipulation that disqualifies rural 

economically distressed and underserved communities from receiving access to 

more inclusive grants and low interest loans to support broadband. Allow 

additional USDA funding for communities where broadband does not currently 

meet the federally established standard.

Recommendation 55: Improve Support for Underserved Communities Through Rural 

Utilities 

In the context of the Inflation Reduction Act (IRA), Bipartisan Infrastructure Law, and other 

grant and loan programs administered by USDA, the Department must incentivize utilities 

and eligible entities to invest a portion of their funding to support underserved communities. 

Costs related to energy and other utilities more heavily burden low income and underserved 

communities while exacerbating already existing inequities. Energy and utility programs 

must consider the specific communities benefiting from loans and grants to ensure resources 

are equitably distributed. To promote this goal, the application process should award bonus 

points to applicants who demonstrate a commitment to community benefit plans and efforts 

to ensure that funds will benefit underserved communities.

Additionally, USDA should insist on consistent accountability and the transparent reporting 

of program investments and outcomes, including information on the communities and 

individuals benefiting from the initiatives. USDA should incorporate implementation 

guidelines of the Justice40 Initiative to enhance the focus on equity in new sustainability 

programs. Mechanisms to enforce transparency and accountability must be in place for all 

rural utility programs, especially water and electric programs. 

Furthermore, USDA should consider replicating requirements from other federal agencies, 

such as the Department of Energy (DOE), to ensure that USDA’s efforts are in line with the 

best practices across the Federal Government for promoting equitable resource distribution 

and support for underserved communities across various sectors.

Finally, for cooperatives to work most effectively and to serve the interests of their members, 

they should be democratically controlled - that is, the board is elected in fair and transparent 

elections by the members of the cooperative. Over the years, observers have indicated that 

certain utility cooperatives, especially in geographic areas with a large minority population, 

have not conducted fair and transparent elections, which has resulted in boards that are not 

reflective of the members.

55. Incentivize utility cooperatives and companies to support rural economically 

distressed and underserved communities through USDA-administered grants 

and loans, increase the transparency of the utility programs, and encourage fair 

and transparent election of utility boards. 

a. Contractually require utilities and other eligible entities applying for Rural Utility 

Grants and Loans to demonstrate a commitment to use a portion of these funds to 

support rural economically distressed and underserved communities. 

b. Award bonus points in the application process for community benefit plans that 

ensure funds support underserved communities, consistent accountability, and 
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USDA EQUITY COMMISSION

transparent reporting of the location of the investments and the results of a 

program with a focus on historically underserved communities. The distribution 

of funds should be contingent on the implementation of community benefit plans. 

c. Incorporate Justice40 Initiative implementation guidelines. 

d. Monitor and evaluate how rural utilities spend funds allocated to them through 

USDA programs, with a specific focus on assessing the impact on underserved 

communities. 

e. Take steps to amplify the voices of underrepresented groups within rural water 

associations, electric cooperative boards, and other utility managing entities. This 

effort should focus on fostering a more inclusive decision-making process that 

better reflects the needs and priorities of the entire community. 

f. USDA should support communities in ensuring fair and transparent board 

elections for rural utility cooperatives by collecting data and proactively providing 

information to historically underserved communities on how to conduct and 

participate in fair and transparent elections including by working with 

community-based organizations such as Minority Serving Institutions (colleges 

and universities) and other organizations rooted in historically underserved 

communities.

Recommendation 56: Edge-of-Grid Lending 

To transform the electric production in America to clean energy, edge-of-grid18 power 

generation will play a critical role. USDA must adapt rural electric programs to incentivize 

edge-of-grid projects and ensure that this funding is distributed equally. Investing in the 

edge-of-grid will encourage utilities to pursue energy efficiency, solar power, battery 

storage, microgrids, and smart energy devices. This recommendation aims to guarantee that 

underserved communities receive a fair share of the benefits from these investments and 

contribute to a more equitable distribution of resources.

56. Expand Edge-of-Grid lending and investments for rural economically 

disadvantaged and underserved communities. 

a. Reassess the criteria for qualifying for loans to ensure rural economically 

disadvantaged and underserved communities have access to edge-of-grid 

technology and promote the growth of edge-of-grid programs, such as the Energy 

Efficiency Conservation Loan Program (EECLP). 

b. Offer incentives for broadband deployment in remote rural areas to support 

electric cooperatives’ efforts in implementing edge-of-grid technologies for all 

member-consumers. 

c. Ensure that the implementation of the Justice40 Initiative is integrated into edgeof-grid lending and investment programs. 

18 Edge-of-grid lending refers to a new power-generation phenomenon where individual consumers not only produce electricity at home, but 

also contribute energy to the broader power grid. Solar, wind, and other renewable power generation technologies allow for individual 

consumers to produce the energy they consume. For more information, visit https://www.greentechmedia.com/articles/read/what-is-thegrid-edge. 
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Recommendation 57: Prevent Displacement through Equitable Land Zoning and Community 

Participation 

Infrastructure projects in rural communities can drive economic development and create 

opportunities for residents. However, these projects may also displace underserved and 

minority members of the community as rent and property values rise. The Equity Commission 

has identified the need to tie equitable land zoning policies and affordable housing to 

infrastructure and utility projects. Additionally, the Equity Commission believes engaging 

communities in the decision-making processes will ensure that future development aligns 

with local needs and values and is critical to ensuring equitable outcomes of infrastructure 

and utility projects.  

57. Ensure future infrastructure projects account for impacts to local communities 

particularly rural economically distressed and historically underserved 

communities. Specifically, USDA should: 

a. Assess the impacts of potential infrastructure projects on the displacement of local 

communities by developing criteria to evaluate the potential community 

displacement based on factors like number of households displaced, loss of 

cultural sites, disruption of local economies, etc. Review impact assessments to 

quantify predicted effects. 

b. As part of the decision-making process in infrastructure projects, increase funding 

for further engagements with local stakeholders through public consultations to 

ensure the project aligns with the community’s interests. This engagement should 

include inter-agency collaboration through programs like the Rural Partners 

Network. Measure stakeholder satisfaction through surveys and impact on 

decision-making through analysis of how feedback was incorporated. 

c. Strengthen its collaboration with local and regional governments to better 

understand the needs of rural communities by encouraging and incentivizing local 

policies and plans through qualitative review. 
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USDA EQUITY COMMISSION

Community Facilities

Recommendation 58: Expanded Financing Options for Community Facilities Projects 

The Equity Commission finds that the funding for investments in community facilities falls far 

short of the need for new and improved community facilities across rural America. We also 

find that community facilities are underfunded relative to other programs made available to 

rural communities by USDA RD. The community facilities program, if funded adequately, 

has the potential to solve the most basic needs of rural communities. With its significant rural 

footprint, strong capital position, and commitment to farmers and rural communities, the 

Farm Credit System (FCS) is well positioned to do more in rural communities. At present, 

FCS financing for community facilities for healthcare, food systems, and community support 

is limited and involves an inefficient and cumbersome investment process. Nevertheless, over 

the past decade the FCS has demonstrated its ability and interest in financing a number of 

successful community facilities projects. Allowing rural municipalities and community-based 

organizations greater access to financing for community facilities through the FCS would 

greatly improve rural healthcare, emergency services, and food systems in rural 

communities. Community facilities and infrastructure services must be considered as 

important as other RD programs to ensure the health and prosperity of rural communities. 

Healthcare, emergency services, and even housing could be addressed by just allowing 

communities to determine what is the most essential piece of infrastructure their community 

needs.

58. Partner with the Farm Credit System to ensure that the Community Facilities 

Direct and Guaranteed Loan and Grant Programs are eligible for additional 

financing through the Farm Credit System. Specifically, USDA should: 

a. Pursue changes to the current authorities and practices and partner with FCS to 

allow rural municipalities and community-based organizations to access financing 

through the FCS to fund community facilities projects. 

b. Continue to assess and prioritize removing barriers to accessing financing for 

community facilities. 

c. Allow rural communities to determine which facilities projects are most needed 

for their communities. 

Recommendation 59: Community Facilities Direct and Guaranteed Loan and Grant 

Program 

The Equity Commission has recognized the need to expand and invest in USDA Community 

Facilities Programs to create a prosperous Rural America. Other RD programs, such as 

Broadband and Rural Electric programs, are less restrictive and better funded relative to 

Community Facilities programs. The Commission believes that the Community Facilities 

Direct Loans and Grants programs should be made more accessible to smaller, rural 

communities [populations with less than 5,500]19. A significant portion of Community 

Facility funding is currently directed to communities in higher population counties; 75 

percent of project funding went to communities with populations over 20,000. Priority points 

should be awarded to lower population counties.

19 Small counties can be defined as counties less than 5,500 as distinguished from census tracts that fall below 5,500.
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

Note, socially disadvantaged individuals are those who have been subjected to racial or 

ethnic prejudice or cultural bias within American society because of their identities as 

members of groups and without regard to their individual qualities. The social disadvantage 

must stem from circumstances beyond their control20.

59. Expand access to USDA’s Rural Community Facilities Direct Loan and Grant 

Programs. 

a. Increase participation and funding for Socially Disadvantaged and underserved 

communities, specifically, USDA should focus on communities in counties with 

smaller populations (under 5,500). 

b. USDA should clearly differentiate between counties below 5,500 and 

communities in census tracts below 5,500 and how priority points are awarded for 

Community Facilities Programs. USDA should emphasize funding for counties 

below 5,500. 

c. Appropriate funds for counties with a population below 5,500 to automatically 

receive funding and increase their access to the Community Facilities Programs. 

Recommendation 60: Removing Barriers for Community Facilities Direct and Guaranteed 

Loan and Grant Programs 

The Equity Commission has recognized the need to expand and invest in USDA Community 

Facilities Programs to create a prosperous rural America. Previously, these programs have 

not been funded or accessible to many rural communities. A significant portion of 

Community Facility funding is currently directed to communities in higher population 

counties. Although Community Facility funding has increased, participation by small 

counties under 5,500 people has not increased. USDA should ensure that the current 

structure is not disenfranchising counties below 5,500 and underweighting towards the 

county population.

60. Remove barriers to participation in Community Facility Loan and Grant 

Programs for small and underserved communities in counties with less than 

5,500 people. 

a. Conduct an annual assessment on the distribution of Community Facility Loan 

and Grant funds to determine socially disadvantaged and underserved 

communities in counties with less than 5,500 people are fully accessing the 

program. This assessment should aim to increase participation and expand levels 

of sustained funding for such communities in more sparsely populated counties. 

Review the assessment quarterly. 

b. Based on the results of the assessment outlined in sub recommendation ‘a’, refine 

program requirements, application processes, priority points, and outreach efforts 

targeted towards socially disadvantaged and underserved communities in counties 

with less than 5,500 people. 

c. Seek additional appropriations to increase funding for the Community Facility 

Grant Programs. For socially disadvantaged and underserved communities in 

20 United States, Small Business Administration. "§124.103 Who is socially disadvantaged?" Electronic Code of Federal Regulations 

(eCFR), Title 13, Part 124, 27 Apr. 2023, https://www.ecfr.gov/current/title-13/chapter-I/part-124/subpart-A/subject-groupECFR4ef1291a4a984ab/section-124.103.
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USDA EQUITY COMMISSION

counties with less than 5,500 people, adjust the maximum percentage of cost of 

projects that grants can cover: 

i.From 75 percent to 100 percent for communities with a population of 5,000 

or less; 

ii.55 percent to 75 percent for communities under 12,000; 

iii.35 percent to 55 percent for communities under 20,000, without changing 

other eligibility requirements. 

d. Prioritize increasing funding for community facilities that bolster healthcare, food 

system, and community support (i.e., education, EMS/Fire first responders, 

housing, and childcare). 

Additional opportunities USDA should consider: 

a. Grant Approval:  

i. Applicant must be eligible for grant assistance, which is provided on a 

graduated scale with smaller communities with the lowest median 

household income being eligible for projects with a higher proportion 

of grant funds. Grant assistance is limited to the following percentages 

of eligible project costs:  

a. Maximum of 75 to 100 percent when the proposed project is:  

i. Located in a rural community having a population of 

5,000 or fewer; and 

ii. The median household income of the proposed service 

area is below the higher of the poverty line or 60 

percent of the State nonmetropolitan median household 

income. 

b. Maximum of 55 to 75 percent when the proposed project is:  

i. Located in a rural community having a population of 

12,000 or fewer; and 

ii. The median household income of the proposed service 

area is below the higher of the poverty line or 70 

percent of the State nonmetropolitan median household 

income. 

c. Maximum of 35 to 50 percent when the proposed project is: 

i. Located in a rural community having a population of 

20,000 or fewer; and 

ii. The median household income of the proposed service 

area is below the higher of the poverty line or 80 

percent of the State nonmetropolitan median household 

income. 

d. Maximum of 15 percent when the proposed project is: 

i. Located in a rural community having a population of 

20,000 or fewer; and 

ii. The median household income of the proposed service 

area is below the higher of the poverty line or 90 

percent of the State nonmetropolitan median household 

income. The proposed project must meet both 

percentage criteria. Grants are further limited. 
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iii. Grant funds must be available. 
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USDA EQUITY COMMISSION

XVII. Strengthening Rural Economies

USDA’s investments in rural economies are crucial to the prosperity of rural communities. 

USDA’s rural business loans, grants, and other programs play an important role in the 

economic development of rural communities. USDA’s support for rural cooperatives 

provides critical services to rural communities so rural citizens can participate in the local, 

regional and national economy. To advance equity and opportunity in rural communities, 

USDA must evolve its programs to support access and expand its investments in underserved 

communities.

Recommendation 61: Matching Waivers for RD Programs and Grants 

Many of USDA’s RD Programs and Grants require a matching contribution from a private 

or state entity. This requirement results in a barrier for small and underserved service 

providers that may not have access to capital. By following the precedent set by other federal 

agencies that have permanently waived match requirements as an equitable strategy, USDA 

can foster a more inclusive funding environment. While some matching waivers currently 

exist, many stakeholders are unaware of the process for requesting a waiver. Building on 

encouraging progress under the current Administration, this will ensure that more 

organizations can benefit from available resources.

61. Develop eligibility requirements and waivers of matching requirements that 

prioritize rural economically distressed communities and historically 

underserved communities, including Federally Recognized Tribes, and enhance 

access to USDA programs and services. Specifically, USDA should: 

a. Remove match requirements from the scoring rubric. 

b. Provide priority points for rural economically distressed communities and 

historically underserved communities. 

c. Clearly communicate the process to request waivers for matching funds to all 

service providers. 

d. While working to implement sub-recommendation ‘a’, establish a universal 

application to waive matching requirements for all programs. 

Recommendation 62: Rural Business Loans - Financing for Native Agricultural Producers by 

Microenterprise Development Organizations (MDOs)

According to the Intertribal Agriculture Council as well as Indigenous Food and Agriculture 

Initiative surveys21 of community organizations working on food systems and health issues in 

Indian Country, lack of funding, be it access to credit or other financial support, is the 

biggest barrier for Native producers. Additionally, farmers and ranchers from disadvantaged 

communities still face barriers in accessing affordable capital through USDA’s existing 

programs. USDA should open new forms of credit for producers by removing restrictions to 

the intermediary relending program that prevent IRP’s low interest loans from benefiting 

agricultural producers. Agriculture is one of the primary arenas of entrepreneurship in 

Indian Country with the three primary categories of agricultural loans being made for 

equipment, land purchases, and herd development. RD/USDA should be leading and 

supporting the growth of agriculture on the individual level, not prohibiting it. 

21 Akiptan. “2022 Market Study.” Akiptan, 2023, www.akiptan.org/2022-market-study. Accessed 18, February 2024. 
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

62. Allow all loans and grants administered by Microenterprise Development 

Organizations (MDOs) to serve agricultural operations and provide agricultural 

credit as defined in the Consolidated Farm and Rural Development Act, Con 

Act. Specifically, USDA should: 

a. Remove Agricultural production as an ineligible loan purpose S 4274.319 (f) in 

RD Instruction 4274-D for the Intermediary Relending Program. 

b. Remove agriculture producer as an ineligible ultimate recipient from Rural 

Business Development Grant Program. 

c. Pilot the program with 2-3 strong partner MDO’s and provide $5 million in direct 

financing for the MDO to provide agricultural credit to their target market, similar 

to the 502 Relending pilot done in South Dakota. 

Recommendation 63: Loan Loss Reserve Requirement

Each USDA loan product requires a 6 percent cash reserve for loan loss regardless of the 

portfolio health of the intermediary. Each lending entity submits a relending plan to USDA in 

the application process and describes its strategy for defaulting loans. A required cash loan 

loss reserve locks up capital for 30 years that could be flowing to the community and 

ultimate recipients.

63. Permanently remove the loan loss reserve (LLR) requirement for intermediary 

lenders that submit an acceptable strategy for handling defaulting loans. 

a. Require and include in the scoring that the Microenterprise Development 

Organizations (MDO) submit an acceptable strategy and track record for handling 

defaulting loans within their Revolving Loan Funds (RLF) Plan, with proof of a 

loan loss reserve contra-asset account established.

Recommendation 64: Equitable Lending Frameworks

Rural and underserved communities do not have ready access to philanthropy, corporate or 

individual partners. Therefore, they lack operational funding to implement the intermediary 

responsibilities which are required by RD’s lending programs. RD has a model program 

called Rural Microentrepreneur Program (RMAP) that offers administrative dollars 

alongside the loan, based off a formula. USDA could replicate this model across all its loan 

offerings to offer a more equitable lending framework.

64. Create and include administrative grants with every loan product to 

intermediary lenders. 

a. The 2018 Farm Bill amended Section 379E of the Con Act (Consolidated Farm 

and Rural Development Act) to require that grant amounts to Microenterprise 

Development Organizations (MDO) be in an amount equal to not less than 20 

percent and not more than 25 percent of the total outstanding balance of 

microloans made by MDOs. 
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USDA EQUITY COMMISSION

Recommendation 65: Investing in Cooperatives 

People in rural communities, and especially those in historically underserved communities, 

have sometimes lacked the ability to own and control the businesses that most directly impact 

their livelihood and families. One strategy that people have used in rural communities is the 

establishment of cooperative businesses where the people who use the businesses are the 

ones who own, control, and benefit from the business. Rural people have used cooperatives 

at scale to access agricultural markets and to ensure that rural people have affordable and 

reliable electricity, water, and telecommunications services. While the model has been used 

in many different sectors, it is especially prominent in both agriculture and utilities. More 

than 50 percent of all farmers in the U.S., including farmers from historically underserved 

communities, are members of farmer cooperatives. More than 40 million people in the U.S. 

are members of rural electric cooperatives. This strategy could be used in emerging sectors 

such as grocery, care economy, and converting small businesses to worker or consumerowned cooperatives.

65. Provide robust research, education, and technical assistance for rural people 

who seek to use cooperatives to access markets, services, and capture economic 

opportunities. 

a. Double the current investments in the Cooperative Services staff so that it can 

acquire, analyze, and share information about all types of cooperatives in rural 

areas—including emerging cooperative sectors such as those in the care economy 

and conversion of rural small businesses to worker or consumer owned 

cooperatives. 

b. Use the discretion provided in the Rural Cooperative Development Grant program 

to provide much larger, multi-year grants to cooperative development 

organizations, particularly in rural economically distressed and historically 

underserved communities. Congress and USDA should provide much greater 

financial resources for these grants, appropriating $20 million in funds. 

c. Allocate new resources and provide $300,000-$500,000 to utilize the voluminous 

new data provided by the Census Bureau Business Census, which in recent years 

has collected statistically significant data on cooperatives from different sectors to 

help inform policy makers and other stakeholders on how people are and can use 

cooperatives to grow their local economies. 

Recommendation 66: Rural Energy for America Program

The Rural Energy for American Program (REAP), established under the OneRD Guaranteed 

Loan Program in October 2020, provides financing and grants to agricultural producers and 

rural small businesses for renewable energy systems and for energy efficiency improvements. 

Producers can also apply for new energy efficient equipment and new system loans for Ag 

production and processing. 

REAP helps increase American energy independence by increasing the private sector supply 

of renewable energy and decreasing the demand for energy through efficiency improvements. 

Over time, these investments can also help lower the cost of energy for small businesses and 

producers.
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

This program could significantly enhance underserved areas with less expensive and 

alternative sources of energy. The Equity Commission has not been able to identify whether 

underserved areas are taking advantage of the program. USDA should identify any barriers 

to accessing REAP in underserved communities and adjust program requirements to further 

increase equity.

66. Expand opportunities for rural economically distressed and underserved 

communities to benefit from REAP through assessing where funding is going 

and refining program requirements to allow for greater access. 

a. Remove requirement for UEI (Unique Entity Identify) number for applications 

under $200,000. USDA has removed this requirement for Ag producers for the 

Farm Service Agency programs. The elimination of this requirement for smaller 

applications would encourage more applications and expedite the process. 

b. For smaller projects remove the requirements for a civil engineering report at time 

of application. Make the civil engineering report a condition of commitment for 

receiving the grant or loan. For rural areas and underserved communities, it is an 

access issue to entice and fund certain professional services during the application 

process. There are other USDA programs where certain professional services are 

a condition of funding. 

c. Provide grant/loan assistance in areas where it is expensive or difficult to access, 

whether through USDA State or National offices. This support will help bolster 

rural communities’ capacity to participate in the REAP program and access 

critical funding for energy projects. 
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USDA EQUITY COMMISSION

XVIII. Conclusion

The Equity Commission’s investigation and recommendations provide a comprehensive 

approach to addressing historical inequities within the USDA’s programs and services. The 

report highlights the need for targeted reforms that promote inclusivity and equal opportunity 

for all Americans, including those from historically marginalized communities. By 

considering the Commission’s guidance, the USDA can implement effective measures to 

eliminate systemic barriers and enhance fairness in agricultural support, rural development, 

and access to resources.

The Commission’s recommendations urge a transformative shift towards a 

“whole – of - household” approach, including the reinvestment in USDA staffing, the 

expansion of loan programs, the integration of housing as a critical infrastructure component, 

and the reevaluation of program criteria to support underserved communities better. 

Moreover, embracing technology to improve service delivery, forming partnerships that 

amplify local voices, and acknowledging the value of cooperatives are paramount for 

revitalizing rural economies and addressing the “left out” rural areas.

In conclusion, the Commission suggests that substantial investments, informed by rural and 

minority stakeholders, can bridge the gap between rural potential and achievement. A 

realignment of priorities, coupled with persistent evaluation, training, and policy adjustments, 

can fortify USDA’s role in facilitating equitable growth and affirm the right to fair access 

across its spectrum of influence. This commitment to equity can ensure that the USDA not 

only supports but also dignifies the diverse fabric of America's agricultural legacy and rural 

communities, that acknowledges historical injustice while also transforming challenges into a 

testament of national prosperity and resilience.
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Appendix A 

The Equity Commission members received briefings from the following USDA staff:

• Dr. Gbenga Ajilore, Senior Advisor, Rural Development

• Andrew Berke, Administrator, Rural Utility Service 

• Steffanie Bezruki, Chief of Staff, Rural Development 

• Robert Bonnie, Under Secretary, Farm Production and Conservation 

• Dr. Penny Brown Reynolds, Acting Assistant Secretary, Office of the Assistant 

Secretary for Civil Rights

• L’Tonya Davis, Chief Diversity and Inclusion Officer, Office of the Secretary 

• Zach Ducheneaux, Administrator, Farm Service Agency 

• Katharine Ferguson, Chief of Staff, Office of the Secretary 

• Claudette Fernandez, (Former) Senior Advisor Program Equity and Opportunity 

Strategy, Office of the Secretary 

• Rick Gibson, Senior Counsel, Office of the General Counsel 

• Dr. Dewayne Goldmon, Senior Advisor for Racial Equity, Office of the Secretary 

• Gloria Montaño Greene, Deputy Under Secretary, Farm Production and 

Conservation 

• Scott Marlow, Deputy Administrator, Farm Service Agency

• Chris Nelson, Associate Director, Office of Budget and Program Analysis 

• Jennifer Nicholson, Deputy Director, National Appeals Division 

• Carlos Ortiz, National Program Leader, National Institute of Food and Agriculture 

• Kimberly Peyser, Deputy Assistant Secretary, Administration

• Monica Rainge, Deputy Assistant Secretary for Civil Rights, Office of the Assistant 

Secretary for Civil Rights 

• Margo Schlanger, Senior Advisor, Office of the Secretary 

• Heather Dawn Thompson, Director, Office of Tribal Relations 

• Xochitl Torres Small, Deputy Secretary of Agriculture 

• Leslie Weldon, Former Acting Chief Diversity and Inclusion Officer, Office of the 

Secretary 

• Homer Wilkes, Under Secretary, Natural Resources and Environment 

• Frank M. Wood, Director, National Appeals Division
Final Report | Page 82 

USDA EQUITY COMMISSION

Appendix B 

The following list of resources was provided to Equity Commission. They are also available 

on the Equity Commission website https://www.usda.gov/equity-commission/resources 

Executive Orders

Executive Order 13985 On Advancing Racial Equity and Support for Underserved 

Communities Through the Federal Government

(Published January 20, 2021)

Memo to Agencies: Advancing Equity in Procurement

(Published December 2, 2021)

Executive Order 13988 Preventing and Combating Discrimination on the Basis of Gender 

Identity and Sexual Orientation

(Published January 20, 2021)

Memo to Agencies on Modernizing Regulatory Review

(Published January 20, 2021)

Executive Order on Transforming Federal Customer Experience and Service Delivery to 

Rebuild Trust in Government

(Published December 13, 2021)

Strategic Plan to Advance Diversity, Equity, Inclusion, and Accessibility in the Federal 

Workforce

(Published November 2021)

Executive Order on Further Advancing Racial Equity and Support for Underserved 

Communities Through the Federal Government

(Published February 16, 2023)

American Rescue Plan 

American Rescue Plan Website and Fact Sheet

American Rescue Plan of 2021

(Published February 22, 2021)

Advancing Equity through The American Rescue Plan Report

(Published May 2022)

Federal Government Resources

Agricultural Credit Needs and Barriers to Lending on Tribal Lands

(Published May 2019)

IT Modernization: USDA Needs to Improve Oversight of Farm Production and Conservation 

Mission Area

(Published September 23, 2021) 

USDA Market Facilitation Program: Oversight of Future Supplemental Assistance to Farmers 

Could Be Improved

(Published January 4, 2022)

GAO-12-976R, U.S. Department of Agriculture: Progress toward Implementing GAO’s Civil 

Rights Recommendations

(Published August 29, 2012)
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 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

GAO-09-62 U.S. Department of Agriculture: Recommendations and Options to Address 

Management Deficiencies in the Office of the Assistant Secretary for Civil Rights

(Published October 2008)

Information on Credit and Outreach to Socially Disadvantaged Farmers and Ranchers Is 

Limited

(Published July 11, 2019) 

Are Rights a Reality? Evaluating Federal Civil Rights Enforcement

(Published November 2019)

Engaging People with Lived Experience to Improve Federal Research, Policy, and Practice | 

U.S. Dept. of Health and Human Services

(Visited April 2023)

A Whole-Family Approach to Serving Families in Rural America | White House Domestic 

Policy Council 

(Published November 2016)

FACT SHEET: Biden-Harris Administration Announces New Measures to Promote Equitable 

Community Development

(Published June 27, 2023)

FACT SHEET: President Biden Announces Actions to Promote Educational Opportunity and 

Diversity in Colleges and Universities

(Published June 29, 2023)

Biden-Harris Administration Makes Historic, $11 Billion Investment to Advance Clean Energy 

Across Rural America Through Investing in America Agenda

(Published May 16, 2023)

Office of the Inspector General Assessments / Analyses

The Pigford Cases: USDA Settlement of Discrimination Suites by Black Farmers

(Published May 29, 2013)

Garcia v. Vilsack: A Policy and Legal Analysis of a USDA Discrimination Case

(Published February 22, 2013)

USDA Oversight of Civil Rights Complaints | USDA

(Published October 22, 2021)

Outreach and Assistance for Socially Disadvantaged Farmers and Ranchers and Veteran 

Farmers and Ranchers Program (2501 Program) in Fiscal Years 2018 and 2019 | USDA

(Published November 10, 2021)

Hispanic and Women Farmers and Ranchers Claim Resolution Process | USDA

(Published March 31, 2016)

Market Facilitation Program—Interim Report | USDA

(Published September 30, 2020)

Black Farmers Discrimination Litigation (BFDL) Audit Report

(Published December 2013)

USDA Reports, Resources, and Tools 

Heirs’ Property and Land Fractionation: Fostering Stable Ownership to Prevent Land Loss and 

Abandonment

(Published September 2019)

Civil Rights at the United States Department of Agriculture

(Published February 1997)
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USDA Oversight of Civil Rights Complaints

(Published September 2021) 

Implementation of the Civil Rights Action Team Report at USDA: An Interim Progress Report

(Published September 1997)

Independent Assessment of the Delivery of Technical and Financial Assistance: Civil Rights 

Assessment, Executive Summary

(Published March 31, 2011)

Independent Assessment of the Delivery of Technical and Financial Assistance: Civil Rights 

Assessment, Final Report (Also known as the “Jackson Lewis Report”) 

(Published March 31, 2011) 

Jackson Lewis Equity Recommendations

• USDA Exit Memo 2017

• The People’s Department – A New Era for Civil Rights

Equity at USDA Fact Sheet

2017 USDA Agriculture Census

Map Tool on the Census Website

USDA Direct Farm Loans Journey by GSA and FSA

(Published July 10, 2018)

USDA FY 2023 Budget Summary and 2023 USDA Budget Explanatory Notes

Tribal Consultations Website and Framing Papers (Published April 2022)

• Framing Paper: Economic Development 

• Framing Paper: Food, Safety, and Trade 

• Framing Paper: Farming, Ranching, and Conservation

• Framing Paper: Forests & Public Lands 

• Framing Paper: Education & Research

Your FSA Farm Loan Compass

(Revised March 2021) 

Office of the Ombudsperson at USDA

• Fact Sheet 

• Introduction to the Office of the Ombudsperson Presentation 

• Frequently Asked Questions

Farm Service Agency Committees: In Brief

(Updated January 29, 2021) 

Racial and Ethnic Equity in U.S. Agriculture: Selected Current Issues

(Published April 11, 2022) 

FSA County Committee Resources

• County Committee Federal Register Notice-33063, Page 8 (Published June 5, 2022) 

• 2019 Farm Service Agency County Committee Election Report (Published 2019) 

• County Committee Eligibility to Vote Factsheet (Published June 2022) 

• Code of Federal Regulations, Selection and Functions of Farm Service Agency State 

and County Committees (Published June 2012) 

• County Committee Frequently Asked Questions (Published June 2022) 
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Rural Data Gateway Website

(Viewed April 2023)

USDA Procurement Forecast Tool

(Viewed June 2023)

Discrimination Financial Assistance Program (Section 22007 of the Inflation Reduction Act)

• Program Press Release (Published July 7, 2023) 

• Program Website (Viewed July 7, 2023) 

• Program Fact Sheet (Published April 2023)

USDA Language Access Plan 

• Plan Press Release (Published November 15, 2023) 

• Language Access Website (Viewed November 15, 2023)

USDA Advisory Committee Reports

Advisory Committee on Minority Farmers Website (ACMF)

• ACMF Recommendations (Published 2012)

• Letter to Secretary Vilsack (Published October 2015) 

• ACMF Recommendations (Published February 2021)

Advisory Committee on Beginning Farmers and Ranchers Website (ACBFR)

Council for Native American Farming and Ranching Website (CNAFR)

• CNAFR Recommendations (Updated June 2018) 

A Time to Act: A Report of the USDA National Commission on Small Farms

(Published December 31, 1997)

Indian Country Extension Commission Report

(Published April 2022)

USDA Strategic Plan & Equity Action Plans

USDA Strategic Plan Fiscal Years 2022-2026 (Published March 2022)

USDA Equity Action Plan (Published April 14, 2022)

Equity Action Plans for all Agencies (Published April 14, 2022)

White House Convening on Equity (Recording of meeting hosted on April 14, 2022)

Executive Order 13985 RFI Summary Findings (Published April 14, 2022)

Blog Post: USDA Mission Areas, Agencies, and Offices’ Equity Action Plans Are Making 

Progress

(Published August 1, 2023)

USDA Equity Action Plans

(Viewed August 2023)

Other

Redefining Rural Towards a Better Understanding of Geography, Demography, and Economy 

in America’s Rural Places | Economic Innovation Group 

(Published March 2021)

Countering the Geography of Discontent: Strategies for Left-Behind Places | Brookings 

Institution

(Published November 2018)

Rural Development Hubs: Strengthening America’s Rural Innovation Infrastructure | Aspen 

Institute

(Published June 2020) 
Final Report | Page 86 

USDA EQUITY COMMISSION

Measure Up: Principles for Measuring Rural and Native Nation Development Progress | Aspen 

Institute

(Published June 2022)

Targeted Universalism Policy and Practice | Othering & Belonging Institute at UC Berkeley

(Published May 2019)

Advocating for Family Success – A 2-Gen Approach in Rural Settings | Highland County 

Community Action Partnership

(Viewed April 2023)

Improving Business Processes for Delivering Work Supports for Low-Income Families | Urban 

Institute

(Published March 2016)

Why Government Technologists Love the Domino’s Pizza Tracker | Statescoop

(Published September 2021)

Place-sensitive Distributed Development – A Strategy to Lift Up Rural Areas with Technology | 

Blandin Foundation

(Published November 2018)

Thrive Rural Framework Overview | Aspen Institute

(Viewed May 30, 2023)

CFPB Finalizes Rule to Create a New Data Set on Small Business Lending in America | 

Consumer Financial Protection Bureau

(Published March 30, 2023)

What Is Frontier? | National Center for Frontier Communities

(Viewed June 2023)

Rural Energy Program Draws Scrutiny over Biden Equity Plan | Politico

(Published July 27, 2023)
Final Report | Page 87 

 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

Appendix C

Transformational Capacity Building - Measure of Success

Suggested measures: 

• The stock of year-round, locally owned housing 

• Change in school enrollments 

• The number/ratio of disconnected youth 

• Increases in post-secondary educational attainment 

• Labor market participation rates per industry based on race, gender and disability status.

• Changes from an accurate baseline in the number and growth of locally owned 

enterprises and cooperative structure. Changes in race, ethnicity, and gender wage gaps. 

• Affordable childcare slots compared to demand

• Community college alignment with local economy 

• Aligned continuum of family services 

• Entrepreneurial growth as voluntary or involuntary (Is self-employment only an 

emergency response?)

• Dollar leakage in or out of the community 

• Change in air, water, housing quality 

• Economic and social impact of job retention

• Living wage requirements – and living wage job availability – in a region

• Change in household savings rates 

• Broadband coverage to homes rather than broadband “coverage” only on Main Street 

• Benefactors of investments. 

• Locally generated wages.

• Systems and policy changes that create equitable economic growth 

• Require all measures create no environmental damage/degrade.

Built

Have there been improvements in infrastructure? 

Financial

Has there been increased investment in the region?

• Amount of Leveraged funding for projects and programs 

• Adequate Technical Assistance funded. 

• Growth in operations 

Individual

Have people acquired or improved skills, or improved their health and well- being? 

• # locations of retail food businesses received TA 

• # of people receive TA 

• Improved working conditions. 

• # of referrals made to partner organizations 

• Amount of sales for affordable, nutritious, and culturally appropriate foods 

• Improved access to markets.
Final Report | Page 88 

USDA EQUITY COMMISSION

Intellectual

Is there greater knowledge, creativity or innovation in the region? 

• # of new programs offered from access points (example: RX-CSA’s or culturally 

diverse art integration) 

Natural

Has the work benefitted natural resources or the environment in the region? 

• $$ of sales from local farmers/ranchers/producers allowing for farmland to stay in 

production 

• # of effective agricultural or conservation practices.

Political

Has there been an increase in influence over decision-making and policies? 

• # of and type policies revised to support food access, affordability, and availability 

Social 

Have new relationships and networks been built? 

• # of minority-owned businesses that received technical assistance - 

• # of new collaborations formed as result of TA and how they impacted leveraged 

resources 

• Have low-income businesses or individuals, or minorities been involved in the design 

and implementation of strategies.

Cultural

Has the work supported/preserved valued assets-traditions or ways of doing things? 

• # Jobs created or retained for local and regional residents from low-income and 

moderate- income areas that reflect area demographics, including communities of 

color. 

• # Stories told that show impacts 

• Changes in ownership of or decision-making power over local resources. 
Final Report | Page 89 

 USDA EQUITY COMMISSION USDA EQUITY COMMISSION

Press Inquiries: press@usda.gov | Public Inquiries: EquityCommission@usda.gov

Equity Commission Website: https://www.usda.gov/equity-commission 
www.usda.gov/equity-commission

Shaping Change at USDA

EQUITY COMMISSION