RFI Summary Report

USDA Request for Information (RFI) Summary Report

Executive Order 13985 Advancing Racial Equity and Support for underserved communities.

Summary

On January 20, 2021, the President issued Executive Order 13985, which established that the Federal Government should pursue a comprehensive approach to advancing equity for all.  In response, USDA took immediate action with a series of activities aimed to meaningfully listen to internal and external stakeholders, understand where barriers to accessing USDA programs and services exist, and assess data to identify opportunities to advance equity.

USDA published and marketed a Federal Register notice that officially called on diverse stakeholders and customers to respond to a Request for Information (RFI) and provide written comments.  The public comment period was open between June 16 and August 14, 2021.  Concurrently, USDA held five public listening sessions in July 2021 attended by over 400 participants.

The RFI requested the following:

• Identify barriers that people of color and underserved communities and individuals may face in obtaining information from USDA.
• Identify opportunities in current USDA policies, regulations, and guidance to address systemic inequities.
• Input on how to best engage external stakeholders and community members representing marginalized, vulnerable, or underserved communities to increase participation in USDA programs, services, committees, and decision-making processes.
• Feedback on customer experience with USDA programs.

In response to the RFI, USDA received a total of 512 comments spanning topics from landownership to farmworker rights.  A total of 426 written comments were submitted to regulations.gov within the open comment period, 65 verbal comments were recorded from public listening sessions, and 21 comments were received via email.  Comments ranged in length from one sentence to up to twenty pages (the requested RFI page limit).

USDA heard from a range of stakeholders across the country including farmers, non-profit organizations, universities, and state, local, territorial, and Tribal governments.  Stakeholders also represented communities of color, LGBTQI+ communities, immigrants, rural communities, children and families, and more.  Some commenters shared their personal experiences engaging with USDA staff and programs while other commenters focused on department-wide or specific program equity concerns and recommendations.

Based on USDA’s analysis, this report provides a high-level summary of the key messages or themes from the RFI comments.  All public comments are accessible online at https://www.regulations.gov/document/USDA-2021-0006-0001.   While comments submitted after the comment period deadline were not included in this report, stakeholder feedback are regularly tracked and considered as part of the Department’s commitment to advancing equity at USDA and its programs.

RFI Summary Findings

USDA’s History of Discrimination

Hundreds of commenters express dissatisfaction that USDA has a long history of systemic racism and discrimination against people of color, particularly Black farmers.  Indigenous people, LGBTQI+ people, women, immigrants, and individuals living with disabilities were also named as marginalized groups that have been discriminated against throughout history.  Commenters generally agree discrimination continues today and urge USDA to address structures, policies, and practices that contribute to unequal access to programs, land, and capital.

Lack of Internal Diversity, Equity, Inclusion, and Accessibility (DEIA)

Many commenters recommend USDA look at internal policies and practices to root out discrimination and become a more equitable department.  Across the board, commenters agree USDA should implement mandatory Diversity, Equity, Inclusion, and Accessibility (DEIA) trainings for staff.  Recommendations from commenters place an emphasis on USDA diversifying staff at all levels and hiring bilingual and Native American staff for the Department to improve customer experience with unique needs of underserved communities in mind.

Barriers to Funding Opportunity and Program Access

Commenters urge USDA to ensure funds are distributed equitably and describe major challenges filling out program or funding applications. Recommendations include making the paperwork less burdensome, removing jargon and technical language, and translating all documents to various languages.  There is also overwhelming support for USDA to provide one-on-one technical assistance to decrease barriers for understanding program requirements.  

Barriers to Land Access, Ownership, and Retention

Many farmers and non-profits stated USDA should reduce barriers to owning and operating agricultural land in the United States.  Commenters recommend USDA increase funding opportunities for minority farmers, beginning farmers, and farmworkers and improve the loan process by reducing loan processing times and providing technical assistance.  Commenters also recommend USDA provide debt relief and improve access to markets for farmers of color to address the historic inequities faced by minority farmers and ranchers.

Need to Honor Trust & Treaty Responsibilities with Indian Tribes

Tribal producers, governments, and advocacy organizations recommend USDA respect Tribal nations’ sovereignty through strengthening the Nation-to-Nation relationship and regularly engaging in Tribal consultation.  They also suggest USDA should increase funding opportunities to support Tribal ownership, protection, and conservation of land and expand market opportunities for Tribal producers.  Suggestions were made for USDA to protect Tribal food sovereignty and address food access and nutrition security issues.

Need for Targeted Education, Outreach & Technical Assistance

Hundreds of comments highlight the need for USDA to build back trust with underserved communities by increasing outreach and targeted technical assistance.  Commenters agree USDA should provide technical assistance and translation services for all programs.  Commenters advise that USDA should partner with trusted local organizations and land-grant universities to support program outreach, delivery, and evaluation.  Commenters also recommend USDA increase recruitment, education, and job training for underserved communities by leveraging the Cooperative Extension System and workforce development partnerships.

Expanded Access to Nutrition Programs

Many comments are in support of USDA investing in underserved communities by strengthening food assistance programs.  Commenters made recommendations on ways USDA can expand program eligibility for the Supplemental Nutrition Assistance Program (SNAP), the Special Supplemental Nutrition Program for Women, Infants and Children (WIC), and for free or low-cost meals through the National School Lunch Program (NSLP).  Commenters also recommend USDA expand online purchasing options and access to nutritious and culturally appropriate foods.

Strengthening USDA’s Civil Rights

Commenters expressed concerns on how the Office of the Assistant Secretary of Civil Rights (OASCR) handles discrimination complaints which have resulted in lost complaints, long processing times, and/or unfair outcomes.  Commenters recommend USDA reform the Office of the Assistant Secretary of Civil Rights (OASCR) to be more equitable and settle longstanding complaints and cases.  There was also commenter support to improve the complaint process by making it more efficient, easier to navigate, and more transparent.

Customer Experience

Across USDA grant, loan, and food assistance programs, commenters advocate for modernizing and streamlining applications and benefit delivery systems to improve customer experience.  Recommendations from commenters place an emphasis on USDA offering service and benefit delivery options via the phone, online and in person and ensuring local offices are properly staffed to effectively provide services.  Commenters also highlight the need for increased transparency around application timelines and decisions.

Conclusion

USDA is grateful for the collaboration and participation of customers and stakeholder groups in providing feedback in how we can break the cycle of inequities at USDA and its programs once and for all.  All too often programs have been designed to benefit those with land, experience, money, and education while leaving behind those without means, resources or privilege of one kind or another.  Because of the flawed design of programs as well as individual acts of discrimination, over the course of decades, many underserved producers have lost equipment, land, farm operations, and opportunities to train future generations of diverse producers.  In some cases, they lost their family home and valued links to their culture, history, community, and identity.  These losses have been devastating. USDA must take accountability for its role in the precipitous decline in the number of Black farmers in the United States and for erecting barriers that have kept other underserved communities including Native Americans, beginning farmers and ranchers, veteran producers, farmworkers, and other underrepresented groups from full and fair access to USDA programs and services, including but not limited to USDA farm programs.

USDA is off to a strong start using both discretionary and new authorities, and historic investments that both American Rescue Plan Act (ARPA) and the Bi-Partisan Infrastructure Investment and Jobs Act provide.  Based on early lessons learned and stakeholder input, USDA staff offices, mission areas, and programs were directed to coordinate, develop, and implement their respective key actions to comprehensively incorporate equity into farm, family, and food programs that touch every American’s life – including fortifying civil rights where improvements need to be made.  As guided by data, RFI and stakeholder input, and EO13985 requirements, USDA responded to the stakeholder input by considering and integrating them in agency and mission area equity action plans and other policy decisions aimed at building trust, reducing barriers, increasing investments and benefits in underserved communities, upholding civil rights, and strengthening our trust and treaty responsibilities with Indian Tribes.

The RFI and stakeholder input also simultaneously informed what USDA must do internally to create new norms, practices, structures, and an organizational culture that consistently and systematically places equity at the center of program design, implementation, and evaluation.  The Department will also provide concurrent attention to creating an organizational culture that embraces internal diversity, equity, inclusion, and access (DEIA).  A DEIA Strategy is currently underway that ensures USDA has an organization that is reflective of America and able to meet the needs of underserved communities.  Moreover, the launch of the Equity Commission in Feb 2022 further strengthens partnerships with diverse stakeholder groups in providing honest and sound recommendations that USDA can consider – so with time – USDA becomes known as a trusted partner that does right by underserved communities and thus live up to its name as The People’s Department now and for future generations.  It is our intent to continuously partner and engage with a diversity of stakeholders to build trust and make progress in a way that truly and regularly considers what our customers expect.

Ongoing updates on progress addressing RFI Stakeholder comments as mentioned in this report can be reviewed on the USDA Equity Website.