This commentary, written as an open letter to Secretary of Natural Resources Julie Moore, is by James H. Maroney Jr., who has a masterโs degree in environmental law & policy from Vermont Law School, a master’s degree in business administration and is a former organic dairy farmer.
Dear Secretary Moore,
As you know, it is the goal of the state of Vermont to reduce emissions of greenhouse gases not less than 26% from 2005 greenhouse gas emissions by 2025; not less than 40% from 1990 greenhouse gas emissions by 2028; not less than 80% from 1990 greenhouse gas emissions by 2050. I am writing to warn you that the Initial Climate Action Plan for the agricultural sector is not written to meet these targets. It is written with the express intention of shielding the conventional Vermont dairy industry from the kind of regulations that would.
The Initial Climate Action Plan suggests, โThe main mitigation options within the agricultural sector comprise three strategies: prevention, sequestration and substitution.โ But the plan does not list the strategy its authors have apparently chosen: compensation.
I could take up the councilโs prescriptions one by one and explain why this one or the other is inadequate or just plain wrong. I might point out, for example, that the Climate Councilโs Initial Climate Action Plan for the agricultural sector does not, in pp. 109-127 inclusive, once mention โfossil fuels.โ I might also point out that farmers, who are described in the plan as โmotivated to be part of the climate change solutions and many already include climate mitigation as a major goal in managing their farm,โ have had ample opportunity over the past thirty or forty years to adopt a โsustainableโ business model and they have not done so. But in a word, my complaint boils down to this: the Climate Councilโs Initial Climate Action Plan is a bold-faced defense of the status quo.
The council, in keeping with a generations-old Vermont tradition, is attempting to greenwash conventional agriculture, to redefine it so that the public will perceive the industry not as part of the problem but as an important part of the solution. The council suggests that cover crops, nutrient management, manure management, reduced tillage and riparian tree plantings will reduce greenhouse gas emissions from โagriculture.โ But these practices have been available to the industry for decades and they will never โ and can never โ reduce greenhouse gas emissions from the agricultural sector by 26% by 2025, let alone 40% or 80%.
The reason is simple: the Agriculture and Eco-Systems Subcommittee of the Climate Council does not anywhere acknowledge that one of the main drivers of climate change โ and one of the three reasons the legislature enacted the Global Warming Solutions Act โ is the 70 years long application in Vermont of conventional agriculture.
Recommending that Vermont farmers continue to farm conventionally as a strategy for mitigating greenhouse gas emissions is the rough equivalent of recommending air conditioning as the best way to cool hot office buildings and schools.
Second, the Agriculture and Eco-Systems Subcommittee suggests that of the three options, sequestration โyields the most co-benefits, is the easiest and most immediate to implement.โ
But the strategy the Council recommends does not strike at the root cause of greenhouse gas emissions from agriculture, and that is the GWSAs legislative intent.
Compensating for a problemโs cause is frequently recommended when those charged with addressing it want to deflect attention away from the problemโs cause. For example, in 2018, the Vermont Department of Environmental Conservation, the Vermont Legislature, the University of Vermont, and local community members were forced to address pollution problems in Lake Carmi. DEC determined that a key driver of cyanobacteria blooms was the โenrichment of phosphorus in the lakeโs sediment (legacy phosphorus) due to many decades of human activities in the lakeโs watershed such as farming and shoreline development.โ These agencies decided to install an aerator in the lake. But the aerator was chosen to compensate for the problem, which to the surprise of almost no one was โrun offโ from area conventional dairy farms, not to solve it at its source.
Here is another relevant example: the University of New Hampshire has suggested that feeding cows seaweed as a part of their diet can lower bovine enteric methane by as much as 30%. Sounds good! But feeding seaweed is a compensating tactic designed only to address societyโs concerns about greenhouse gas emissions while leaving conventional dairyโs protocols intact. Aside from cost and availability, hereโs the problem with the introduction of seaweed: dairy farmers would still be farming conventionally, still planting 90,000 acres of corn in the floodplain, still applying artificial fertilizer and herbicides and still overproducing their markets and driving down farm prices.
The proximate cause of 45% of lake pollution and 16% of greenhouse gas emissions attributable to โagricultureโ is the broad-based application of petroleum-based artificial fertilizer and herbicides, which is admittedly efficient, but by no means necessary. The best way to reduce greenhouse gas emissions from โagricultureโ is, as suggested in the GWSA, โSubstitution โ substituting biological products for fossil fuels or energy-intensive products, thereby reducing CO2 emissions.โ And what this means is Vermont dairy farmers must discontinue their reliance on fossil-fuel-derived fertilizer and herbicides.
I readily admit that farming is not โnatural,โ but it is how we grow our food. Crop rotation is the closest thing to a โnaturalโ process for restoring soil fertility, and cultivation is the closest thing to a โnaturalโ process for controlling weeds. But crop rotation and cultivation are slow and expensive.
Conventional farming was designed to circumvent the โnaturalโ processes and speed them up. This was the advantage, and farmers were quick to catch on. But conventional farming is not natural, and fossil-fuel-derived fertilizer and herbicide are not biological products. Notably, the GWSA supports natural practices: Act 153, ยง592 (7)(d)(7) states that the state shall โsupport the use of natural solutions to reduce greenhouse gas emissions.โ
This year, Canada, the Netherlands and Ireland all determined that to meet their ambitious climate mitigation targets โ which are identical to Vermontโs โ farmers must reduce the use of artificial fertilizer by 30%. Predictably, Canadian and Dutch farmers are not happy with these policies. Notably, both Canada and the Netherlands farms must produce food to feed their people and dramatically cutting the use of fertilizer will unquestionably affect yields and/or raise the cost of food for millions. But Vermonters import 85-90% of their food, which means Vermont agriculture can tolerate reductions in artificial fertilizer without inviting food insecurity.
As difficult and disruptive as reforming Vermont dairy will undoubtedly be, the consequences of continuing to permit conventional farming are far worse: greenhouse gas emissions from โagricultureโ will continue to build up in the atmosphere and the apocalyptic effects of climate change will soon go beyond our ability to manage them.
To my knowledge, Vermont has never once asked openly whether conventional farming is doing the state more harm than good and the greenwashing of conventional Vermont farming continues at the very highest level to this day. To wit, The Governorโs Commission on The Future of Vermont Agriculture (Nov. 15, 2021) does not mention the dairy industryโs out-sized dependence on fossil fuels, the GWSA or the industryโs contribution to greenhouse gas emissions. The Report from the Governorโs Task Force to Revitalize the Vermont Dairy Industry (December 2019) does not contain the words conventional, organic, fossil fuel or climate change.
The state of Vermont has never acknowledged conventional agricultureโs externalities; but because the GWSA requires the state to lower its greenhouse gas emissions 26% by 2025, and because conventional agriculture and the GWSA are patently contra-indicated, it is incumbent upon the State to acknowledge them without delay.ย
The GWSAโs legislative intent is to dramatically lower societyโs reliance on petroleum products and do so as soon as possible. But with the TCI and the Clean Heat Standard both in doubt, and with plans to compensate rather than reduce emissions from โagricultureโ at their source, the chances that Vermont will meet its first GWSA target are remote. And unless the State changes course now, its chances of meeting its second and third targets are worse than remote.
