At the start of this year, the California Department of Food and Agriculture (CDFA) established a Regenerative Agriculture Work Group to assist the State Board of Food and Agriculture in defining “Regenerative Agriculture.” We submitted the letter below as our public comment on the matter to represent how we believe the term should be defined.
Dear CDFA:
Thank you for the opportunity to comment on the proposed definition of regenerative agriculture in California. Our family company, Dr. Bronner’s, is located in Vista, North County San Diego, employs over 300 people and generated $200 million in net revenue last year. We source our major raw materials from farming communities around the world that are certified to the Regenerative Organic Certified ® standard. I’m including two blogs I wrote as part of my formal comment here: the first Regenetarians Unite that led to the formation of the Regenerative Organic Certification ® standard that we helped launch with our partners at Patagonia and Rodale; and the second Regenerative Agriculture: the Good the Bad and the Ugly.
Summarizing the latter, there’s widespread agreement in the movement about what constitutes regenerative practices on a farm or ranch: managed grazing, cover crops, diverse crop rotations, minimal soil disturbance, etc. However the focus of my blog and comment here is on off-farm feed and synthetic inputs, which is under-appreciated and if not addressed in a real and credible way, will undermine the promise that regenerative agriculture has to mitigate climate change and restore soils.
Starting with off farm feed, something like 40% of American ag land is dedicated to growing feed crops—soy, corn and alfalfa for livestock—generally raised in confined animal feeding operations, or “factory farms.” The general regenerative consensus is that cows, pigs, and chickens should be raised on pasture in a way that is beneficial to the soil biology and ecology of a given farm or ranch. However, monogastric pigs and chickens are omnivores like us, and require just as much if not more grain when raised on pasture than their factory farm counterparts. They can supplement with insects, worms and seeds on pasture, but still require most of their caloric intake from grain. Nothing will change the vast monoculture deserts of soy and corn in this country, if the definition for regenerative livestock does not address how the off farm feed is grown. If that feed is grown in a regenerative way, great, but if its not then just measuring soil carbon on a given ranch gives a false impression of regenerative impact, when the soil that the feed is grown in is being stripped of fertility and life. So defining regenerative in a way that accounts for how off farm feed is grown for livestock is key, not simply what the practices and soil carbon levels are on a given farm or ranch that livestock are being raised on.
As far as synthetic fertility and pesticide inputs, regenerative practices will turbocharge the soil biology and fertility of a given farm or ranch, allowing for the reduction and eventual elimination of synthetic inputs over time. Especially synthetic nitrogen that is the largest greenhouse gas contributor in agriculture. The test of a true regenerative farm or ranch operation is being able to graduate off synthetic fertility and pesticides at some point. If we define “regenerative agriculture” to not include the reduction and eventual elimination of synthetic inputs, then we will sabotage the promise that regenerative ag has of mitigating climate change. It is of course awesome to cut synthetic inputs in half, but if that’s all regenerative ag accomplishes, then that’s like saying to the automobile industry in California, it’s OK for fleets to go hybrid as the end goal, and not worry about going completely electric. Cutting fossil fuel reliance in half via hybrid technology is great, but it’s also not remotely good enough; going completely off fossil fuels is what we need, and we should define the end goal of regenerative ag similarly. A farm or ranch is regenerative to the extent that they graduate off synthetic fertility and pesticides in some reasonable time bound way. Rick Clark for example who farms 7,000 acres organic no till in Indiana, advises five to seven years is plenty of time.
California also has the opportunity to define regenerative ag more expansively to include fair labor and animal welfare criteria, rather then just in terms of soil health. We envision a regenerative future where people, land and animals are treated with respect, and rural economies are thriving. My two blogs linked above go into these and other issues in more depth, and I hope regenerative agriculture in California sets a real credible bar and example for the rest of the world to follow.