For Immediate Release
Contact: Laura Zaks
National Sustainable Agriculture Coalition
press@sustainableagriculture.net
Release: NSAC Urges Reconsideration of Problematic OMB Proposed Rule
Washington, DC, July 14, 2026 – Yesterday, the National Sustainable Agriculture Coalition (NSAC) submitted detailed comments to the Office of Management and Budget (OMB) citing major concerns with OMB’s proposed Regulation for Federal Financial Assistance and urging the agency to rescind the rule in its entirety. NSAC warned that the proposal would inject new uncertainty and risk into an already fragile agricultural sector and undermine the US Department of Agriculture’s (USDA) ability to fulfill its mission.
In its 20‑plus page comment letter, NSAC outlines concerns with the proposal, including, as the comment states:“new and expanded discretionary suspension and termination authority; legal and compliance concerns regarding vague and undefined terms; added burdens on funding recipients and particularly on farmers and partnership projects; politicization of grant review and funding decisions; conflicts with USDA’s own statutory authorities; and an overall lack of clarity regarding scope and applicability to USDA grantees.”
“Each of these concerns alone is significant enough to warrant substantial revision,” said Sophia Kruszewski, NSAC Deputy Policy Director. “Taken cumulatively, they illustrate the dire need to rescind the proposed rule in its entirety and restart the rulemaking process from the beginning, taking care to ensure there are multiple meaningful opportunities to effectively solicit and integrate USDA-specific facts, legal authorities, and stakeholder input.”
NSAC’s comment emphasizes that many of USDA’s most important farm bill and rural development programs, including farmer conservation program contracts, beginning farmer training programs, local and regional food system initiatives, and critical agricultural loan programs, could be destabilized if funding agreements can be suspended or canceled at any time at the political discretion of agency leadership.
“Since January 2025, sudden funding freezes, unanticipated grant terminations, and abrupt full program cancellations—not to mention a woefully understaffed USDA—have upended farmers’ business plans and planting decisions, delayed and prevented farmland purchases, prompted layoffs, and left farmers in the lurch awaiting reimbursements for purchases made under duly executed agreements. Agriculture will always have disruptive events, from market disruptions and natural disasters to pandemics and pests. Yet, the structure of federal policy determines the impact of those disruptions on farm families, their communities, the land, and the country. The federal government should offer more, not less, certainty and stability for farmers already confronting the compounding impacts of increasing production costs, decreasing income, rising land prices, lost markets, and evolving pest pressures,” the comment states.
###
About the National Sustainable Agriculture Coalition (NSAC)
The National Sustainable Agriculture Coalition is a grassroots alliance that advocates for federal policy reform supporting the long-term social, economic, and environmental sustainability of agriculture, natural resources, and rural communities.
Learn more and get involved at: https://sustainableagriculture.net
Leave a Reply
Facts Only
* The National Sustainable Agriculture Coalition (NSAC) submitted comments to the Office of Management and Budget (OMB).
* The comments concerned OMB’s proposed Regulation for Federal Financial Assistance.
* NSAC urged the agency to rescind the rule in its entirety.
* Concerns raised included new and expanded discretionary suspension and termination authority.
* Other concerns involved legal/compliance issues related to vague terms, added burdens on funding recipients, politicization of grant review, conflicts with USDA statutory authorities, and lack of clarity on scope.
* NSAC stated these concerns require substantial revision or rescission and restarting the rulemaking process.
* Specific programs mentioned include farmer conservation program contracts, beginning farmer training programs, local/regional food system initiatives, and agricultural loan programs.
* The coalition noted that funding freezes and grant terminations since January 2025 have upended business plans and prompted layoffs.
Executive Summary
The National Sustainable Agriculture Coalition (NSAC) submitted comments to the Office of Management and Budget (OMB) regarding a proposed Regulation for Federal Financial Assistance, urging the agency to rescind the rule entirely. The coalition expressed major concerns that the proposal would introduce new uncertainty and risk into the agricultural sector and hinder the USDA’s mission. Specific concerns raised included new discretionary suspension/termination authority, vagueness in terminology, added burdens on recipients, politicization of funding decisions, conflicts with USDA statutes, and a lack of clarity regarding applicability to grantees.
NSAC argued that these concerns necessitate rescinding the rule and restarting the rulemaking process to allow for more inclusive solicitation of stakeholder input. The coalition further emphasized that sudden funding freezes, grant terminations, and program cancellations since January 2025 have disrupted farmers' business plans, delayed land purchases, prompted layoffs, and caused reimbursement delays. They asserted that federal policy structure dictates the impact of external disruptions like market shifts or natural disasters on farm families.
Full Take
The core dynamic presented is a conflict between centralized administrative authority (OMB/USDA) and the operational needs of the agricultural sector, framed by concerns over stability versus discretion. The argument pivots on whether centralized control over funding mechanisms creates systemic fragility rather than targeted governance. NSAC’s insistence on restarting rulemaking highlights a fundamental disagreement over process: whether policy creation must prioritize procedural inclusivity (soliciting stakeholder input) or administrative efficiency.
The narrative employs an appeal to the concrete, lived experience of farmers—disruptions from market volatility and environmental pressures—to frame abstract regulatory concerns. This connects macro-level administrative uncertainty directly to micro-level economic precarity. The pattern observed is the framing of policy as a direct determinant of existential risk for specific communities, utilizing fear appeals based on tangible impacts (layoffs, delayed purchases) to advocate for structural change.
The implication lies in recognizing how procedural rigidity can exacerbate existing vulnerabilities. When discretion is expanded—as alleged by NSAC—the mechanism shifts from predictable administration to potential arbitrary action, irrespective of the agency's stated mission or statutory context. The missing piece of analysis involves examining whether the critique of discretionary power supersedes the need for predictable financial mechanisms in a system already stressed by external shocks. What specific historical patterns exist where administrative discretion has demonstrably magnified negative outcomes for resource-dependent groups?