People send me stuff. Here’s an email worth reading. Comment deadline is today. – Anthony
The USDA, as expected, will likely try and use Section 5 of the Commodity Credit Corporation Charter Act to push the administration’s climate change agenda. This would allow the administration to potentially spend billions of dollars to push its agenda without getting Congressional approval:
Today is the last day (you have until 11:59pm Eastern tonight) to submit comments to the CCC’s request for information regarding its Climate-Smart Agriculture and Forestry Partnership Program.
My comment is attached.
If possible, please try and submit comments arguing that the USDA does not have the statutory authority for its Climate-Smart Agriculture and Forestry Partnership Program.
It can be really short; submitting even a paragraph would be useful.
Suggested points in a brief comment
– Section 5 of the Charter Act expressly says that any environmental program must be authorized. This program has not been authorized.
– Trying to use 5(e) ignores the plain language of 5(g) dealing specifically with environmental programs.
– The program can’t be created just because it would allegedly be marketing “climate-friendly” commodities when it is obviously an environmental program focused on environmental issues, with this alleged marketing benefit being an obvious pretext to get around the statute.
– By the CCC’s logic, the USDA could always create unauthorized environmental programs inconsistent with the plain language of the statute if the USDA can claim some benefit to the marketing of commodities. This would render the environmental provision superfluous.
– The CCC is trying to do an end-run around Congress and the plain language of the Charter Act.
Submit a comment here: http://www.regulations.gov/commenton/USDA-2021-0010-0001