NCFC Submits Comments to U.S. Department of Agriculture on Proposed Agency Reorganization

Submitted electronically to: reorganization@usda.gov

 

August 28, 2025

 

The Honorable Brooke L. Rollins
Secretary
U.S. Department of Agriculture
1400 Independence Avenue SW
Washington, DC 20250

 

Dear Secretary Rollins,

The National Council of Farmer Cooperatives (“NCFC”) appreciates the opportunity to provide the following comments on the U.S. Department of Agriculture Reorganization Plan as outlined in the July 24, 2025, Secretary Memorandum: SM 1078-015.

American agriculture is a modern-day success story. America’s farmers produce the world’s safest, most abundant food supply for consumers at prices far lower than the global average. Farmer cooperatives – businesses owned, governed, and controlled by farmers and ranchers – are an important part of the success of America’s agricultural supply chain. Today, farmer co-ops across the country have over $300 billion in annual sales. They represent 1.8 million farmer members and provide over 200,000 jobs with a payroll of over $8 billion.

Since 1929, NCFC has been the voice of America’s farmer-owned cooperatives. We have an extremely diverse membership, which we view as one of our sources of strength – our members span the country and handle, process, and market almost every type of agricultural commodity; furnish farm supplies; and provide credit and related financial services, including export financing. Earnings from these activities are returned to their farmer members on a patronage basis, helping improve their income from the marketplace.

NCFC members include:

• Marketing cooperatives – which handle, process, and market virtually every commodity grown and produced in the United States.
• Bargaining cooperatives – which bargain to help their farmer members obtain reasonable prices for the commodities they produce.
• Farm supply cooperatives – which are engaged in the manufacture, sale, and/or distribution of farm supplies and inputs, as well as energy-related products, including ethanol and biodiesel.
• Credit cooperatives – which include the banks and associations of the cooperative Farm Credit System, and which provide a competitive source of credit and other financial services, including export financing, to farmers and their cooperatives.

NCFC upholds four core values as it works to advance the business and policy interests of America’s cooperatives and other farmer-owned enterprises.  These values are (1) farmer ownership and control in the production and distribution chain, (2) continued economic viability of America’s farmers, ranchers, and the businesses they own, (3) the stewardship of the natural resources entrusted to their care, and (4) vibrant rural communities.

Whether it means ensuring families have food on the table or supporting employees who serve double duty as volunteer firefighters and emergency rescue personnel in their communities, farmer cooperatives regularly and as a normal course of their operations step up when it counts. Some programs address immediate needs such as disaster relief, while others occur year after year until they become a neighborhood tradition. No matter the occasion, cooperatives go far beyond their normal business activities to actively help meet the needs in their local communities.

USDA–Cooperative Partnerships

Farmers and their cooperatives depend on USDA as both a regulator and a partner in advancing rural prosperity. Our members work hand-in-hand with USDA’s field offices every day—accessing programs that support farm income, build rural infrastructure, strengthen conservation practices, and expand access to food and nutrition. The strength of this partnership rests on USDA’s deep local presence and its ability to deliver programs in a responsive, place-based manner. As USDA considers reorganization, we urge the Department to preserve and build on these strengths.

For example, agricultural cooperatives are uniquely positioned to help USDA deliver technical assistance that is practical, trusted, and scalable. As farmer-owned businesses, co-ops already serve as a primary resource for producers seeking agronomic advice, conservation strategies, and risk management tools.

The current Technical Service Provider (TSP) program has struggled to keep pace with producer demand—limited availability, uneven geographic coverage, and slow contracting all hinder access. Cooperatives can help fill that gap and reduce the department’s growing backlog. By partnering with co-ops, USDA can leverage existing local relationships, expand outreach to hard-to-reach producers, and ensure that technical assistance reflects on-the-ground realities.

This collaboration enhances program adoption, accelerates conservation outcomes, and builds producer confidence in program delivery. Simply put, when USDA and co-ops work together, producers gain access to timely, relevant, and farmer-driven support that strengthens both rural communities and U.S. agriculture.

Agriculture Marketing Service & Commodity Procurement

NCFC members work closely with the Agricultural Marketing Service (AMS), and we respectfully encourage USDA to maintain the ability of AMS Commodity Procurement staff to respond in a timely and effective manner to industry needs.

We understand that the Department intends to continue providing high levels of service to farmers and ranchers through local FSA offices following the reorganization. However, the memorandum of July 24, 2025, does not provide clarity regarding potential changes in the procurement activities conducted by AMS. Purchases made by AMS, both for USDA Foods destined for schools and household programs, as well as through Section 32 authorities, can directly affect thousands of growers through the actions taken with a single processor. It is therefore essential that experienced personnel be retained, and that sufficient staff remain available to conduct these purchases in a timely manner.

We would be concerned by any effort to merge AMS Commodity Procurement activities into the larger Office of Contracting and Procurement (OCP). The work of OCP generally involves less time-sensitive contracts with longer planning horizons, which are fundamentally different from the short turnaround and market-sensitive demands of food commodity procurement.

When a Section 32 purchase is requested to support a commodity facing market distress, USDA officials analyze data, request additional information as warranted, and engage with applicants to determine an appropriate course of action. It is unclear how this process might change under the reorganization. Similarly, because the Food and Nutrition Service (FNS) sets specifications for USDA Foods used in schools and households, more information is needed on how AMS and FNS will interact under the proposed structure.

We support USDA’s stated goal of ensuring efficiency and effectiveness across all its operations. We look forward to collaborating with the Department in pursuit of these goals. We respectfully urge USDA to solicit additional comments should further details be developed regarding AMS Commodity Procurement operations and personnel.

Protect and Strengthen Field-Based Service Delivery

USDA’s county and regional staff are a trusted first point of contact. They provide critical technical assistance and help navigate complex programs, ensuring that federal investments align with local realities. Any reorganization must protect this footprint by:

• Maintaining adequate staffing levels in field and county offices;
• Backfilling vacancies before further consolidation; and
• Ensuring that regional hubs complement—rather than replace—local authority and service delivery.

Preserve Rural Development and Cooperative Support within USDA

USDA Rural Development, and especially the Rural Business-Cooperative Service (RBCS), plays a unique role in fostering cooperative businesses and investing in the backbone of rural America—housing, water, broadband, and community infrastructure. These responsibilities must remain within USDA, where staff have both the institutional expertise and local presence to serve rural communities effectively. Weakening or transferring these authorities would jeopardize access for farmers and rural citizens.

Ensure Service Continuity During Transition

Reorganization must not disrupt the flow of critical services—whether nutrition assistance, conservation support, or cooperative development resources. USDA should establish clear continuity-of-service protocols, including transparent communication to stakeholders, to minimize disruptions that could delay projects or harm rural families.

Engage Stakeholders Early and Often

Farmer cooperatives stand ready to partner with USDA in this process. We urge the Department to institutionalize stakeholder engagement—through listening sessions, advisory bodies, and formal consultation mechanisms—so that local realities inform national restructuring decisions.

Balance Efficiency with Responsiveness

NCFC supports USDA’s goals of improving efficiency, reducing duplicative processes, and modernizing through technology upgrades. However, efficiency must not come at the expense of responsiveness or the specialized expertise that farmer cooperatives and rural communities rely on. A “one-size-fits-all” approach risks undermining USDA’s ability to meet diverse local needs.

Conclusion

The success of USDA’s reorganization will be measured not by internal restructuring charts, but by how well farmers, cooperatives, and rural communities continue to access and benefit from USDA programs. Preserving USDA’s field-based capacity, strengthening Rural Development and cooperative support, and ensuring continuity of service are essential to maintaining trust and delivering on USDA’s mission.

NCFC and our members remain committed to working alongside USDA to ensure this reorganization strengthens, rather than weakens, the Department’s role as a partner to America’s farmers and rural communities.

 

Sincerely,

Duane Simpson
President & CEO