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March 18, 2022

USDA Office of Urban Agriculture and Innovation Production

RE: Call for Comments on Urban Agriculture Funding and Support


Pasa Sustainable Agriculture represents many urban agriculture groups and farmers across Pennsylvania and the Mid Atlantic region among its 7,500 members and 60,000-member outreach community. Feedback from our staff who work with urban agriculture practitioners, particularly in Philadelphia, Pittsburgh and Harrisburg, are reflected in the general and specific comments below. We appreciate the opportunity to share these comments with USDA, and urge the Department to continue to expand financial and technical support for this growing and vibrant sector of the farm economy. We are witnessing an explosion of interest among urban farmers and gardeners, a trend that predates the COVID 19 pandemic but has accelerated in response to breakdowns in the food production supply chain, growing areas of food insecurity, and the growing realization of the importance of locally grown, healthy and nutrient-rich food. 

General Comments

The City of Philadelphia has become a hotbed of urban agriculture, with many groups working to grow food under difficult circumstances – including contaminated soils, limited technical assistance, and legal imbalances that prioritize commercial and residential development projects over neighborhood food production. Philadelphia has created a city staff position to coordinate urban agricultural issues, a great step, and this has blossomed into a large partnership of groups and activists who recently released a comprehensive urban agriculture plan addressing everything from composting to land security. A link to Philadelphia’s Urban Agriculture Plan is provided here:

Like many city agriculture programs, it is understaffed, underfinanced, and lacks readily available technical assistance. Philadelphia County is the only one of Pennsylvania’s 67 counties that does not have a conservation district. A multi-partner grant application to NRCS in January seeking to remedy this and develop the foundation for a Philadelphia Conservation District was not funded. Helping provide the long-term technical assistance support for efforts underway in Philadelphia is critically important, and federal financial support grants should be made available to provide this. The recent addition of $1.5M in the FY 22 Omnibus package for urban agriculture represents a good, if modest, step in this direction, but at $8.5M total for the whole country, these funds do not go far enough to ensure the stable long-term sustainable funding needed by many cities. Philadelphia’s wide range of urban agriculture – from the Asian-American-led Fishadelphia program, to the Philadelphia Orchard Project, to Weavers Way Farm Cooperative leased from and integrated into the meals and curricula of the W.B. Saul Agricultural High School within the city limits – illustrates the importance of USDA maintaining a broad and inclusive definition of urban agriculture.  

At the other end of the state, the City of Pittsburgh has also witnessed an explosion of urban gardening and farming activity. Here again, more support is needed to build on the piecemeal approach that nonprofits have stepped in to supply. More funding for specific urban agriculture projects through the county conservation district, the public schools, and nonprofits would go a long way to sustaining many small enterprises, and addressing some of the larger systemic issues – including contaminated soils, land access, infrastructure, and food waste. Pennsylvania’s Department of Agriculture recognized the growing needs of city agriculture efforts in its 2019 Pennsylvania Farm Bill by adding an Urban Agriculture Infrastructure Grants program, but this annual $500,000 program for the entire state is a drop in the bucket of what is needed, and requires both matching funds and a reimbursement basis that create barriers for underserved communities. We strongly recommend a separate allocation of federal urban agriculture funds for underserved communities that doesn’t require cash matches or be based on a reimbursement policy, and that provides information on financial and technical support in languages other than English. Pittsburgh is home to a growing population of Somali Bantu gardeners and farmers, just one example.

Harrisburg has worked for several years to consistently fund a public-facing greenhouse in Reservoir Park as an educational outlet and youth internship opportunity. These funds could support the Environmental Advisory Council and their ongoing work with Public Works to reduce stormwater runoff.

Food waste and wood waste are common issues in urban centers. USDA estimates food waste in the U.S. is running at 30%-40%, often in cities where restaurants and grocery stores are concentrated. Pittsburgh’s nonprofit 412 Food Rescue is a great example of a nonprofit stepping in to combat food waste and provide nutrition to some 3,000 households each year, and like many other small nonprofits, deserves a dedicated federal source of sustainable funding. (See EPA graphic below).

Low-use wood disposal from downed or cut urban trees is also a growing problem, and frankly a wasted resource that could be put to better use, particularly in urban farming and gardening as mulch. Federal funds to help establish low-use wood mulching and recycling centers would also provide farmers and gardeners with accessible and affordable sources of mulch, and would save homeowners and cities the cost of landfilling tree branches, limbs and yard waste, which decompose and add to carbon emissions and climate change. Unlike food production, low-use wood can be stockpiled and broken down on vacant lots, edges of city parks, and other places that don’t require pristine soils.  Excess wood can also be turned into biochar, a low-cost, locally sourced soil amendment, something USDA might consider adding as a fundable activity.      

Specific funding and support needs:

The following specific funding suggestions come from Pasa staff working directly with urban farmers:

  • Systematic grid sampling for heavy metal contaminants;
  • Support for local technical service providers/extension agencies to host and administer XRF testing of soils for remediation;
  • Purchase of scale-appropriate tools for decompacting urban sites;
  • Subsidy support for the removal of debris and rubble generated from site remediation (Bricks, cinder blocks, construction debris, etc.);
  • Study of cost-effective strategies for physically, chemically, AND biologically remediating urban soils;
  • Permitting and zoning support for neighborhood and community composting projects to generate sufficient material for urban ag remediation efforts;
  • Subsidy support for utility connections on urban sites – with so many suboptimal demolitions in the last 30 years, finding, excavating, and connecting to utilities can incur significant cost ($2,000-20,000 per connection), while being connected to utilities. There should be a competitive advantage for urban growers;
  • Support for mapping and site assessment work (like in Pittsburgh) for the identification, preservation, and activation of sites that are prime for urban agriculture
  • Support for purchasing or long-term leasing of sites for urban farming.

We appreciate the opportunity to share our ideas, and are available to answer any questions or provide additional details. Specific questions can be directed to Sara Nicholas, policy specialist, at, or Dan Dalton, Director of Apprenticeship programs, at