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Too Close For Comfort

REPORT - December 2021

What You’ll Learn From This Report

  • 1: Introduction
    • A special project at Food & Water Watch focuses on the people living near natural gas power plants, who tell a different story than the fossil fuel industry does when it comes to harmful effects. 
  • 2: The Fight Against Fracked Gas in New York
    • Mark Sanchez-Potter is a Newburgh, NY resident concerned about the Danskammer Energy Center.
  • 3: A California Community Member Becomes An Advocate
    • Kitty Merrill’s fight against the proposed Puente Plant in Oxnard, CA led her to become an environmental activist.
  • 4: The Ripple Effect of People Power in New Jersey
    • Bill McClelland has become a seasoned veteran in the battle between concerned residents and persistent power plants in New Jersey.
  • 5: Conclusion
    • Our future depends on us creating the political will to ban fracking and stop the buildout of more fossil fuel infrastructure.

Part 1:


A special project at Food & Water Watch focuses on the people living near natural gas power plants, who tell a different story than the fossil fuel industry does when it comes to harmful effects. 

Our dependence on fossil fuels is destroying our climate and eroding the health and safety of everyone who lives in this country. Natural gas, produced primarily from fracking (hydraulic fracturing) — a dangerous form of drilling, is being touted as a “cleaner” fossil fuel by the industry and its supporters.1 But the experiences of those on the frontline show that it is anything but clean or safe.

At a time when we need to be shifting away from fossil fuels, more and more natural gas power plants are being proposed in communities across the United States. These plants prop up the toxic fracking industry and emit significant amounts of methane, carbon dioxide, nitrogen oxides, sulfur dioxides, particulate matter and other pollutants.2 It is a public health and climate nightmare.

You can enter your zip code in this map to see the natural gas power plants — already built or being proposed — near you.

In this special project connecting our research with stories from the frontlines, Food & Water Watch interviewed the people living near these facilities. These stories uncover the plight of pollution plaguing communities, the health issues suffered and the victories from those who have been brave enough to fight against climate-polluting corporations.

The interviews took place in late 2020. In October 2021, New York Governor Kathy Hochul rejected a key permit that effectively blocks the proposed Danskammer Energy project, underscoring the importance of citizen activism.3

Following section divider photo credit: Gilles Uzan

Part 2:

The Fight Against Fracked Gas In New York

Mark Sanchez-Potter is a Newburgh, NY resident concerned about the Danskammer Energy Center.

The Power Plants Ravaging Neighborhoods Across The U.S.
Source Data: U.S Energy Information Administration (EIA); U.S. Census Bureau.23

Nestled in a New York suburb some 60 miles from Manhattan lies the diverse community of Newburgh, which is largely made up of Black and Hispanic people.4 Newburgh is also home to Danskammer Energy Center, a seldom-used natural gas power plant that has been the center of widespread opposition and rising tensions in the community. While New York is one of the only states to ban fracking, a dangerous proposal to turn Danskammer into a full-time fracked gas power plant would endanger the community in Newburgh and others nearby.5 The potential perils from this facility have sparked residents’ fears that the state is moving in the wrong direction when it comes to mitigating climate change.

Among these concerned residents is native New Yorker Mark Sanchez-Potter, who lives four miles from the plant in Newburgh. Mark’s involvement in volunteer work with Food & Water Watch and environmental activism naturally developed as he witnessed his community devastated by corporate pollution and, as he puts it, by “neglect” from every level of government.

For years, a military base polluted Newburgh’s main water supply with firefighting foam, and the area is now considered a Superfund site.6 Analyses found PFAS (per- and polyfluoroalkyl substances that are toxic waste from chemical manufacturing and related products) in the community’s water— highly toxic forever chemicals that have been linked to medical issues like cancer. Outrageously, after these tests were run, state officials failed to warn residents not to drink the water.7 At the time of the interview, Mark said the community was getting its water trucked in from the Catskill Aqueduct.

The proposed expansion at Danskammer would have compounded the health and safety threats already plaguing the community. “These corporations don’t give a shit about Black and Brown folks and Indigenous folks, and that’s why they put these projects in these communities, and you know they wouldn’t put something like this in a white area of Westchester,” Mark lamented. The proposed plant would have run year-round and processed fracked gas from Pennsylvania.8 “It’s a bridge fuel to nowhere,” he says.

From being a former coal plant and now running on natural gas, Danskammer has historically polluted the community. Mark says residents have dealt with high rates of asthma and compounded pollution from vehicles and other modes of transportation. Between 2011 and 2013, the city of Newburgh had more than two times the number of hospitalizations for asthma as the entire state of New York.9 “Old folks, undocumented folks that we’ve talked to … understand ‘I don’t want to breathe that.’ So, it’s not the jargon of environmental science and the environmental movement that they understand, it’s the impact.”

The majority of the Newburgh community is staunchly against the facility’s expansion, but there are communal tensions between the plant’s union and its members that support the plant. The potential of new jobs in the area is enticing to blue-collar union members, but Mark says, “you know who these jobs are going to be for? They’re not going to be for the Black and Brown people in the city of Newburgh. They’re going to be for people outside of Newburgh who don’t have any connections or who don’t care about their company’s polluting.”

“Our energy needs will be met without Danskammer. We don’t need it.”

It’s safe to say the community won’t go down without a fight. Mark has been involved with various advocacy efforts in Newburgh, from bird-dogging elected officials to participating in a die-in (a visually stunning public action where participants represent the deadliness of a public health issue). He emphasized the importance of putting pressure on former New York Governor Andrew Cuomo. “Governor Cuomo says he’s a climate leader, but I feel like he’s wishy-washy with a lot of climate issues.” Mark adds, “He has the executive power to stop the application process and … the plant. He has the ultimate authority.”

“We have to think of renewable energy,” Mark affirmed. “We need to be investing in renewable energy with an emphasis on a just transition for union workers.” New York has legislation in place to get the state to 70 percent renewable energy by 2030 (although 100 percent would be optimal). Former Governor Cuomo himself had been vocal about shifting the state to renewables, while creating clean energy jobs for New Yorkers.10 But to communities like Newburgh, it seems like lip-service. According to Mark, “our energy needs will be met without Danskammer. We don’t need it.” Governor Hochul’s October denial of the Danskammer permit in October 2021 shows what real climate leadership looks like. The next step for her administration is to halt all fossil fuel development.

You helped us stop Danskammer. Let’s beat the next environmental threat in NY, too! We need a ban on cryptocurrency mining powered by fracked gas!

Part 3:

A California Community Member Becomes An Advocate

Kitty Merrill’s fight against the proposed Puente Plant in Oxnard, CA led her to become an environmental activist.

The Power Plants Ravaging Neighborhoods Across The U.S.
Source Data: U.S. Environmental Protection Agency (EPA); California Air Resources Board; California Department of Conservation.24

Kitty Merrill lived peacefully on the south end of Oxnard, California with her family for decades, completely oblivious to the “chemical soup” of pollution all around them. “It had this really charming feel,” Kitty described first moving to Oxnard. “You could drive and smell the strawberry fields, it’s just really cool.” And then, one day, a text message from her adult daughter changed everything.

“Did you know you’re in one of the most polluted areas in the region?” the text message read. Oxnard, California is flanked with contamination from mega agricultural operations, power plants, a wastewater treatment facility and a Superfund site — marking a history of pollution.11 “We get particulate matter from power plants; there was a recycling plant that turned out to be a Superfund site with toxic waste,” says Kitty. The strawberry fields that once enticed Kitty and her family turned out to be heavily sprayed with pesticides. “I realized this really wonderful environment that we sought out to raise our kids was really a toxic one.”

“I felt really betrayed that a community could look so perfect on the outside.”

In an area that is predominantly Hispanic and lower-income, residents are faced with terrible air quality and asthmatic conditions.12 In 2013, Oxnard had some of the worst air quality scores in all of Ventura County,13 and residents have reported feeling symptoms consistent with asthma.14 Kitty said she started hearing about asthma in the community and realized that her daughter first got asthma in elementary school. A lot of her daughter’s friends are also asthmatic. “It’s not just a statistic, it’s something that I was seeing in the real world, on a day-to-day basis.” She admits, “it never clicked with me that there was a connection.”

The pollution in the area often goes unacknowledged by the wider community, becoming an invisible threat. “People don’t really discuss pollution issues,” says Kitty. At the community college where Kitty worked, she was surprised that her students were not more passionate about the environmental issues in the community. “They were more concerned about bread and butter,” she recalls. The students “had parents that were agricultural workers” with “different levels of documentation,” which made it hard for them to focus their energy on the less obvious environmental dangers in the community. “They weren’t at the level where they could afford to start thinking about the health effects and the things … that are less immediate.”

At the same time, the community’s health issues were being exacerbated by the high concentration of existing natural gas plants in the area and threatened by repeated proposals for new ones, including power plants along the local beaches. When the Puente Plant was proposed for Oxnard, a coalition of fed-up locals, including Kitty, started rallying against the highly contentious facility.15 She began speaking out against the plant at community meetings, which was something she “had never done before.” “It was something I really felt strongly about, and I wanted to make sure that I could do what I could for my community.”

Ultimately the Puente proposal was knocked down after widespread opposition, but as California continues to be ravaged by larger and larger wildfires each year, it becomes all the more crucial to move away from fossil fuels in general. In fact, the state’s demand for electricity has declined in the past decade.16 “We’re at a point where so many things are changing in technology, that locking our community into fossil fuels for 20, 40 years … was just ridiculous.”

“I think that time is on our side, and in the same breath I can say time is against us because climate change is clearly here.”

Kitty continues to push for clean energy measures in her community, working alongside organizations like her local chapter, the Ventura Climate Hub, Food & Water Watch and other California organizers. “We’ve been putting our energy into county-level things.” She hopes that small changes on the local level will have a ripple effect at the state level. “I think that time is on our side, and in the same breath I can say time is against us because climate change is clearly here.” Despite it all, Kitty remains hopeful about “the possibility of change in our future.”

You can stand with us. Urge Governor Newsom to stop all new fracking and drilling permits in CA!

Part 4:

The Ripple Effect of People Power in New Jersey

Bill McClelland has become a seasoned veteran in the battle between concerned residents and persistent power plants in New Jersey.

The Power Plants Ravaging Neighborhoods Across The U.S.
Source Data: EPA; EIA.25

Despite the political clout and deep coffers of the fossil fuel industry, the collective action of the people can be even more powerful. Sometimes all it takes is a dedicated and passionate community unwilling to compromise. Bill McClelland has watched this play out in his diverse community in Hudson County, New Jersey where he has lived for the past four decades. “Obviously the goal is to ban and stop all fossil fuel projects,” Bill says.

Having lived in New Jersey for so long, Bill is familiar with the pollution that has plagued the state and his neighborhood in Hudson County. He says that over the decades, industrial development has resulted in “all sorts of environmental problems,” from “illegal dumping” to chromium pollution. Bill’s community is home to a large Superfund site, where for decades an oil processing plant spewed millions of gallons of contaminants into the soil and wetlands — including lead.17 “These industries, because they are in such isolated areas, can get away with anything.”

Historically, Hudson County has had air quality issues, receiving an “F” rating from the American Lung Association for ozone pollution from 2016 to 2018.18 Air pollution has also been linked to environmental justice issues in New Jersey, and one study found that particulate matter, a major natural gas plant pollutant, is associated with higher mortality among Black and lower-income residents.19 Notably, natural gas plants are a major source of particulate matter pollution.20 Yet the industry claims that these plants are “clean” and has been trying to push for new natural gas-fired power plants in New Jersey for years.

When the North Bergen Liberty Generating (NBLG) natural gas power plant was initially proposed in 201821, the community began fighting against its development. According to Bill, the plant would have been located in a pristine wetland called the Meadowlands, close to homes and a school — all of which prompted outcry from residents. Bill participated in a protest that was organized by students called March for Our Lungs, where “hundreds … maybe even a thousand people showed up,” he said. “We marched from the high school down to the site where this power plant was supposed to be.” Community organizing successfully led to the defeat of those plans at the end of 2020.

“You’ve got to be persistent … you can’t be intimidated by these people.”

On the heels of the NBLG win, the community found itself fighting yet another natural gas plant, this one proposed by New Jersey Transit. “Along came the proposal by New Jersey Transit to build another huge fracked gas power plant on the other side of the Meadowlands.” These plans were also quickly shot down after the community stood against the proposal.22 “You’ve got to be persistent and … you can’t be intimidated by these people just because they have power,” Bill emphasizes. “We’ve had two major victories in the last year, and … everyone is just high.”

What makes Bill’s story so inspiring is that he is a passionate resident committed to a better planet. “You know, I’m not a scientist — I’m a musician.” Bill’s interest in environmental advocacy started in the late 1980s when New Jersey first passed a mandatory recycling law. “I called the town, totally out the blue … and said ‘you need any help?’” The rest is history. As only a volunteer, Bill helped start up the state’s recycling program; he’s worked with North Bergen’s assemblymen on environmental issues over the years, and now stands with his community against natural gas power plants.

“A lot of these power plants … go on forever, long past time of usefulness, and they just get dirtier and dirtier and cause more problems.” But Bill remains motivated to continue to fight these natural gas proposals. “Our primary goal is to stop construction of any new power plants that plan to burn fossil fuels.” Riding the high of these wins, Bill and other community organizers and organizations are committed to banding together to fight other proposals around the state. He is now assisting in efforts to stop New Fortress Energy’s proposal for an LNG export terminal known as the Gibbstown Facility.

“I hope others seeing this say ‘wow it can be done,’” Bill says. Although it can be daunting to directly address the powers that be, the communities in New Jersey have proved to be fearless. And while he’s not sure he’ll be around long enough to witness a less-exploitive world, Bill remains hopeful for the future.

Help Bill keep NJ free from new fossil fuel infrastructure. Your voice makes a difference!

Part 5:


Our future depends on us creating the political will to ban fracking and stop the buildout of more fossil fuel infrastructure.

Our current energy system is unsustainable and dangerous to communities and people all across the United States. The continual push for more fracking has only further propped up the toxic oil and gas industry, with little regard for the communities carrying the burden of these consequences. The time for an energy system overhaul is now, and the good news is that people power can work with time and dedication. We need to ban fracking and make the shift to clean, renewable energy — because the health and safety of our communities and our very futures depend on it.

For clean energy to heal our planet, we must also ban fracking.

Add your name to the movement!

  1. U.S. Department of Energy (DOE). Energy Information Administration (EIA). “Natural gas explained: Natural gas and the environment.” Updated September 24, 2020. Available at Accessed March 2021 and on file with Food & Water Watch (FWW).
  2. Fard, Reza Fouladi et al. “The assessment of health impacts and external costs of natural gas-fired power plant of Qom.” Environmental Science and Pollution Research. Vol. 23, No. 20. August 2016 at 20922; Public Service Commission of Wisconsin. “Environmental Impacts of Power Plants.” June 2015 at 5.
  3. McKenna, Chris. “DEC rejects key permit for proposed Danskammer power plant in Newburgh.” Times Herald-Record (NY). October 27, 2021; FWW. [Press release]. “NY Governor Hochul rejects applications for Danskammer and Astoria fracked gas plants.” October 27, 2021.
  4. U.S. Census Bureau (USCB). QuickFacts. Available at Accessed January 2021.
  5. TRC. Prepared for Danskammer Energy, LLC. “Preliminary Scoping Statement, Danskammer Energy Center.” Case No. 18-F-0325. February 2019 at 5-11.
  6. U.S. Environmental Protection Agency (EPA). “What is Superfund.” Available at Accessed May 2021.
  7. McKinley, Jesse. “Military base near Newburgh is made a Superfund site over tainted water.” New York Times. August 12, 2016.
  8. Bellamy, Lana. “Danskammer Energy looks to hydrogen for future power; activists claim company is ‘greenwashing’.” Times Herald-Record (NY). August 31, 2020; FWW. “Twenty cities and towns in New York unite to oppose Danskammer fracked gas plant.” June 22, 2020.
  9. New York State Department of Health (DOH). “City of Newburgh: Health Equity Report.” February 2017 at 16 and 20.
  10. Walton, Robert. “New York expands state clean energy standard, moves to boost renewables use in the Big Apple.” Utility Dive. October 16, 2020; New York State Energy Research and Development Authority (NYSERDA). [Press release]. “Governor Cuomo announces new competitive program to retain New York’s existing renewable energy resources.” January 22, 2021.
  11. Boyd-Barrett, Claudia. “As California’s ports expand, neighboring communities fight back against pollution.” California Health Report. March 18, 2019; Homefacts. “Ventura County, CA Environmental Hazards Report – Superfund Sites.” Available at Accessed January 2021.
  12. Boyd-Barrett(2019); USCB.
  13. “Environmental report shows Oxnard has worst score in the county.” Ventura County Star. April 23, 2013.
  14. Dignity Health St. John’s Hospitals. “Oxnard, California Latino Community Health Needs Assessment.” April 2014 at 11 and 26.
  15. Weikel, Dan. “Oxnard residents are fighting slag heaps, power plants and oil field that mar the town’s beaches.” Los Angeles Times. July 9, 2017.
  16. Penn, Ivan and Ryan Menezes. “Californians are paying billions for power they don’t need.” Los Angeles Times. February 5, 2017.
  17. D’Auria, Peter. “Who will foot $24M bill to clean up one of Hudson County’s most polluted sites?” Jersey Journal. October 8, 2020.
  18. American Lung Association. “State of the Air: 2020.” 2020 at 121.
  19. Wang, Yan et al. “Estimating causal effects of long-term PM2.5 exposure on mortality in New Jersey.” Environmental Health Perspectives. Vol. 124, No. 8. August 2016 at 1182.
  20. Massetti, Emanuele et al. Oak Ridge National Laboratory. Prepared for DOE. “Environmental Quality and the U.S. Power Sector: Air Quality, Water Quality, Land Use and Environmental Justice.”. ORNL/SPR-2016/772. January 4, 2017 at vii and 15.
  21. Heinis, John. “DEP grants first land use approval for $1.8B North Bergen electricity plant.” Hudson County View. July 6, 2018.
  22. Johnson, Tom. “NJ Transit opts for green energy, ending plan for gas-powered plant.” NJ Spotlight News. October 23, 2020.
  23. FWW analysis of Power Plants. US Energy Information Administration (EIA). Accessed March 2021; 2019 American Community Survey 5-Year Estimates. US Census Bureau. Accessed March 2021; 2019 TIGER/Line Shapefiles. US Census. Accessed March 2021.
  24. FWW analysis of TRI Explorer. US Environmental Protection Agency (EPA). Accessed March 2021; Superfund National Priorities List (NPL) Sites with Status Information. EPA. Accessed March 2021; Pollution Mapping Tool. California Air Resources Board. Accessed March 2021; WellSTAR. California Department of Conservation. Geologic Energy Management Division. Accessed March 2021.
  25. FWW analysis of TRI Explorer. US Environmental Protection Agency (EPA). Accessed March 2021; Superfund National Priorities List (NPL) Sites with Status Information. EPA. Accessed March 2021; Power Plants. US Energy Information Administration (EIA). Accessed March 2021; Wetlands of New Jersey. New Jersey Geographic Information Network (NJGIN) Open Data. Accessed March 2021; Proposed NJ TRANSITGRID Project Area. NJ Transit. Accessed March 2021.

Fracking, Power Plants & Exports: Three Steps for Meaningful Climate Action

REPORT - November 2021

Fracking Nightmare: The Gibbstown Explosive Liquefied Gas Export Plan


PDFClimate and Energy

Off Course: Carbon Pricing Myths and Dirty Truths


PDFClimate and Energy

Natural Gas Liquids: A Dangerous Plastic-Producing Byproduct of Fracking


PDFClimate and Energy

Planes de SoCalGas Para Expandir la Estación de Compresión de Ventura


PDFClimate and Energy

SoCalGas Plans to Expand Ventura Compressor Station


PDFClimate and Energy

Natural Gas Liquids: Fracking’s Hazardous Plastics and Pollution Scheme


PDFClimate and Energy

How Much Do Food Labels Tell You?


PDFFood System

Federal Legislation for a Just Food System


PDFFood System


REPORT - April 2021

What You’ll Learn From This Report

  • 1: A Broken Food System
    • Deciding what and how to farm should be left to farmers, not corporations
  • 2: From Extractive To Regenerative Food Systems
    • The farmers at the forefront of this movement
  • 3: Rebuilding Regional Food Hubs
    • Rebuilding regional food hubs connects farmers and eaters, and reduces the monopoly corporate agribusiness has on the food system.
  • 4: Policy Recommendations: A Roadmap To A Just Transition
    • Here are our policy recommendations on how to pivot to this much-needed systemic change.
  • 5: Conclusion
    • We can build regenerative food systems

Part 1:

Our Food System Is Broken

Deciding what and how to farm should be left to farmers, not corporations.

Corporate monopolies control food production.

Today’s supermarkets seem like the pinnacle of choice and variety. But consumers might be surprised to learn that this choice is really a façade, and that a few companies dominate the market in each food category. Your steak? Just four companies slaughter 83 percent of all U.S. cattle (see Figure 1).1 Your flour? It likely comes from Ardent Mills or ADM Milling, which together mill half of all U.S. wheat.2 And then there are companies that profit from value-added processing of raw ingredients. The jars of Gerber, boxes of Cheerios and Lean Cuisine, and tins of Fancy Feast in your shopping cart are all Nestlé-owned brands.3 Agribusinesses make consumers feel like they have ample choices, while forcing them to buy much of their food from just a handful of corporations.

Livestock Farmers Sell into Highly Concentrated Markets

Market share of top four processing firms

Source Data: USDA AMS 20184

Even supermarkets themselves have gobbled up competitors and secured huge market shares. Four companies — Walmart, Kroger, Costco and Ahold Delhaizea — control 65 percent of the grocery market.5 This stranglehold raises food prices and wipes out local grocery stores, reducing food access in both rural and urban communities (see Figure 2).6

Supersizing the Supermarket: National Market Share

Source Data: CBRE 20197

Less competition among agribusinesses means higher prices and fewer choices for consumers. But for farmers and the rural communities they support, it is a fight to survive.

Corporate agribusinesses gut rural America.

Market consolidation has wiped out competition, giving farmers fewer choices when they buy seed and feed and when they bring products to market (see Figure 3 on page 3). As a result, they face both rising costs and stagnating income.8 In fact, today’s median farm income is negative $1,840; many farms manage to stay afloat through off-farm income.9

Ironically, while farmers have little power in our industrial food system, they often receive much of the blame for that broken system. Misguided policymakers and others deride farmers for overproduction, for receiving subsidies, or for participating in contract farming when all of these are symptoms of the underlying dysfunction in the food system.

Market Share Of Top Four Seed Firms

All Source Data: ETC Group 201810

Market Share Of Top Four Agrochemical Firms

All Source Data: ETC Group 201810

Corporate consolidation also hurts rural communities. Local slaughterhouses and flour mills have shuttered as processing facilities became fewer and larger. Revenue that once circulated in rural communities and built thriving main streets is now funneled to Wall Street and far-away corporate headquarters.11

Corporate agriculture perpetuates exploitation and racism.

Our farming system rests on stolen land, stolen labor and stolen resources, including forced removal of Indigenous peoples, the enslavement of African Americans and the sharecropping model. These systems persist today in vertically-integrated livestock systems that lock farmers into abusive contracts and high debt, the patenting of Indigenous seed varieties, the freezing-out of farmers of color from federal loans and subsidies, and the exploitation of low-wage labor in dangerous conditions in our nation’s produce fields and slaughterhouses.12

Industrial agriculture is extractive.

The industrial farming system focuses on squeezing out as much profit as possible, with little regard for long-term environmental ecological or public health impacts. Planting monocultures year-after-year can impair soil health.13 So does spraying synthetic pesticides. Intensive practices also harm bees and other pollinators and microorganisms that make up healthy ecosystems.14

Factory Hog Farm Counties Produce as Much Waste as Metropolitan Areas

Source Data: Food & Water Watch analysis of USDA 2017 Census of Agriculture15
Industrial agriculture pollutes the environment and fuels climate change.

Factory farms confine thousands of animals in inhumane, unsanitary conditions. They produce more manure waste than can be sustainably disposed and increase the risk of diseases jumping from livestock to humans (See Figure 4).16 In many parts of the country, factory farms are concentrated around communities of color and low- income communities, making them environmental justice catastrophes.17

Rural communities bear the brunt of pollution from industrial farming, from pesticide exposure to toxic emissions from factory farms.18 Yet these impacts reach far beyond the farm; nutrient runoff from manure and pesticide application pollutes waterways, contributing to fish kills and aquatic “dead zones” from the Great Lakes to the Gulf of Mexico.19 Pesticide residue is found on all food types of food, from organic produce that was never sprayed with pesticides to human breast milk.20

Agriculture is also one of the largest human sources of climate change; across the entire production chain, it contributes 19 to 29 percent of all human-sourced emissions. Overproduction of commodities and meat, food waste, growing crops for fuel, and use of synthetic fertilizers produced from fossil fuels all enlarge this footprint.21

Our food production chain is not resilient.

Decades of unchecked corporate consolidation has worn away our food system’s resilience.22 For instance, large, centralized processing facilities replaced the regional slaughterhouses and dairy processors that once dotted the rural landscape, leaving farmers with fewer options for marketing their products.23 When some of these large facilities closed during the COVID-19 pandemic, many farmers were left with no choice but to euthanize livestock or dump milk — gut-wrenching scenarios that would not have been as widespread if we still had networks of smaller facilities serving local markets.24

Our food system does a poor job of feeding people.

Even after accounting for commodities grown to feed livestock and produce energy, the U.S. still has roughly 4,000 calories of nutrients available per day per capita.25 Yet nearly one in seven children live in food-insecure households.26

Much of what goes into deciding what and how to farm is shaped by agribusiness, not farmers. Corporations set farm markets and policy.27 We need to join farmers and food chain workers to break Big Ag’s stranglehold and rebuild our food systems so they work for everyone. It can be difficult to imagine what alternatives to the industrial system might look like. We can start by learning from those at forefront of this movement, who are building healthy farmland and rural communities through regenerative agriculture.

Part 2:

From Extractive to Regenerative Food Systems

The farmers at the forefront of this movement

Regenerative agriculture is generating a lot of buzz today, with everyone from food activists to big agribusinesses floating the term. But with no unifying definition, the term “regenerative” can take on different meanings.28 So let’s start by defining what we mean by “regenerative food systems.”

Regenerative food systems are those that invest in the long-term health and fertility of farmland; build soil and prioritize soil health; and rely on natural rather than synthetic inputs. They embody these principles along each step of the food supply chain — investing in local economies; providing farmers and food chain workers with living wages and safe working conditions; and addressing racial and economic injustice. The regenerative movement shares roots with organic farming, a reaction against the environmental degradation caused by industrial farming. Today, the U.S. Department of Agriculture (USDA) oversees the National Organic Program, creating standards for the organic label and certifying compliance. Regenerative farming, on the other hand, has no federal standards or label any farmer or food company can market their products as regenerative.

Some regenerative advocates market it as a new concept that goes beyond the limits of organic agriculture.29 This is a disservice to the organic community and its decades of work in strengthening the integrity of the organic label and increasing federal funding for organic research and adoption. It also erases centuries of contributions from indigenous and other farmers of color who farmed regeneratively long before the term emerged.30

In this piece, we use the term “regenerative” as an umbrella term for sustainable farming systems. Some of the farms featured are certified organic whereas others have not sought certification. What unites them is a holistic method of farming that seeks to regenerate, rather than extract, natural resources.

Part 3:

Regional Food Hubs

Rebuilding regional food hubs connects farmers and eaters, and reduces the monopoly corporate agribusiness has on the food system.

Farms need access to open, competitive markets to thrive. However, agribusiness consolidation has all but wiped out the nation’s smaller-scale slaughterhouses, grain mills and mom-and-pop grocery stores,81 making it increasingly difficult to imagine a food system that is not dependent on highly consolidated supply chains. The truth is, agri- businesses built the industrial food system over a few decades; we can similarly rebuild this broken system to ensure justice for all farmers, food chain workers and consumers.

Building just, regenerative food systems will not happen overnight. It requires significant public investment and political will. Direct sales and farmers markets are important but insufficient; we must also connect local farms to the grocery stores and restaurants where consumers spend the majority of their food dollars.82 Regional food
hubs can play a vital role, aiding smaller farms with distribution and marketing of their products so they can reach new markets that would otherwise be difficult to enter on their own.83

Common Grain Alliance

How Food Hubs Work

The idea for Common Grain Alliance98 emerged in the winter of 2018, as a group of friends were baking bread together and discussing how difficult it is to find local grain. “If you go to the Shenandoah Valley, you see all this grain infrastructure, silos, row crops,” says founder Heather Coiner.

“The landscape suggests that grains should be growing here, so how come we can’t find any?”


Photo: Common Grain Alliance members. Photo credit: Beth Ferguson
Common Grain Alliance

Heather, who owns Little Hat Creek Farm and bakery, started by looking for growers who produced and processed grain in the mid-Atlantic. “We feel strongly that grain is a missing part of the local food table and we want to change that in this area,” she says. In just a couple of years, Common Grain Alliance grew to include over 60 members, connecting wheat growers and millers to local restaurants, brewers and distillers.

Common Grain Alliance’s mission is to revitalize the mid-Atlantic’s grain economy. “We’re trying to tap into the historical infrastructure and skills that got pushed aside by industrial agriculture in the last half of the 20th century,” says Heather. For example, some millers have restored existing stone mills while incorporating modern equipment to take advantage of recent advances in grain milling.

Photo: Murphy & Rude Malting Co. in Charlottesville, Virginia, which is part of the Common Grain Alliance. Photo Credit: Glenn Stone
Common Grain Alliance

Common Grain Alliance has received some federal funding to grow its network, including a grant through a USDA program called SARE (Sustainable Agriculture Research and Education). But while some Farm Bill programs directly target small-scale growers, Heather says that non-commodity crops are still largely off the radar of most academics and policy experts. “Even with this support, the vibe I get is, this is a fun idea but you are not going to feed millions of people.” Heather hopes that as the Common Grain Alliance grows, so will the political will of its growers and buyers who want grain that is transparently sourced, traceable and grown without chemicals.

Photo: Murphy & Rude Malting Co. in Charlottesville, Virginia, which is part of the Common Grain Alliance. Photo Credit: Glenn Stone
Common Grain Alliance

In fact, the pandemic showed the importance of local food chains like those created by Common Grain Alliance. “One thing the pandemic laid bare is the flaws in the global food supply chain. Americans saw empty grocery store shelves — that’s not something most people have seen in their lifetimes. And your local farmers are like, we have grain, we have vegetables… Our supply chain isn’t interrupted because it’s shorter.” Heather is optimistic that for some people, the trends that led people to seek out local food and support nearby farms might endure past the pandemic. “It is worth going out of your way to invest in your local food producers, because when crisis hits, they’re the ones that are still going to have food.”

Photo: Murphy & Rude Malting Co. in Charlottesville, Virginia, which is part of the Common Grain Alliance. Photo Credit: Glenn Stone

Small farms often lack the volume and consistency of products to sell directly to a retailer or foodservice institution. Larger institutions prefer to purchase from a single entity rather than several small farms. A food hub can help bridge this divide by connecting several smaller farms with regional buyers. Some food hubs even invest in infrastructure farmers need to bring products to market, like warehouses where food is stored, packed and labeled. What distinguishes food hubs from other local distributors is that they are formed with the goal of improving the economic, social and environmental health of their communities. As such, they are committed to providing farmers with fair prices and longstanding relationships rather than undercutting them in search of the cheapest alternative.84

There are many current efforts to revitalize local food systems through the food hub model. Public investment and incentives can help create similar food hubs across the country that are unique to each region’s geography and food culture.

Part 4:

A Roadmap For a Just Transition

Here are our policy recommendations on how to pivot to this much-needed systemic change.

Regenerative and organic farming are economically viable and already working to feed people, invest in local communities and create jobs. But federal farm policy is not designed to serve “alternative” or smaller-scale farming systems. Powerful agribusinesses have spent billions of dollars influencing lawmakers and regulators to serve their economic interests.126 But we can fight back against corporate control and reshape farm policy to achieve social and economic justice.

Enact Federal Legislation

Stop the growth of factory farms.

A handful of state legislatures have introduced factory farm moratoriums in recent years; the moment is growing. But to enact systemic change, we need a national moratorium on all new and expanding factory farms.

Models for federal legislation include the Farm System Reform Act (FSRA),127 introduced by Senator Cory Booker and Representative Ro Khanna. The FSRA would immediately ban all new large factory farms and the expansion of existing ones, and would phase out existing large factory farms by 2040.

Moreover, the FSRA would invest in a “just transition” by creating a $10 billion buy-out program for factory farm operators to pay off debt (an obstacle for farmers wishing to exit contract growing) or transition to more sustainable systems, such as pasture-based livestock or specialty crops. Notably, this funding would only be available to farmers for projects on land they own which ensures that corporate giants that created the problem do not pocket the funds.

Send a note to your Congressperson asking them to support the Farm System Reform Act today!

Stop further consolidation in the food industry.

The COVID-19 pandemic makes hitting the pause button on mega-mergers all the more critical, to ensure that agribusinesses do not use the pandemic recovery to buy out struggling competitors and further entrench market power.

Federal lawmakers are targeting agribusiness consolidation. This includes Senator Cory Booker and Representative Marc Pocan’s Food and Agribusiness Merger Moratorium and Antitrust Review Act.128 The legislation would enact a moratorium on all agribusiness and grocery mega-mergers and create a commission to recommend steps to strengthen antitrust and merger rules and enforcement. The moratorium would be in place until Congress passes comprehensive legislation to address market consolidation in the agribusiness sector.

End discrimination within USDA programs and support farmers of color.

Black farmers faced disproportionately higher rates of farmland loss throughout the 20th and early 21st centuries. This was accelerated by systemic racism within federal agencies like USDA.129

Legislation like the Justice for Black Farmers Act,130 introduced by Senators Cory Booker, Elizabeth Warren and Kirsten Gillibrand, seeks to end discrimination by establishing an independent civil rights board to review reports of and appeals to civil rights complaints filed against USDA. It would also create a number of initiatives to address Black farmer land loss, including creating a land trust to provide the next generation of Black farmers with land and resources to farm.

Overhaul the Federal Farm Safety Net

The current farm safety net is just a Band-Aid on a broken system. Crop insurance provides some economic relief to farmers, but does not address overproduction, a key contributor to price slumps. And farmers are not incentivized to implement sustainable practices that make land more resilient to future disasters in a changing climate.

Reinstate federal supply management for commodities.

The first Farm Bill enacted a federal supply management program, saving countless farmers from bankruptcy during the Dust Bowl.131 The program took marginal farmland out of production and provided farmers with living wages — until it was systematically dismantled by Big Ag.132

USDA used to set a price floor for grains that achieved parity, an income that both covers the cost of production while providing farmers with a living wage. USDA provided farmers loans based on this price floor, which farmers repaid after harvest. In years when market prices dropped below the price floor, USDA collected the harvest as collateral, essentially buying surplus grains from the market for the federal grain reserve. Then when drought or other disasters reduced crop yield, USDA sold grains from the federal reserve into the market,133 smoothing out market volatility and ensuring a steady supply of grain to the benefit of both farmers and consumers.

Remarkably, supply management can operate at virtually no budgetary cost to taxpayers.134 We can reinstate supply management for grain crops and extend it to dairy, if our elected officials stand up to the corporate agribusinesses greedy for artificially-cheap commodities.

Require farmers to implement organic practices in order to participate in safety net programs.

This would provide a huge incentive for farmers to shift from ecologically-depleting monocultures to ones that incorporate cover crops, crop rotation and no-till farming. Safety net programs should also promote crop and livestock systems that are appropriate and sustainable for each region. In turn, organic practices would build soil and help make farmland more resilient to future climate change events, reducing reliance on disaster insurance.

Expand coverage for more crops that directly feed people.

Feed corn, soybeans and cotton make up a huge chunk of acreage enrolled in federal crop insurance programs,135
while many fruits, vegetables and nuts are not eligible under many programs.136 Expanding safety net coverage to more specialty crops supports farmers in shifting to new production systems and diversifying their operations.

These crucial changes will encourage organic practices and stop propping up factory farms with taxpayer-subsidized feed. However, we must also correct past failures of safety net programs to include historically underserved farmers, including farmers of color, female and beginning farmers.137

Redirect Public Funding To Support Organic And Regenerative Agriculture

Big Ag has perfected the art of funneling public dollars into maintaining industrial agriculture’s status quo.
Money earmarked for conservation programs flows to factory farms, and agribusinesses court public universities to develop patented seeds.138 It is time to end public research for private gain and instead invest in building a food system that works for every farmer, food chain worker and consumer.

Increase funding for regenerative practices.

USDA spends billions of dollars each year on agricultural research, yet only a small slice of this goes into regenerative systems.139 Federally funded research should prioritize practices that reduce chemical inputs, build soil and help farmers adapt to a changing climate. Similarly, state legislatures should follow the example of states like Maryland and California and earmark funding for regenerative practices.140

Farmers must also have access to information on regenerative practices. State extension services have long played vital roles in sharing new practices with farmers. They can be important facilitators in connecting farmers with the growing body of research on climate-friendly practices.141 We should also provide financial and technical support to help farmers — especially those historically under-served — transition to USDA Organic certified operations.

Develop climate-resilient seeds and livestock breeds and make them publicly-available.

Land-grant universities have long been incubators of new farming practices and seed varieties that were once shared widely with farmers, with each public dollar invested paying out $10 in benefits.142 But when public funding lagged, federal policies increasingly encouraged private corporations to partner with universities. Today, agribusinesses develop new seeds at public universities which they then patent. This raises seed costs and prevents farmers from seed-saving.143 Corporations are more interested in developing seeds that lock farmers into costly, poisonous pesticides than those that adapt to climate change.

Federal dollars should instead fund research into non-GMO, patent-free seeds and livestock breeds through traditional breeding methods. We must increase funding for land-grant universities and discourage so-called public-private partnerships. Seeds should be developed to respond to specific geographical conditions and to be climate-resilient. State extension services can help distribute innovative seeds and breeds to farmers and encourage farmers to save seed in order to break free from buying expensive patented seeds year after year.

Reject false solutions and close “conservation” loopholes that fund factory farms.

Money from conservation programs flows to false solutions, such as anaerobic digesters, which generate factory farm gas from manure and other waste.144 Factory farm gas is a dirty, polluting energy. 145 Digesters built with taxpayer money simply prop up factory farms and entrench fossil fuel infrastructure. Instead, we should encourage farmers to shift to smaller, integrated crop-and-livestock systems where they can sustainably recycle manure as crop fertilizer.

Another false solution peddled by corporate interests are carbon pricing schemes for farmers. Carbon pricing — or “pay-to-pollute” schemes — allow polluting industries to avoid emissions reduction by purchasing “offsets” from another source, such as a farmer who sequesters carbon in her soil. But pollution trading doesn’t meaningfully reduce carbon emissions and instead allows companies to pay to pollute.146 The practice is unfair to farmers who have already been practicing climate-friendly agriculture and are unable to claim new offsets. Instead, we must leverage existing conservation programs to implement sustainable practices and tie their adoption to safety net participation, while investing in a rapid transition to a 100 percent clean energy economy.

Part 5:


We Can Build Regenerative Food Systems

This is a window into what regenerative farming systems and food hubs in the United States can look like. It is meant to start a conversation, not offer a prescription, as there is no “one-size-fits-all” model for regenerative farming. We can build new farming and food systems that work for everyone if we embrace a few core principles:

Communities of color are leaders — not afterthoughts — in rebuilding food systems.

Our great-grandparents modeled many of the farming systems and practices we strive for today, with diverse farms serving local markets. But we must not romanticize the past; our farm systems have largely benefitted white male farmers with the most capital. We need to ensure that everyone has a seat at the table, and work alongside communities of color that have been in this fight for generations. There is no food justice without racial justice.

Everyone must be able to afford to participate.

Food hubs that provide farmers and food chain workers with living wages should be accessible to everyone. In the short term, we must increase Supplemental Nutrition Assistance Program (SNAP) benefits and extend benefits to farmers markets, co-ops and online purchasing. We must also reform labor laws to raise the minimum wage, eliminate wage theft and provide universal paid sick and family leave, so that everyone can afford healthy food.

Reform will bring choice, variety and availability.

Reforming the way we produce animal products will impact cost and availability. We can embrace a “less-is-better” approach, choosing high-quality meat, dairy and eggs produced sustainably while increasing our consumption of whole produce and grains.

Food policies must promote food sovereignty at home and abroad.

This means empowering communities to feed themselves with fresh, local, healthy food. We must also reorient our trade policies so they do not undermine the ability of farmers and rural communities in the developing world to feed themselves.147

Perhaps the disruption caused by the COVID-19 pandemic will be this generation’s “Dust Bowl” that forces a systemic overhaul. Let’s seize the moment and pressure our leaders to enact policies and make investments in food systems that work for all farmers, food chain workers and consumers.

Send a note to your Congressperson asking them to support the Farm System Reform Act today!

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  89. Reynolds, Bruce J. USDA. Rural Business-Cooperative Service. “A History of African-American Farmer Coopera- tives, 1938-2000.” Presented at the NCR-194 Research on Cooperatives Annual Meeting. Las Vegas, Nevada. October 30-31, 2001 at 1 and 8 to 18; Taylor, Dorceta E. “Black farm- ers in the USA and Michigan: Longevity, empowerment, and food sovereignty.” Journal of African American Stud- ies. Vol. 22, No. 2. March 2018 at 51 to 55.
  90. Moore, Kelly and Marilyn E. Swisher. “The food movement: Growing white privilege, diversity, or empowerment?” Journal of Agriculture, Food Systems, and Community Development. Vol. 5, Iss. 4. Summer 2015 at 116; Kolavalli, Chhaya. “Confronting whiteness in Kansas City’s local food movement: Diversity work and discourse on privilege and power.” Grastronomica: The Journal for Food Studies. Vol. 20, No. 1. Spring 2020 at 60 to 61.
  91. U.S. Federation of Worker Cooperatives (2015) at 1.
  92. Based on information taken from the Hmong American Farmers Association (HAFA) website, and reviewed by HAFA staff on August 18, 2020.
  93. Holpuch, Amanda. “‘I almost got killed’: The Hmong refu- gees who call the US home.” Guardian. June 28, 2019.
  94. Adler, Erin. “Farm prospers by providing land, larger markets for Hmong farmers.” Star Tribune. August 16, 2016.
  95. Hmong American Farmers Association (HAFA). “Our story.” Available at Accessed August 2020 and on file with Food & Water Watch.
  96. Williamson, Shawn. “How much $ does it take to become a farmer? Successful Farming. June 27, 2017.
  97. HAFA. Our story. Accessed August 2020. Available at
  98. FWW staff interview with Coiner, Heather. Common Grain Alliance. June 17, 2020.
  99. Jackson, Charlie and Allison Perrett. Appalachian Sustainable Agriculture Project (ASAP). “The End of Tobacco and the Rise of Local Food in Western North Carolina.” March 2018 at 1 to 2.
  100. Jackson & Perrett (2018) at 2; Appalachian Sustainable Agriculture Project (ASAP). “Appalachian Grown™ 2019 Producer Survey Report.” June 2020 at 3.
  101. Brod, Andrew. University of North Carolina—Greensboro. “The Economic Impact of RAFI-USA’s Tobacco Communities Reinvestment Fund since 2008.” May 2011 at executive summary and 1.
  102. ASAP. “The legacy of tobacco in WNC.” February 10, 2020. Available at legacy-of-tobacco-farming-in-wnc/. Accessed August 2020 and on file with Food & Water Watch.
  103. Jackson & Perrett (2018) at 3.
  104. Ibid. at 2 to 3.
  105. Brod (2011) at executive summary.
  106. Jackson & Perrett (2018) at 24.
  107. Basinger Tuschak, Grace. University of North Carolina– Chapel Hill. “Food Hubs as Community Economic Development: Lessons from TRACTOR Food & Farms.” April 2018 at 6 to 7.
  108. Blue Ridge Women in Agriculture. “About.” Available at Accessed August 2020 and on file with Food & Water Watch; Ham, Nathan. “High Country Food Hub sees major increases in customers sales and in food supply from local farmers.” High Country Press (NC). May 13, 2020.
  109. Viertel, Josh. “Why big ag won’t feed the world.” Atlantic. January 20, 2010; Center for Consumer Freedom. “Organic agriculture cannot feed the world.” September 18, 2013; Center for Consumer Freedom. “About us.” Available at al-agriculture-still-feeds-the-world/. Accessed July 2020 and on file with Food & Water Watch.
  110. Schrama, M. et al. (2018) at 123, 124 and 129; Ponisio, Lau- ren C. et al. (2015) at 1, 2 and 5; USDA. Natural Resources Conservation Service (NRCS). “Cover Crops to Improve Soil in Prevented Planting Fields.” June 2013 at 1; Aktar, Md. Wasim. et al. “Impact of pesticides use in agriculture: Their benefits and hazards.” Interdisciplinary Toxicology. Vol. 2, Iss 1. 2009 at 1.
  111. Arneth, Almut et al. Intergovernmental Panel on Climate Change (IPCC). [Summary for policymakers]. “Climate Change and Land: An IPCC Special Report on Climate Change, Desertification, Land Degradation, Sustainable Land Management, Food Security, and Greenhouse Gas Fluxes in Terrestrial Ecosystems.” August 7, 2019 at 20 to 26 and 40 to 41.
  112. Martin, Allyson. “Seed savers v. Monsanto: Farmers need a victory for wilting diversity.” DePaul Journal of Art, Technology & Intellectual Property Law. Vol. 24, Iss. 1. Fall 2013 at 96; Andrews (2012) at 2 to 5.
  113. Gonzalez, Carmen. “An environmental justice critique of comparative advantage: Indigenous peoples, trade policy, and the Mexican neoliberal economic reforms.” University of Pennsylvania Journal of International Law. Vol. 32. 2011 at 755 to 758.
  114. Holt-Giménez, Eric et al. “We already grow enough food for 10 billion people…and still can’t end hunger.” Journal of Sustainable Agriculture. Vol. 36, No. 6. July 2012 at 595; FAO. “FAO’s Work on Agroecology: A Pathway to Achieving the SDGs.” 2018 at 6.
  115. FAO (2018) at 6 and 20.
  116. Hendrickson (2014) at 20.
  117. McGreal, Chris. “How America’s food giants swallowed the family farms.” Guardian. March 9, 2019; U.S. Meat Export Federation. “U.S. pork exports soared to new value, volume records in 2019.” National Hog Farmer. February 6, 2020.
  118. Clark (ND) at 7 and 29.
  119. Şentürklü et al. (2016) at abstract.
  120. Popay, Ian and Roger Field. “Grazing animals as weed control agents.” Weed Technology. Vol. 10, No. 1. Jan.—Mar. 1996 at abstract and 219.
  121. Stanley et al. (2018) at 257; de Vries et al (2015) at 286 to 287; Hillenbrand, Mimi et al. “Impacts of holistic planned grazing with bison compared to continuous grazing with cattle in South Dakota shortgrass prairie.” Agriculture, Eco- systems and Environment. Vol. 279. July 2019 at 156 to 157.
  122. University of New Hampshire Sustainability Institute. “Field to fork farm: Resilience through diversification.” ND at 1 to 2.
  123. Egan, Franklin and Brooks Miller. “Scaling up pastured live- stock production: Benchmarks for getting the most out of feed & land.” Pasa Sustainable Agriculture. June 2020 at 6 to 7; Stampa, Ekaterina et al. “Consumer perceptions, pref- erences, and behavior regarding pasture-raised livestock products: A review.” Food Quality and Preference. Vol. 82. 2020 at abstract; Stanley et al. (2018) at 255.
  124. Neff, Roni A. et al. “Reducing meat consumption in the USA: A nationally representative survey of attitudes and behaviours.” Public Health Nutrition. Vol. 21, No. 10. March 2018 at abstract.
  125. Ranganathan, Janet et al. WRI. “Shifting Diets for a Sustain- able Food Future.” Installment 11 of “Creating a Sustainable Food Future.” April 2016 at 36 to 37.
  126. Ayazi & Elsheikh (2015) at 15; Mooney (2017) at 71 and 74 to 75.
  127. S. 3221. 116th Cong. (2019).
  128. S. 1596. 116th Cong. (2019).
  129. Gilbert, Jess et al. Land Tenure Center. “The Decline (and Revival?) of Black Farmers and Rural Landowners: A Review of the Research Literature.” Working Paper No. 44. May 2001 at 8 to 9; Reynolds, Bruce J. USDA. “Black Farmers in America, 1865-2000: The Pursuit of Independent Farming and the Role of Cooperatives.” RBS Research Report 194. October 2002 at 24.
  130. S. 4929. 116th Cong. (2019).
  131. Graddy-Lovelace, Garrett and Adam Diamond. “From supply management to agricultural subsidies – and back again? The U.S. Farm Bill & agrarian (in)viability.” Journal of Rural Studies. Vol. 50. February 2017 at 76.
  132. Graddy-Lovelace & Diamond (2017) at 76; Ayazi & Elsheikh (2015) at 23 to 24.
  133. Graddy-Lovelace & Diamond (2017) at 76.
  134. Ibid. at 76; McMinimy, Mark A. Congressional Research Ser- vice (CRS). “U.S. Sugar Program Fundamentals.” R43998. April 6, 2016 at summary.
  135. Shields, Dennis A. Congressional Research Service (CRS). “Federal Crop Insurance: Background.” R40532. August 13, 2015 at summary; Schnepf, Randy. Congressional Research Service (CRS). [Fact sheet.] “2018 Farm Bill primer: Marketing Assistance Loan program.” IF11162. April 3, 2019 at 2.
  136. Rosa, Isabel and Renée Johnson. Congressional Research Service (CRS). “Federal Crop Insurance: Specialty Crops.” R45459. Updated January 14, 2019 at 9; Smith, Trevor J. “Corn, cows, and climate change: How federal agricultural subsidies enable factory farming and exacerbate U.S. greenhouse gas emissions.” Washington Journal of Environmental Law & Policy. Vol. 9, Iss. 1. March 2019 at 43 to 44.
  137. Graddy-Lovelace & Diamond (2017) at 78.
  138. FWW analysis of EQIP payments, using data received from the Environmental Working Group; FWW. “Public Research, Private Gain: Corporate Influence over University Agricul- tural Research.” April 2012 at 1.
  139. Lehner, Peter and Nathan A. Rosenberg. “Legal pathways to carbon-neutral agriculture.” Environmental Law Reporter. Vol. 47. 2017 at 14; DeLonge, Marcia S., Albie Miles and Liz Carlisle. “Investing in the transition to sustainable agriculture.” Environmental Science & Policy. Vol. 55, Part 1. January 2016 at 267.
  140. Lehner & Rosenberg (2017) at 16.
  141. Ibid at 17.
  142. Fuglie, Keith O. and Paul W. Heisey. USDA ERS. “Economic returns to public agricultural research.” Economic Brief No.10. September 2007 at 3.
  143. FWW (2012) at 1 and 12.
  144. FWW analysis of EQIP payments, using data received from the Environmental Working Group; Environmental and Energy Study Institute (EESI). “Biogas: Converting Waste to Energy.” October 2017 at 1; U.S. EPA. “How does AD work?” Accessed July 2020. Available at anaerobic-digestion/basic-information-about-anaerobic- digestion-ad.
  145. Kuo, Jeff. California State University, Fullerton. “Air Quality Issues Related to Using Biogas from Anaerobic Digestion of Food Waste.” Prepared for California Energy Commission. CEC-500-2015-037. March 2015 at 2, 9 and 10.
  146. FWW. “The truth about offsets.” May 2013 at 1; Ritter, Tara and Jordan Treakle. Institute for Agriculture and Trade Policy (IATP) and National Family Farm Coalition (NFFC). January 2020 at 1 to 2.
  147. Gonzalez (2011) at 755 to 759; Frison, Emile A. Interna- tional Panel of Experts on Sustainable Food Systems (iPES FOOD). “From Uniformity to Diversity: A Paradigm Shift from Industrial Agriculture to Diversified Agroecological Systems.” June 2016 at 24 to 26.

Well-Fed: Companion Fact Sheet


PDFFood System

Fair Farming: A New Deal Approach to Food Supply Management


PDFFood System

The Relationship Between Water Shutoffs and COVID-19

REPORT - March 2021

What You’ll Learn From This Report

  • 1: Report findings
    • A nationwide water shutoff moratorium might have saved more than 9,000 lives and prevented nearly half a million people from being infected with COVID-19 through the end of 2020.
  • 2: A national water affordability crisis
    • The pandemic has exposed and exacerbated the pre-existing water affordability crisis in the United States.
  • 3: Water shutoff moratoria during the pandemic
    • A wave of protections and a wave of endangerment provide an opportunity to study outcomes of each approach.
  • 4: Our study
    • A small change in infection growth rate yields a significant impact.
  • 5: Conclusions and recommendations
    • 5 specific steps could save countless lives and slow the spread of contagion during public health emergencies.

Part 1:

Report Findings

A nationwide water shutoff moratorium might have saved more than 9,000 lives and prevented nearly half a million people from being infected with COVID-19 through the end of 2020.

This study finds that in states with moratoria, the growth rates for COVID-19 infections and deaths were significantly lower. Had these shutoff protections been in place nationally, it might have reduced total COVID cases by 4.0 percent and COVID deaths by 5.5 percent in the 41 states without a full coverage of a moratorium over the period from April 17, 2020 to December 31, 2020. Existing water shutoff protections have protected human health and helped slow the spread of novel coronavirus.

Since March 2020, when the outbreak of the COVID-19 was declared a national emergency, hundreds of localities and states took strong action to suspend water shutoffs to ensure households had water for handwashing and sanitation. Unfortunately, this patchwork of protections was never uniformly applied nationwide and left millions of people vulnerable to service disruptions due to an inability to pay water bills during the pandemic.

With emerging variants of the virus that causes COVID- 19, it is critical to ensure access to water services to continue to help slow the spread of the virus and prevent worsening infection rates. Food & Water Watch urges President Joe Biden to halt water shutoffs nationally for the remainder of the COVID-19 national emergency, and his administration should champion legislative solutions to cancel the water debt accrued during the pandemic and fully fund our public water infrastructure to provide long-term relief into the future.

Key Findings

From April 17, 2020 to December 31, 2020, states with moratoria on water shutoffs significantly reduced their growth rates of COVID infections and deaths, compared to states without moratoria, with the biggest reduction seen in states with comprehensive water shutoff moratoria covering all water systems in the state. A moratorium on water shutoffs was associated with a reduced daily infection growth rate by 0.235 percent, and daily death growth rate by 0.135 percent. These small reductions in the daily growth rates were significant and had a sizeable impact on the cumulative case and death numbers. Comprehensive water shutoff moratoria that apply to all water systems in a given state are associated with even lower infection and death growth rates. A nationwide water shutoff moratorium might have reduced COVID cases by 3.97 percent and COVID-related deaths by 5.51 percent in the 41 states without full coverage of a moratorium over this period. Extrapolating from model results, we estimated a nationwide water shutoff moratorium during the study period might have protected 480,715 people from COVID-19 infection and 9,052 people from death.

Report by Xue Zhang and Mildred E. Warner from Cornell University in collaboration with Food & Water Watch

Part 2:

A National Water Affordabilty Crisis

The pandemic has exposed and exacerbated the pre-existing water affordability crisis in the United States.

Since March 2020, one of the Centers for Disease Control and Prevention’s top recommendations to help stop the spread of the novel coronavirus has been thorough and frequent handwashing,1 but tens of thousands of people have been unable to follow this simple but crucial advice because their water service was shut off over water debt.2

For years, unaffordable water bills have been a growing problem in communities across the country.3 A 2017 study found that water bills were already unaffordable for 12 percent of households, and if water charges increased at projected rates, nearly 36 percent of U.S. households would be unable to afford their water bills within five years.4 This crisis disproportionately affects low-income households and communities of color.5 A study of Michigan found that communities of color pay higher average household water bills than communities with lower percentages of racial minorities.6

Austerity underlies this crisis. The federal government has cut back support for water systems, shifting the burden onto local ratepayers. Federal funding for water and sewer systems fell by 77 percent in real dollars from its peak in 1977 to 2017.7 At the same time, water pipes are aging and need to be replaced, while treatment plants need updates to comply with stronger water quality regulations, and climate chaos creates unprecedented challenges in many parts of the country.8 With weak federal support, water systems rely on rate increases to meet these daunting challenges.9 But many people just can’t keep up with bills that outpace their wages.

Hardships and Water Shutoffs

One of the main collection practices of utilities for unaffordable water bills is service shutoffs.10 In a more typical year, 2016, an estimated 15 million people experienced a water shutoff for nonpayment.11 A 2015 national survey found only 8 percent of municipalities had programs to protect low-income consumers from water shutoffs, and publicly owned water operators were more likely to protect residents from water shutoffs.12

Water shutoffs pose a real threat to human health.13 Without water service, people cannot flush their toilets, wash their hands or bathe. Lack of adequate sanitation can cause diseases to spread and allow people to become sick. The elderly, pregnant women, children and people with diabetes and other illnesses would be especially vulnerable.14 Black and Indigenous people of color, Latinx communities and low-income populations face higher disconnection rates and are more likely to lack access to basic water services.15 Water shutoffs can be traumatic. There is a substantial, statistically significant effect of water insecurity on psychological distress.16

A January 2021 working paper from Duke University researchers, published by the National Bureau of Economic Research, found that policies that promote housing stability through moratoria on evictions and utility shutoffs can have profound impacts on COVID death and infection rates.17

Part 3:

Water Shutoff Moratoria During the Pandemic

A wave of protections and a wave of endangerment provide an opportunity to study outcomes of each approach.

Before the pandemic, protections from water shutoffs were rare in the United States,18 but on March 9, 2020, Detroit became among the first U.S. cities to pause water shutoffs and temporarily reconnect water services for all residents.19 Advocates had fought water shutoffs in Detroit for nearly two decades before this historic decision,20 which sparked a wave of moratoria nationally. Over the next several months, more than 800 localities and states followed Detroit’s lead.21

A Wave of Protections

By June 2020, 34 states had imposed moratoria on water shutoffs, protecting the 247 million people living in those states. Twenty states imposed comprehensive water shutoff moratoria that apply to all water systems in the state, and an additional 14 states imposed partial moratoria that covered only water systems, typically investor-owned utilities, that are regulated by state public utility commissions (see Figure 1 and Appendix A).

States that regulate private water utilities through their public utility commission and states that had higher COVID-19 case rates were more likely to impose a moratorium on water shutoffs in the first two months of the COVID-19 pandemic.22 Cities with higher per capita income, a higher percent of people of color, and higher income inequality and Democratic-led states were also more likely to impose moratoria on water shutoffs.23

It is clear that moratoria on water shutoffs have protected hundreds of thousands of people from disconnection. Based on limited data from the New Jersey Board of Public Utilities, 37,386 households — about 100,000 people — in New Jersey alone were protected from losing their water at the end of 2020 because of the state-issued moratoria.24 California found that 1.6 million households (one in eight households) were behind on their water bills, owing more than $1 billion as of January 2021.25

FIGURE 1. State Water Shutoff Moratoria as of May 2020

Source Data: See Appendix 1

A Wave of Endangerment

Many of these protections were short-lived and expired months before COVID cases peaked in January 2021. By the end of 2020, 22 states had allowed their moratoria to expire, leading to 134 million people losing protections from water shutoffs. Only 12 states still had moratoria in place by the end of 2020 (see Figure 2 and Appendix A). As of December 2020, 65 percent of the country — 211 million people — were not covered under a state- issued moratorium. This includes 75 million people of color and 2.6 million households in the lowest income quintile. These households are most at risk of water disconnection.

The length of state-imposed moratoria varied greatly across the country (see Figure 3 for the number of days that states went without a moratorium during the study period). During the study period, only nine states had a moratorium in place the entire time. Twenty-five states had a moratorium in place part of the time, and 16 states had no moratorium for the entire period.

FIGURE 2. State Water Shutoff Moratoria as of December 31, 2020

Source data: See Appendix 1

FIGURE 3. Days without a state moratorium on water shutoffs during the study period (April 17 -December 31, 2020)

Source data: See Appendix 1

In Michigan, for example, Governor Whitmer issued a comprehensive statewide water restoration order and moratorium on March 28, 2020.26 The order, as extended, was set to remain in effect until at least the end of the year, but in October, the state Supreme Court struck down many of the Governor’s COVID protections, including the shutoff moratorium.27 Figure 4 shows that cases were peaking, due to the second wave, in the days when the moratorium was not in effect. Michigan water advocates successfully passed state legislation to reimpose a moratorium, which went into effect in December 2020.28

FIGURE 4. COVID-19 cases and water shutoff moratoria over time in Michigan (February – December 2020)

Source Data: See Appendix 1 and New York Times COVID tracker (2020).

Part 4:

Our Study

A small change in infection growth rate yields a significant impact.

Study Design

We ran a multilevel mixed effects linear regression to examine the relation between water shutoff moratoria and COVID-19 daily infection growth rate and daily death growth rate between April 17 and December 31, 2020.29 This method has been used in other studies of COVID-19 health policies.30 Both the COVID-19 infection growth rate and death rate had a large fluctuation at the beginning of the pandemic in March due to the low initial denominator of cases, so we excluded these outliers.

We calculate growth rate in confirmed cases and deaths using the prior seven-day rolling average. This smooths spikes and reporting fluctuations (e.g., weekends) to more accurately estimate the trend. Our model controls for the effect of time to get an overall effect of the moratoria.

Because the infection rate is related to testing capacity which varies across states, we controlled for the daily test growth rate in the infection growth rate model. We also controlled for comprehensive coverage of the moratoria (applied to all water systems), and other confounding factors that might affect COVID case rates, including other state policies, such as mask mandates, the level of health insurance coverage and state demographic characteristics, such as minorities and essential workers.31

Results: Significant Decrease in COVID Infections and Deaths with Moratoria

Model results show that for the days when states had
a moratorium on water shutoff in place, daily infection growth had a 0.235 percent decrease and the death growth rate had a 0.135 percent decrease (see Appendix 2). In addition, comprehensive coverage of the moratorium was significantly associated with an even lower infection and death growth rate. This small change in the growth rate had a significant impact.

Protecting 9,000 Lives and Preventing Nearly Half A Million Infections

Had a national shutoff moratorium been in place during the study period, it might have protected 480,715 people from COVID-19 infection and 9,052 people from death. This accounts for 4.0 percent of the increase in confirmed cases and 5.5 percent of the increase in total deaths for the 41 states which had days without a moratorium during the study period. Using model results, we calculate the potential impacts as shown in Table 1 (see Appendix 3 for calculation). These estimates exclude the 9 states which had a moratorium in place (whether partial or comprehensive) during the entire study period. Partial moratoriums cover less of the population; but in the analysis below, we do not distinguish partial and comprehensive, we only measure days when a moratorium was not in place.

TABLE 1. Potential reduction in COVID-19 cases and deaths if water shutoff moratoria in place across all U.S. States (April 17 – Dec 30, 2020)

Source Data: Calculations based on model results (see Appendices 2 and 3) for the 41 states which did not have a moratorium in place during the entire study period

Figure 5 illustrates the number of people in each state that might have avoided contracting COVID had a moratorium been in place. Figure 6 shows the number of lives in each state that might have been saved with a nationwide water shutoff moratorium. The biggest benefits are in states with short or no moratoria, and also reflect the state’s relative population size.

FIGURE 5. Number of people who might have been protected from COVID-19 infection by a shutoff moratorium (April 17 -December 31, 2020)

Source Data: Calculations based on model results (see Appendices 2 and 3)

FIGURE 6. Number of people who might have been protected from COVID-19 death by a shutoff moratorium (April 17 -December 31, 2020)

Source Data: Calculations based on model results (see Appendices 2 and 3)

Part 5:

Conclusions and

5 specific steps could save countless lives and slow the spread of contagion during public health emergencies.

A nationwide water shutoff moratorium might have reduced COVID infections by 4.0 percent and by 5.5 percent in states that lacked moratoria. Through a patchwork of protections in states with existing moratoria on water shutoffs, the growth rate of both COVID infections and deaths was significantly lower, with the biggest protection observed in states that imposed comprehensive moratoria on both public and private water systems. A national moratorium might have saved thousands of people. To ensure protection of water access for every person in the country, Food and Water Watch recommends that President Joe Biden work with Congress to:

Enact a Nationwide Moratorium on Utility Shutoffs for the Remainder of the COVID-19 Emergency.

Enacting a nationwide moratorium on utility shutoffs is an important and urgent measure to help slow the spread of COVID-19. There should be policies in place to automatically impose a water shutoff moratorium during states of emergency in the future. Moreover, vulnerable households must be protected from shutoff at all times. This includes households with young children, seniors, and medically compromised individuals.

Cancel Water Debt

Households have accrued an estimated nearly $9 billion in water and sewer debts over the pandemic.32 Federal support is necessary to offer forgiveness of these debts to avoid a tidal wave of shutoffs when moratoria expire.

Establish Income-Based Water Affordability Programs

Federal funding should support the establishment of state and local programs to provide percentage-of-income payment plans with arrears management components for all households at or below 200 percent of the federal poverty level. Combined water and wastewater bills should not exceed 3 percent of household income, according to the United Nation’s standard of water affordability.33

Collect Better Data

Better data collection and reporting are necessary to help inform policy and solutions. Utilities should periodically report statistics about shutoffs, restorations, arrears, aging of arrears, and other metrics to inform policy. These data must be provided by zip code or census tract to allow for investigation of disparate impacts based on race and other socioeconomic factors and to better inform the outreach of low-income aid providers.

Restore Federal Funding for Water Infrastructure

National support for long-term financing for water utilities would help address systemic inequalities and create stronger, more resilient and more equitable communities. The nation’s water and wastewater systems need federal support.34 The Water Affordability, Transparency, Equity and Reliability (WATER) Act is the type of sweeping legislation needed to address water contamination, affordability, job creation and justice all at the same time.

Water must be a priority for an infrastructure stimulus. With adequate water funding, we can provide immediate relief to households and fight the coronavirus, and we can also protect the health and safety of all communities. We must come out of this crisis with a newfound commitment to providing universal access to water for all.

Tell President Biden: No water shutoffs during a pandemic!


We want to thank the Atkinson Center for a Sustainable Future for partial funding support of the Cornell research.

Report by Xue Zhang and Mildred E. Warner from Cornell University in collaboration with Food & Water Watch.100

  1. U.S. Centers for Disease Control and Prevention. “How
    to Protect Yourself & Others.” February 4, 2021, available
    at getting-sick/prevention.html; Thebault, Reis et al. “How to prepare for coronavirus in the U.S.” Washington Post. March 11, 2020.
  2. For example, see: Missouri Public Service Commission. “Staff report on utility data request responses.” File No. AW- 2020-0356. February 22, 2021 at 34; Tennessee American Water. “Informational filing of Tennessee-American Water Company.” Tennessee Public Utility Commission. Docket No. 20-00047. February 15, 2021 at 4 to 8; Illinois Commerce Commission. “Illinois American Water Compliance Filing.” Docket 20-0309. February 16, 2021 at 2; Grant, Robert. “‘Some families end up homeless’: Jacksonville advocacy group urges utility districts to stop disconnects during pandemic.” Action Jax News. October 8, 2020.
  3. National Academy of Public Administration. “Developing a New Framework for Community Affordability of Clean Water Services.” October 2017 at 2.
  4. Mack, Elizabeth A. and Sarah Wrase. “A burgeoning crisis? A nationwide assessment of the geography of water afford- ability in the United States.” PLoS One, Vol. 12, Iss. 1. January 2017 at 7 to 9.
  5. Montag, Coty. Thurgood Marshall Institute at the NAACP Legal Defense and Education Fund, Inc. “Water/Color: A study of race and the affordability crisis in America’s cities.” 2019 at 2 to 5.
  6. Butts, Rachel and Stephen Gasteyer. “More cost per drop: Water rates, structural inequality, and race in the United States — The case of Michigan.” Environmental Reviews & Case Studies, Vol. 13, No. 4. December 2011 at 386 and 392.
  7. U.S. Congressional Budget Office. “Public Spending on Transportation and Water Infrastructure, 1956 to 2017.” (Pub. No. 54539). October 2018 at Supplemental Table W-8.
  8. Mirosa, Oriol. “Water affordability in the United States: An initial exploration and an agenda for research.” Sociological Imagination. Vol. 51, Iss. 2. December 2015 at 41 to 42.
  9. National Academy of Public Administration at 25.
  10. U.S. EPA. Environmental Financial Advisory Board. “Afford- able Rate Design for Households.” February 2006 at 5.
  11. Food & Water Watch. “America’s Secret Water Crisis: Na- tional Shutoff Survey Reveals Water Affordability Emergency Affecting Millions.” October 2018 at 2.
  12. Homsy, George C. and Mildred E. Warner. “Does public ownership of utilities matter for local government water poli- cies?” Utilities Policy. Vol. 64. Iss. 101057. 2020 at 1 and 5.
  13. Amirhadji, Jason et al. Georgetown Law Human Rights Insti- tute Fact-Finding Practicum. “Tapped Out — Threats to the Human Right to Water in the Urban United States.” April 2013 at 31 to 32.
  14. Ibid. at 31 to 32.
  15. Holmes, Lillian et al. Pacific Institute. “Water and the COV- ID-19 Pandemic: Equity Dimensions of Utility Disconnections in the U.S.” July 2020 at 3 to 4; DigDeep and US Water Alliance. “Closing the Water Gap in the United States: A National Action Plan.” 2019 at 22; Montag, 2019 at 4.
  16. Gaber, Nadia et al. “Water insecurity and psychosocial distress: case study of the Detroit water shutoffs.” Journal of Public Health. 2020 at 1.
  17. Jowers, Kay et al. “Housing Precarity & the COVID-19 Pan- demic: Impacts of Utility Disconnection and Eviction Mora- toria on Infections and Deaths Across US Counties.” National Bureau of Economic Research. January 2021. Available at
  18. Homsy and Warner, 2020.
  19. Neavling, Steve. “As coronavirus spreads, Detroit to restore water to thousands of households, offer moratorium on shutoffs.” Detroit Metro Times. March 9, 2020; Lakhani, Nina. “Detroit suspends water shutoffs over Covid-19 fears.” The Guardian. March 12, 2020.
  20. People’s Water Board Coalition. (Press release). “People’s Water Board Coalition Applauds Detroit Mayor’s Decision to Ban Water Shutoffs and Restore Residential Water.” Decem- ber 8, 2020.
  21. Food & Water Watch. “External-Local-State Water Shutoff Moratoria Amidst Coronavirus.” Accessed March 5, 2021, available at spreadsheets/d/153Ze6RRZ-ZZ9oVkaSErhVHGMv3Z4laQDs- 0GRO7UmYnQ.
  22. Warner, Mildred E., Xue Zhang and Marcela González Rivas. ”Which states and cities protect residents from water shut- offs in the COVID-19 pandemic?” Utilities Policy. Vol. 67. Iss. 101118. September 2020 at 1, 3 to 4.
  23. Ibid. at 4.
  24. New Jersey Board of Public Utilities. “Water and Sewer Ar- rearages as of December 2020.” 2021, available at https:// and%20Sewer%20Arrearages%20December%202020%20 Summary.pdf; U.S. Census. “Quickfacts: New Jersey.” Avail- able at Accessed March 5, 2021.
  25. California Water Boards. “Frequently Asked Questions: COVID-10 Drinking Water Financial Impacts Survey Results.” January 19, 2021 at 2.
  26. Michigan. Executive Order No. 2020-28. March 28, 2020.
  27. Egan, Paul. “Michigan Supreme Court strikes down Gov. Whitmer’s emergency orders, effectively immediately.” Detroit Free Press. October 12, 2020.
  28. Michigan. Public Acts of 2020. Act No. 252. December 22, 2020.
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  35. Laws of Alaska. Enrolled SB 241. §19 and §39. (2020).
  36. Arkansas Public Service Commission. Order. Docket No. 20- 012-A. Order No. 1. April 10, 2020 at 2 to 3.
  37. California Public Utilities Commission. (Press release). “CPUC ensures essential utility services for consumers to assist in Covid-19 mitigation.” March 17, 2020.
  38. California. Executive Order N-42-20. April 2, 2020.
  39. Colorado. Executive Order D 2020-012. March 20, 2020.
  40. Colorado. Executive Order D 2020-031. April 6, 2020; Colo- rado. Executive Order D 2020-051. April 30, 2020; Colorado. Executive Order D 2020-088. May 29, 2020; Colorado. Executive Order. D 2020-098. June 12, 2020. (EO-088 expires 15 days from May 29. The June 12 order includes no moratorium).
  41. Connecticut Public Utilities Regulatory Authority. Motion 1. Docket No. 20-03-15. March 12, 2020.
  42. Connecticut Public Utilities Regulatory Authority. Motion 9. Docket No. 20-03-15. September 2, 2020 at 5.
  43. Delaware. Executive Order. Sixth Modification of the Declara- tion of a State of Emergency for the State of Delaware due to a Public Health Threat. March 24, 2020 at 8 to 9.
  44. Delaware. Executive Order. Twenty-Third Modification of the Declaration of a State of Emergency for the State of Dela- ware due to a Public Health Threat. June 30, 2020 at 12.
  45. Hawaii Public Utilities Commission. Order 37125. Non-dock- eted. May 4, 2020 at 4; Hawaii Public Utilities Commission. Order 37506. Docket No. 2020-0209. December 22, 2020 at 2 to 3.
  46. Illinois Commerce Commission. “Emergency Interim Order.” Docket No. 20-0309. March 18, 2020 at 7.
  47. Illinois Commerce Commission. “Staff of the Illinois Com- merce Commission’s Unopposed Motion for Entry of an Order Approving and Adopting Stipulation Resolving All Issues Between Various Parties.” Docket No. 20-0309. June 10, 2020 at 5 and 8; Illinois Commerce Commission. “Stipu- lation.” Docket No. 20-0309. June 10, 2020 at 2 and 3 (30 days after August 1 are under moratorium period).
  48. Indiana. Executive Order 20-05. March 19, 2020 at 2.
  49. Indiana. Executive Order 20-33. June 30, 2020 at 2.
  50. Iowa Utilities Board. “Order Phasing in Disconnection of Utility Service and Modifying March 27 2020 Order.” Docket No. SPU-2020-0003. May 20, 2020 at 1 to 3.
  51. Kansas. Executive Order No. 20-05. March 17, 2020.
  52. Kansas. Executive Order No. 20-28. April 30, 2020.
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  54. Kentucky. Executive Order No. 2020-323. May 8, 2020 at 3.
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  58. Louisiana Public Service Commission. Special Order No. 43- 2020. July 1, 2020 at 2.
  59. Maine Public Utilities Commission. Order. Docket No. 2020- 00081. March 16, 2020.
  60. Maine Public Utilities Commission. Order. Docket No. 2020- 00081. September 17, 2020 at 1.
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  62. Maryland. Order of the Governor of the State of Maryland. No. 20-07-31-01. July 31, 2020.
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  68. Mississippi Public Service Commission. Clarification State- ment. Docket No. 2018-AD-141. March 19, 2020.
  69. Mississippi Public Service Commission. Order Extending Order Temporarily Suspending Disconnection of Certain Util- ity Services. Docket No. 2018-AD-141. May 12, 2020 at 5.
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  72. New Hampshire. Emergency Order #3 Pursuant to Executive Order 2020-04. March 17, 2020.
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  75. New Jersey Department of Community Affairs, Department of Environmental Protection, and Board of Public Utilities. (Press release). “All water providers asked to suspend shut- offs during Covid-19 outbreak.” March 20, 2020; Hutter, David. “Murphy orders water providers to suspend shut-offs during COVID-19.” March 26, 2020.
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  93. Texas Public Utility Commission. Third Order Directing Certain Actions and Granting Exceptions to Certain Rules. Project No. 50664. May 14, 2020 at 1 and 2.
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