ADC flags data gaps, farm-data control, and methane metrics
CHILTON, Wis., April 27, 2026 — As USDA weighs expanding farm-level data collection tied to greenhouse gas (GHG) modeling, dairy farmers are raising a more fundamental question: Are the underlying metrics—and the data system itself—getting it right?
In public comments filed with USDA, the American Dairy Coalition (ADC) warns that data expansion proposed by checkoff organizations Dairy Management Inc (DMI) and its Innovation Center for U.S. Dairy, tied to sustainability and Net Zero initiatives, is premature and that existing USDA datasets show growing gaps directly impacting dairy farm economics.
In a follow-up brief, ADC also warns that data collection systems are being built on methane assumptions that remain unsettled, pointing to the central role methane accounting now plays in shaping data requests. Current GHG modeling commonly treats enteric methane from cattle as a new, long-lived, accumulating gas, while a growing body of scientific discussion recognizes methane’s short-lived nature and the recycling role of cattle. The coalition argues that how methane is measured ultimately determines how dairy is valued, regulated, and positioned in the marketplace—raising concerns about building expanded data systems on metrics that overstate the warming impact of stable cattle herds as cattle recycle natural, existing carbon over time.
DMI and its Innovation Center, have asked USDA to collect new detailed farm-level data to support their environmental modeling and verification of GHG emissions reductions for their Lifecycle Assessments and the FARM ES program. Their request includes expanded USDA data collection and reporting on detailed feed rations by animal age and class, manure management systems, soil amendments, operational water use and re-use (i.e. cattle drinking, parlor wash down) beyond current irrigation surveys, and it calls for more geographically-specific reporting of this information at the state and county levels for spatial modeling.
In its public comments to USDA, DMI states that “high-quality, publicly available, and well-documented datasets are essential” to support these efforts.
ADC argues this proposal represents a departure from USDA’s traditional role of collecting statistical data for market transparency, economic forecasting, and federal policy. In its filing, ADC states that expanding into detailed farm-level reporting introduces new questions around data ownership, use, and risk as well as potential for scope-creep into regulation and market access. This is of particular concern given that the checkoff program is advancing these recommendations to USDA, which oversees checkoff activities, while farmers fund the checkoff program through mandatory, not voluntary, deductions.
“While framed as sustainability support, this would be a substantial expansion into proprietary farm business information outside what dairy farmers have historically been asked—or have requested—to provide,” ADC states in its comment.
ADC further contends that these data demands are not occurring in isolation. Farm-level data collection tied to sustainability programs is already happening through supply-chain channels, where participation is often described as voluntary but increasingly functions as a condition of market access. ADC cites its farmer survey results: most producers feel participation is required in practice, with most reporting they have not signed data-sharing agreements or were not sure if such agreements exist, nor were they compensated for the use of their data.
This dynamic, ADC warns, risks creating an uncompensated transfer of value from farms to the broader supply chain, where environmental claims and market advantages, derived from farm-level data and practices, are captured without clear benefit returning to the dairy farmers who generated the data.
In its public comments, ADC also urged USDA to address existing gaps in its current data systems, highlighting the widening gap between USDA’s NASS-reported All-Milk price and the actual returns farmers receive represented by USDA's AMS-reported Mailbox Milk price, a divergence that has grown from an average of 11 cents per hundredweight between 2008 and 2016 to average 63 cents between 2017 and 2025, and averaged $1.00 since new Federal Milk Marketing Order changes went into effect (June 2025-Jan.2026). According to ADC analysis, this disconnect undermines the accuracy of Dairy Margin Coverage calculations and raises broader concerns about whether federal data reflect real farm-level conditions. ADC also took the opportunity to suggest ways to improve the DMC margin calculation.
Additional data-gaps cited in the ADC public comments include USDA's decision to continue monthly Milk Production reports but discontinue monthly Cold Storage Inventory reports during the 43-day government shutdown in 2025. The imbalance in reporting contributed to murky market signals. ADC also cited the unflagged revisions to state-by-state licensed dairy herd totals that significantly understated 2025 farm exits and suggested that ultrafiltered and extended shelf-life (ESL) products should be separated in monthly Estimated Retail Fluid Milk Sales reporting as new federal pricing adjustments are tied to these categories.
ADC sees USDA data systems depending on voluntary farmer and stakeholder participation and trust—both of which could be jeopardized if data collection expands to detailed sustainability-related information without clear safeguards for farmers.
“Farm data has value, and that value is being captured,” said Sherry Bunting, ADC Dairy Market Analysis & Policy Advisor. “Dairy farmers need to remain in control of how their proprietary business data is collected, used, shared, aggregated, and monetized. We are looking carefully at this issue, which has been raised by dairy farmers and confirmed in our recent producer survey.”
ADC’s message to USDA is straightforward: address current data gaps, ensure transparency and trust, and fully evaluate the scientific and economic implications before considering expansion of farm data collection tied to sustainability metrics.
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American Dairy Coalition Inc | PO Box 104 | Chilton, WI 53014 US
