Illinois’ draft Comprehensive Climate Action Plan (CCAP) outlines strong policies to reduce pollution from energy, transportation, and industry, but falls short in addressing agriculture, land use, and water systems. Instead of setting clear targets and accountability measures, it relies on voluntary approaches that have historically been ineffective. Key issues—like water use, wetlands protection, and the environmental impacts of large agribusiness—are insufficiently addressed or missing altogether.
Prairie Rivers Network has created a public comment letter that calls for stronger, more concrete action, including enforceable agricultural emissions goals, measurable commitments to land conservation, and better water management as part of climate resilience. Illinois has a critical opportunity to create a more effective and equitable climate plan if it takes clearer, more decisive steps in these areas.
Add your signature below to Prairie Rivers Network’s public comment letter as a response to the draft Illinois Comprehensive Climate Action Plan. Signatures will be delivered at the end of the day on Friday, May 1st. Read the full letter below!
PRN’s Public Comment Letter for Draft Illinois Comprehensive Climate Action Plan:
Illinois EPA and Climate Planning Team:
We are writing as Illinoisans to express serious concern and disappointment with the agriculture and land use components of the draft Comprehensive Climate Action Plan (CCAP) released in April 2026, as well as to request greater attention to water in CCAP.
The Plan reflects significant analysis and policy development in electricity, transportation, buildings, and industry. That work should be applauded. But the contrast makes the gaps in agriculture and land use impossible to ignore. In a state where agriculture occupies roughly 72% of the land landscape and represents a growing share of emissions, this section does not meet the standard set elsewhere in the Plan.
The agriculture and land use sections do not match the rigor of the rest of the Plan.
Across the other sectors in the Plan, the state is willing to mandate change, set targets, and design real policy for emissions reductions. Agriculture is treated entirely differently. Instead of taking this opportunity to create a demand for meaningful change, the Plan offers one measure: publicly-funded incentives of up to $200 per ton of CO₂e abated.
There is no regulatory backbone, no clear targets, and no sector-specific policy design.
Natural lands fare even worse. The executive summary advertises forest expansion, wetland flooding, urban greenspace, and grassland restoration. None of these appear as measures in the Plan.
This matters for fairness as well as climate outcomes. The public is being asked to pay twice: once to subsidize an industry whose practices generate the pollution, and again to pay that same industry to reduce it. The petroleum and chemical industries are making the gains and the public is absorbing the losses.
The Plan documents public input—and then ignores it.
The draft Plan accurately summarizes what Illinois residents and stakeholders said during last summer’s public comment process: move beyond marginal practices on the corn-soy system, support diversified and perennial agriculture, protect wetlands and floodplains, and avoid “false solutions” such as CAFO methane digesters and cropland-based biofuels.
But the Plan does not include that input as part of measurable goals. Listing concerns in a stakeholder section while proceeding without engaging them does not meet the meaningful engagement standard the CPRG process requires.
We should not be paying polluters not to pollute.
The Plan proposes no regulatory measures for agriculture at all. When large emitters are producing pollution that damages water quality, air quality, soil health, and the climate, the appropriate response is to require reductions, not to ask taxpayers to pay for reductions. Every other sector has some regulatory backbone. Agriculture, alone among major emitting sectors, is treated as a purely voluntary, incentive-driven space.
The voluntary approach also does not produce permanent reductions. Carbon stored in soil through reduced tillage can be released in a single tillage pass the moment payment stops. Worse, the state’s CPRG dollars are flowing to farmers who already practice no-till or strip-till. We’re not even buying climate progress, we’re paying for the status quo.
The Plan ignores polluting industries upstream from farming.
Agricultural emissions are shaped by fossil fuel-based fertilizers and pesticides, biofuel-driven commodity markets, and an overproduction-driven processing and supply chain.
Much of this system is controlled not by individual farmers, but by large corporations, including fossil fuel-based fertilizer and pesticide manufacturers, processors, and agribusiness firms. Yet the Plan largely treats agriculture as a land-use issue, rather than as part of a broader industrial system. Fertilizer manufacturing emissions are largely invisible to Illinois’ inventory because most fertilizer is produced out of state, while the consequences—soil nitrous oxide, nitrate runoff, drinking water contamination, harmful algal blooms—show up here. Any serious agricultural climate strategy must address the entire chain, not just the farmer end of it.
The Plan should also address the loss of carbon sequestration potential due to the intensive agricultural system as compared to a system of agriculture that sequesters carbon, methane and other GHG through natural processes. Public investment should support the transition to more sustainable and resilient food production methods—diversified rotations, perennial crops, and pasture-based livestock. Tax dollars should not be used to subsidize temporary, easily reversible practices like strip-till or no-till; public money should be invested in lasting change.
Land use is not treated as a policy priority
Natural land protection and restoration are absent from the Plan beyond serving as a static carbon sink. Other states have shown what a serious approach looks like. Minnesota treats natural and working lands as a core climate goal, with peatland restoration commitments and quantified tree canopy targets. California has produced quantified land restoration targets across eight landscape types, with assigned agency responsibility. Illinois already borrows regulatory models from Colorado, Massachusetts, New York, and Vermont for buildings and industry. There is no reason it cannot borrow from Minnesota and California for agriculture and natural lands.
Water security is a missing piece of the climate strategy
Illinois faces more variable precipitation and climate, as well as a growing industrial and agricultural water demand, and a voluntary water-use reporting system unequipped for current demand. The Plan projects a ninefold increase in data center electricity demand by 2038 with no associated water analysis. Water is foundational to agriculture, ecosystems, and human health, and should be treated as such in the final Plan.
What we are asking for in the final Plan
- Rewrite the agriculture and natural lands sections to match the rigor of every other sector, with specific measures, modeled outcomes, program architecture, and implementation pathways.
- Add regulatory measures alongside incentives. Voluntary programs alone will not deliver the scale of reductions needed, and they unjustly place the full cost on the public.
- Prioritize durable, irreversible reductions. Public dollars should buy permanent emissions reductions wherever possible. Where reversible practices are funded, the Plan should disclose the perpetual payment obligation honestly and weigh it against the cost of durable alternatives.
- Establish upstream accountability for fertilizer, pesticide, and chemical input producers, including fees, standards, and supply chain accountability.
- Quantify and commit to the land restoration strategies already named in the executive summary, with acres, costs, timelines, and assigned agency responsibility.
- Fund the transition, not the status quo. Support farmers and workers actively moving toward perennial systems, diversified rotations, rotational grazing, and pasture-based livestock.
- Conduct transparent reassessment of biofuels and methane digesters, grounded in land use, water, and community impacts
- Include a comprehensive water security strategy with mandatory metering for high-capacity users, expanded groundwater monitoring, and integration of land and water policy.
- Respond substantively to public input. If the agency disagrees with stakeholder recommendations, the final Plan should explain why.
Conclusion
Illinois has demonstrated, in other sectors of this Plan, that it can design serious, detailed, and enforceable climate policy. Agriculture, land use, and water are not peripheral issues. They are central to any credible climate strategy and thus should meet that same standard.
We urge the Illinois EPA to revise these sections so that the final Plan reflects not only the importance of these sectors, but the level of policy ambition required to address them.
Thank you for your consideration.
[Signers will be added here]
