Proposal 4
Agricultural Workforce Stability Through Administrative Coordination
Food Security Is Workforce Security
Agriculture is the only major industry governed by biology rather than scheduling. Crops ripen when they ripen, harvest windows open for days, and missing labor at the wrong moment means permanent loss. The immigration system, however, operates through queues, adjudication cycles, and procedural timelines that cannot be accelerated to match planting and harvest seasons.
This mismatch has created decades of instability for farmers, workers, and regulators alike. The proposed framework does not attempt to expand immigration categories or create new residency pathways. Instead, it aligns administrative authority with operational reality by establishing a monitored labor participation authorization coordinated between the Department of Homeland Security and the Department of Agriculture.
The goal is continuity: lawful work participation tied directly to agricultural activity, preserving both enforcement credibility and domestic food production stability.
1. The Core Problem: Biological Timelines vs Administrative Timelines
Agricultural Production Cycle
- Planting windows measured in weeks
- Harvest windows measured in days
- Weather determining scheduling
- Irreversible crop loss if missed
Immigration Processing Cycle
- Filing queues measured in months
- Adjudications measured in years
- Staffing-dependent timelines
- Unpredictable outcomes
This creates a structural conflict.
Farmers must secure labor in advance of events that cannot be delayed. The immigration system provides authorization after events that cannot be reversed.
Because lawful channels cannot consistently match seasonal needs, a predictable pattern develops:
Labor shortage → emergency hiring → legal uncertainty → enforcement conflict → crop waste
This pattern is not driven by policy preference but by operational necessity. Food production continues regardless of administrative readiness.
A stable system requires authorization that matches the timing of agricultural activity rather than attempting to compress agricultural activity into adjudication timelines.
2. Existing Authority Enables Coordination
Federal immigration administration already manages temporary authorized presence through regulation and administrative procedure. The executive branch routinely implements work-authorized classifications tied to specific conditions, compliance requirements, and monitoring.
Similarly, the Department of Agriculture already maintains:
- Regional labor shortage data
- Seasonal production forecasts
- Crop cycle reporting
- Commodity workforce demand indicators
The two systems track the same labor need from different perspectives:
USDA
Measures demand
DHS
Regulates eligibility
Currently, they operate independently. The proposed framework connects them operationally rather than legislatively.
No new visa classification is required because the objective is not permanent immigration status. The objective is monitored workforce participation tied directly to active agricultural employment.
Authorization therefore functions as:
- A compliance authorization
- Not a residency pathway
- Not a quota-based admission
- Not a permanent status
The program regulates activity rather than admission.
3. The Compliance-Based Agricultural Authorization Model
The proposed agricultural participation authorization operates on an activity-based model.
Authorization exists while agricultural work exists.
Registration
Individuals complete identity verification and background screening before participation.
Employer Participation
Farms enroll as participating employers subject to reporting requirements.
Work Reporting
Verified payroll or contract agricultural labor activates and maintains authorization.
Mobility
Workers may move between registered farms as seasons change across regions.
Renewal
Authorization renews based on continued agricultural participation rather than elapsed time.
Termination
Authorization ends after prolonged inactivity unrelated to verified hardship.
If crops exist → labor exists → authorization exists.
If participation stops → authorization stops.
The system therefore regulates conduct rather than duration.
4. Operational Effects on Stakeholders
Farmers
- Predictable workforce availability
- Reduced harvest loss
- Lower recruitment uncertainty
- Improved production planning
Workers
- Lawful labor participation
- Identity recognition
- Protection from informal labor exploitation
- Ability to move regionally with seasons
Government
- Clear distinction between lawful and unlawful employment
- Reduced need for reactive enforcement
- Improved tax reporting compliance
- Focused inspection allocation
Instead of broad enforcement pressure across the agricultural sector, oversight becomes targeted because lawful participation channels exist for the exact work generating compliance conflict.
This reduces friction between regulators and producers while strengthening enforcement credibility.
5. National Economic and Food Supply Impact
Agriculture affects far more than rural economies.
Labor instability influences:
- Food price volatility
- Import dependency
- Transportation supply chains
- Processing plant utilization
- Export competitiveness
When domestic labor becomes unpredictable, producers reduce acreage or relocate production abroad. This does not eliminate demand — it transfers production outside national oversight.
A monitored agricultural workforce authorization preserves domestic production without altering immigration quotas or residency pathways.
Workers remain temporary
Authorization remains conditional
Participation remains verifiable
Production remains domestic
Consumers benefit through supply stability, and enforcement benefits through clarity.
The objective is stability, not expansion.
H-2A Visa Program Growth
DOL and State Department data on temporary agricultural worker visa usage.
H-2A Positions Certified & Visas Issued
| FY | Certified | Issued | YoY Growth |
|---|---|---|---|
| FY2020 | 275,430 | ~213,000 | +8.0% |
| FY2021 | ~317,000 | 258,000 | ~15% |
| FY2022 | 371,619 | 298,000 | +15.0% |
| FY2023 | 378,513 | ~310,000 | +10.5% |
| FY2024 | 384,900 | — | +1.7% |
384,900
FY2024 positions certified
7×
Growth since 2005
42%
Via Farm Labor Contractors
Agricultural Labor Shortage
USDA, AFBF, and DOL survey data on farm labor availability.
2.4M
Agricultural jobs to fill
56%
Farmers report shortages
141,733
Farms lost (2017–2022)
42%
Farmworkers lack authorization
Crop Farmworker Composition
Source: USDA ERS / DOL NAWS (FY2020–2022)
2.94%
food price increase from a 10% decrease in domestic farm employment — Michigan State University (Dec 2025)
H-2A Program Costs & Reform
Per-worker costs and current legislative reform proposals.
| Cost Item | Amount | Notes |
|---|---|---|
| Application fees (per worker) | $1,350+ | Up ~$600 in 2 years |
| Housing (per worker/season) | $9,000–$13,000 | Biggest nonwage expense |
| Avg AEWR (2024) | ~$17.55/hr | Ranges $14.53–$19.75 by state |
| Total per-worker cost | ~$5,000+/season | Not counting wages |
Farm Workforce Modernization Act (H.R. 3227, 119th Congress)
Introduced May 7, 2025 by Reps. Newhouse (R-WA) and Lofgren (D-CA). Previously passed House in 116th and 117th Congresses.
- Certified Agricultural Worker (CAW) status — could legalize ~850K unauthorized workers + 1.5M dependents
- One-year AEWR freeze, then caps at 3.25% annually
- Portable H-2A visa pilot (10,000 workers); visa extended to 3 years
- Mandatory E-Verify for agricultural employers
$1.537T
Agriculture, food & related industries GDP (2023, 5.5% of total)
$53B+
Forecast farm labor costs in 2025 (up 6.9% in 2024)
Agricultural labor challenges are often framed as immigration debates, but they are fundamentally coordination problems. Crops operate on biological deadlines; immigration systems operate on administrative timelines. Stability emerges when authorization follows activity rather than when activity waits for authorization.
By coordinating DHS compliance authority with USDA labor demand data, the government can establish a lawful, monitored workforce channel that protects farmers, workers, consumers, and enforcement credibility simultaneously.
This framework does not expand immigration categories. It aligns government administration with operational reality. When lawful participation matches real economic demand, informal labor markets decline naturally — not through restriction, but through relevance.