November 7, 2016
Farmers and ranchers are important managers of our shared air, water, and soil resources, and the Conservation Stewardship Program (CSP) recognizes and rewards this critical role. CSP is built on the belief that we must enhance natural resource and environmental protection as we simultaneously produce profitable food, fiber, and energy. By providing comprehensive conservation assistance to whole farms, CSP offers farmers the opportunity to earn payments for actively managing, maintaining, and expanding conservation activities like cover crops, rotational grazing, ecologically-based pest management, buffer strips, and the transition to organic farming – even while they work their lands for production.
Last Friday’s announcement from the U.S. Department of Agriculture (USDA) on the opening of the 2017 CSP sign-up period carried particular significance, because it marks the first time that major programmatic changes will be in place after two years of intensive planning by USDA’s Natural Resources Conservation Service (NRCS).
The National Sustainable Agriculture Coalition (NSAC), has been following the CSP “reinvention” process closely, having played a central role in the development of the program in the late 1990s and remaining one of its most vocal advocates following its official adoption in the 2002 Farm Bill.
While we support the stated goals of the reinvention – making CSP more transparent, accessible, flexible, and farmer friendly – we are disappointed in the lack of transparency throughout the process. Even now, following the announcement of the 2017 sign-up period, there are many important details and new tools, like the eligibility and ranking processes and payment structure for conservation activities, that are not yet available to farmers and ranchers.
The details of the CSP reinvention have major implications for farmers, ranchers, and conservation advocates across the country. CSP’s footprint is enormous – with more than 70 million acres of working farm and ranch lands currently enrolled, CSP is the nation’s largest working lands program. NRCS is authorized to enroll an additional 10 million acres in CSP in 2017, at which time more than 12 million acres will also be up for renewal.
Farmers and ranchers interested in enrolling have until February 3, 2017 to complete the initial CSP application, which is a simple form that asks for basic information regarding land ownership, type of production, and contact information. NRCS offices will begin processing applications on November 14, and initial information on the restructured program is available on the new CSP portal. Although applicants can sign up for CSP anytime throughout the year, those who miss the February 3 deadline will not be considered for the program until 2018.
With a new administration soon to be in office and a new farm bill on the horizon, it is particularly important that the program advance farm and ranch stewardship goals in a manner that works well for both farmers and the environment. We urge farmers and ranchers to take advantage of this initial sign-up deadline, and NSAC will continue to push NRCS to make critical details and farmer resources available as soon as possible, ideally well before the February deadline.
Major Questions Remain
In a previous post NSAC identified several key questions we were looking to have answered as the new program details were unveiled; we are disappointed that last week’s announcement fails to address those questions or include many much-needed details about the program’s reinvention.
Thus far, NRCS has released a brief video on the Conservation Activity Evaluation Tool (CAET), which will be used to determine if applicants are meeting the minimum stewardship requirements to participate in CSP. However, the video cannot be customized or tailored to fit individual farm operations, and thus is of limited use to producers. We have instead urged NRCS to make the tool itself publicly available as soon as possible. It is our understanding that NRCS will release a public facing CAET within the next few months.
We are pleased to see that the final Application Evaluation and Ranking Tool (AERT) was revised to include a question to addresses an applicant’s current level of stewardship; however, it is unclear exactly how significantly this question (#3) will factor into a participant’s overall ranking score. Similarly, while we understand that the estimated conservation benefits of planned activities will be factored into the ranking score (through an “efficiency score”), we have yet to see any details regarding exactly how this will be determined.
Finally, CSP is unique amongst conservation programs for rewarding producers on the basis of their current and expected conservation outcomes. NRCS has publicly provided information on how payments for a participant’s baseline level of conservation will be determined, but we are still awaiting information on the “payment schedules” for all conservation activities available through CSP. Access to this information is critical for a potential participant to decide what enrollment in CSP would mean for their operation.
Flexibility and Opportunities for Stakeholder Input
We are pleased that as part of the 2017 changes, USDA will incorporate state and local concerns by utilizing input from farmers, ranchers, and partners in State Technical Committees (STCs) and local workgroups. In today’s announcement, NRCS Chief Jason Weller addressed this change:
“This year, the Conservation Stewardship Program provides even more opportunities for conservation and greater flexibility at the local level to prioritize resource concerns and conservation approaches. State and locally customized CSP tools will improve the customer experience during application evaluations.”
NSAC encourages participation in STCs by farmers and organizations committed to sustainable agriculture in order to ensure the new structure reflects the key resource challenges and most significant opportunities to improve sustainability in each watershed or eco-region.
Emphasis on the Highest Level of Stewardship Is Key
Through CSP, participants receive payments for actively managing, maintaining, and expanding conservation activities on lands in agricultural production. We applaud NRCS for expanding farmers’ options for conservation activities (practices, enhancements, and bundles of enhancements) in the reinvented CSP, and we will work with the agency to ensure that the activities that offer the greatest conservation benefits are appropriately incentivized and promoted. In the past we have seen a continued disconnect between the most frequently selected and most environmentally beneficial enhancements; we hope to see this trend reversed as part of the 2017 overhaul.
In the sign-up announcement, NRCS pointed to key conservation activities like utilizing “cover crops, ecologically-based pest management, buffer strips, and pollinator and beneficial insect habitat.” We hope to see payment rates and bundle incentives that properly reward the expected benefits and resource concerns that each conservation activity addresses.
Materials and Analysis to Follow
Once additional information is available, NSAC will post additional guidance on the CSP application process, including details of conservation activities, payments and ranking and eligibility tools.
In addition to the opportunity to enroll in new contracts, existing CSP participants will be able to renew their 5 year CSP contracts for an additional 5 years. The deadline for farmers with 2013 contracts that expire after 2017 to apply to renew their contracts is anticipated to be sometime in March or April 2017.
Categories: Conservation, Energy & Environment