November 17, 2015
The Conservation Stewardship Program (CSP), the largest conservation program in the United States, is undergoing a major overhaul, or “makeover” for the 2016 sign-up period. To date, nearly 70 million acres are enrolled in CSP, and 60 million acres will be added or renewed before the end of the current farm bill. With so many acres enrolled or soon to be enrolled in the program, there’s a whole lot at stake as CSP changes are finalized in the next two months.
Administered by the U.S. Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS), CSP provides farmers and ranchers technical and financial assistance to actively manage existing conservation and to implement additional conservation activities. CSP is the only comprehensive working lands conservation program designed to help farmers and ranchers protect and improve natural resources on land in agricultural production.
CSP is one of the farm bill’s two large working lands conservation programs, alongside the Environmental Quality Incentives program (EQIP). EQIP provides one-time assistance to correct a problem or add farm infrastructure, whereas CSP provides ongoing performance-based stewardship payments to support advanced conservation systems . The National Sustainable Agriculture Coalition (NSAC) continues to advocate that the new CSP must retain its unique identity as a program based on outcomes and environmental benefits.
Where was the Public Comment and Stakeholder Input?
The upcoming overhaul is taking place outside of the usual farm bill and farm bill rule making process, which begs the question of how stakeholder input is being factored into the new CSP. Had the proposed changes been previewed in the Interim Final Rule, there would have been a greater opportunity for the public to comment on the program redesign.
Despite this procedural shortcoming, the overhaul nonetheless presents an enormous opportunity to make CSP more transparent, more accessible, more farmer-friendly, and more committed to rewarding advanced stewardship, environmental benefits, and an ongoing commitment to conservation improvement. It is on that basis that we will assess whether the program makeover is a success at a macro level. At a more specific level, the questions we will use to judge the success or failure of the makeover include those in the next section below.
What We Know About the Overhaul and Key Questions
NRCS intends to have the new program up and running by January. Information on the the new program structure has been slowly trickling in. Here are some highlights –
Key Concerns: Despite the fact that there were numerous problems regarding the transparency and accessibility of the CMT, it nonetheless provided a tool with which to assess and reward ongoing and new conservation based on an estimate of conservation and environmental benefits. Will the new screening sheets continue to factor in environmental benefits and performance when assessing CSP applications?
Key Concerns: The ranking tool for EQIP is imprecise and very rudimentary. In customizing it for CSP, will AERT simultaneously be improved? Also, how will state and local priorities be assigned and who will be involved in that process?
Key Concerns: An enhanced linkage between enhancements and practices provides an opportunity to promote continued improvement and support producers who want to enhance their stewardship. By the same token, however, that linkage can also reduce conservation innovation and thus hinder program outcomes. How will conservation innovation be retained in the new program? Will low ranking enhancements that nonetheless tie directly to a practice be retained? Will the elimination of CSP-eligible conservation practices limit farmer options to exceed the stewardship threshold for additional priority resource concerns, and if so, how does that help advance the program’s purpose? Will comprehensive conservation planning be included as a program option and payment option in the new CSP?
Key Concerns: Will payments still be based in whole or in part on conservation outcomes? Will equal weight given to active management and new adoption? How many different payment schedules will be used, and how will the process work at the national, regional, and state level?
Key Concerns: The inability to do contract modifications has been a problem with CSP to date, so added flexibility is most welcome. Will the new system allow for both the modification of specific conservation activities, provided the same or higher level of conservation outcomes can be achieved, as well as the addition or subtraction of land under the control of the farmer or rancher?
Farmer Outreach will be Critical
With such sweeping changes planned for CSP, reaching out and communicating with CSP contract holders and potential applicants must be front and center in NRCS’s plan for the 2016 sign-up. Outreach will be essential for all CSP applicants, and in particular for contracts up for renewal, as those farmers and ranchers originally signed up for a significantly different CSP. We have not yet seen a concrete plan for farmer outreach from USDA.
At NSAC, we will do as much quick outreach and communication work as possible for the 2016 enrollment period and then concentrate on developing new materials and more comprehensive outreach strategies for the years to follow.
Stay tuned for more information on CSP’s 2016 makeover. NSAC will provide more information as it becomes available.