Comment on the Conservation Stewardship Program
ACTION ALERT
YOU CAN HELP SHAPE
THE CONSERVATION STEWARDSHIP PROGRAM
Deadline Extended to: October 28, 2009
Sustainable and organic farming advocates have an important opportunity to help shape the implementation of the new Conservation Stewardship Program, the Nation’s first and only green payments program. CSP pays farmers for producing healthy soil, cleaner water, fewer green house gases and greater biodiversity.
USDA has requested comments on the administrative rules that will govern the implementation of this important new program. While the rules are positive overall, NSAC has identified five areas that require your input to ensure that the new CSP recognizes and rewards the multiple environmental benefits of sustainable and organic agriculture. Additional information and talking points for each are provided below.
1. Payments should be based on environmental outcomes rather than on when a practice is implemented.
2. Resource-conserving crop rotations and management-intensive rotational grazing should receive high ranking and payment points.
3. Organic crop and livestock systems should be recognized for their multiple environmental benefits.
4. A minimum contract payment should be added to the program to encourage participation of small acreage farms and to gain environmental benefits as a result.
5. The CSP payment limits should be retained and enforced.
Comment letters can be as short or as long as you want. You needn’t address all five points. Choose the issues most important to you and put your comment in your own words. You can submit a comment from our website here or follow the instructions that follow the talking points below
KEY ISSUES AND TALKING POINTS
1. Farmers and ranchers applying to participate in CSP should be ranked and paid based on environmental outcomes.
USDA has posed a specific question for comment: Should the program give greater weight and therefore a higher rank and a higher likelihood of acceptance into the program to applications proposing new conservation practices? Or should existing and new practices be given equal weight?
The Environmental Quality Incentives Program (EQIP) and other conservation programs pay farmers for adopting new conservation practices. The CSP, however, is unique among working lands conservation programs. The CSP rewards farmers who are already farming at a high stewardship threshold and provides an incentive to maintain those high stewardship standards.
If a farmer has previously adopted advanced conservation measures and systems, the program is designed to reward that behavior and help pay for continued active management and maintenance of those systems and practices. Farmers should also be expected to and be rewarded for adopting new practices. But CSP ranking and payments should be keyed to environmental outcomes and not on when conservation activities are adopted.
CSP design and regulation should equally balance the benefits of both existing and new practices with the primary measure being the environmental benefits secured by the total conservation system regardless of the timing of adoption of various parts of the system. This is essential to making CSP a program that recognizes and rewards the multiple benefits of sustainable and organic farming systems.
2. Resource-conserving crop rotations and management-intensive rotational grazing should receive strong support under the program.Cropping systems built around resource-conserving cropping systems and cover cropping and livestock systems based on rotational grazing are superior conservation approaches with high, multiple environmental benefits. In fact, the 2008 Farm Bill provides for supplemental CSP payments to farmers newly adopting or improving existing resource-conserving crop rotations.
Both resource-conserving crop rotations and management-intensive rotational grazing systems should receive high ranking and payment points and both should be fully rewarded whether they are an ongoing conservation system or a newly adopted one. The definition for resource-conserving crop rotations should specifically require a perennial grass, legume, or legume-grass mixture for use as a forage, seed for planting, or green manure to be part of the rotation. Rotations that include only crops eligible for farm bill commodity subsidies should not qualify as resource-conserving.
3. Organic crop and livestock systems should be recognized for their environmental benefits.
As part of the 2008 Farm Bill, Congress required USDA to make a special effort to reach organic farmers through CSP, in recognition of the elevated resource and environmental benefits which can accrue from organic systems.
The regulations and overall design of the program should specifically include organic conservation activities as well as ensuring that all conservation activities rewarded under the program include appropriate variations relevant to organic farms where the standard conservation practice may be inappropriate for organic systems. Ranking and payment point values should be roughly equivalent for ongoing organic management and new conversions or transition to organic. In addition, USDA should provide organic producers with clear, farmer-friendly, web-based information on what the comparative cross-requirements are with respect to a CSP Plan and an Organic Systems Plan.
4. A minimum contract payment should be added to the program to encourage participation of small acreage farms and to gain environmental benefits as a result.
The proposed rule contains maximum payments rates per farm, but not minimum payment rates. As a result, many produce and other small acreage farms of 50 acres and less will be less likely to participate since their maximum payments may not be large enough to justify the time and expense of meeting the program requirements. A minimum payment could make it worthwhile for such farms to participate and thus bring about a greater degree of equity with respect to types of agriculture that require fewer acres.
The final rule should include a minimum annual payment rate of $1,500 to encourage small acreage farms to participate.
5. The CSP payment limits should be retained and enforced.
The proposed rule includes a $40,000 per year and $200,000 over 5-year contract limit per farm. There is also a per person or legal entity limit to prohibit creating multiple farms to receive multiple payments. This is a fair payment limit system and one that reflects congressional intent to target payments to small and moderate sized farmers and to control costs. The CSP payment limitation, however, has come under attack by some in the agricultural community who oppose targeting and support benefits that increase proportionally to the size of the operation without enforceable limitations.
The payment limit should be maintained and then vigorously enforced. The final rule should retain both the per farm and per contract payment limitations contained in the proposed rule. The Department should resist pleas to incorporate payment limitation loopholes.
Background in Brief
The Conservation Stewardship Program (CSP) is a comprehensive working lands conservation program designed to protect and improve natural resources and the environment for generations to come. CSP provides technical and financial assistance to farmers and ranchers to actively manage and maintain existing conservation systems and to implement additional conservation activities on land in agricultural production. CSP targets funding to:
• Address priority resource concerns in a given state, watershed or region;
• Improve soil, water, and air quality;
• Provide increased biodiversity and wildlife and pollinator habitat;
• Sequester carbon and reduce greenhouse gas emissions to mitigate climate change; and
• Conserve water and energy.
The 2008 Farm Bill authorizes a new nationwide, continuous sign-up for CSP which means farmers and ranchers anywhere in the country will be able to apply for the CSP any year and at any time of the year. Priority resource concerns will still be set by watershed, but all watersheds will be eligible each and every year. CSP contracts run for 5 years and there is a $40,000 per year payment limitation.
Applicants will complete a Conservation Measurement Tool which will allow them to assess their current conservation activities and choose additional conservation activities they would like to implement. Periodically during the year, USDA’s Natural Resources Conservation Service (NRCS) – the agency that administers CSP – will rank applications, selecting those with the highest rankings until funding for that ranking period is completely allocated. Participants, working with NRCS, will then develop conservation plans and CSP contracts.
The new farm bill provides sufficient funding for the program to enroll 12.8 million acres each year. Acres are allocated to each state based primarily on the amount of farmland in that state relative to the national total. For more information, click here.
How to submit a comment:
You can submit a comment from our website by clicking here or you can email comments directly to USDA at CSP2008@wdc.usda.gov
If you send your own email:
Be sure to identify the Docket Number at the top of your letter as RE: NRCS-IFR-09004. Address your comment letter to: Mr. Gregory Johnson, Director, Financial Assistance Programs, US Department of Agriculture, Natural Resources Conservation Service, 1400 Independence Avenue SW, Room 5237-S, Washington, DC 20250-2890. Be sure to identify yourself by providing your name and contact information. You may also mail your letter to this address or fax it to (202) 720–4265 if you prefer not to email it.