May 23, 2019
Last week, the United States Department of Agriculture’s (USDA) Farm Service Agency (FSA) announced that they would begin accepting applications on June 3, 2019 for the Continuous Conservation Reserve Program (CCRP). CCRP pays farmers to install partial field conservation practices, primarily conservation buffers or wildlife habitat. For this current enrollment opportunity, eligible practices are limited to a specific set of practices with direct water quality benefits.
Unlike general CRP sign-ups, there is no competitive bidding or ranking process; instead, the land is enrolled automatically if it meets the eligibility criteria. Farmers and landowners are able to enroll such land at any time, rather than waiting for specific enrollment periods. After the 2014 Farm Bill expired last fall, FSA stopped accepting applications for CCRP; this limited sign-up represents the first available opportunity since the passage of the new farm bill.
The continuous sign up period (“signup 52”) will open on June 3, 2019. Participants with current CCRP contracts that are coming due this year have until August 23, 2019 to re-enroll. Participants seeking to enroll new land can do so at any time, unless and until FSA announces that it is not accepting more applications.
More information from FSA on the signup period and how to apply is available here.
In Signup 52, FSA is offering enrollment for a subset of the total conservation practices available through CCRP. FSA will also begin accepting applications through the Conservation Reserve Enhancement Program (CREP) under existing CREP opportunities. There will be additional opportunities later this year for enrollment in the CRP Grassland Initiative, as well as the General CRP signup. The FSA announcement on CCRP provides guidance for current CRP participants with contracts set to expire by September 30, 2019.
Last month, the National Sustainable Agriculture Coalition (NSAC) urged FSA to immediately move forward with CCRP sign-up this year. We also recommended that FSA focus strongly on outreach, ensuring that participants with CRP contracts set to expire this year were notified of their options to reenroll or manage the land coming out of CRP. We are pleased that FSA is moving forward with CCRP signup this summer, but believe there are still remaining gaps and opportunities for further improvements in the future.
The Conservation Reserve Program (CRP) offers multiple enrollment options, including a periodic “general sign-up” through which large blocks of land are bid into the program on a competitive basis and ranked using an Environmental Benefits Index (EBI). FSA has announced that they will hold a general CRP signup later this year, likely in December, following the release of rules to make changes as directed by the 2018 Farm Bill.
CRP also includes a continuous signup option, CCRP. CCRP pays farmers to install targeted, partial field conservation practices on the most environmentally sensitive lands. CCRP includes individual conservation practices, as well as several special initiatives, including the:
The 2018 Farm Bill increases the overall CRP acreage cap, stepping it up over the life of the 2018 Farm Bill from 24 to 27 million acres. Within that overall cap, USDA is directed to ensure that at least 8 million acres (and up to 8.6 million acres by 2023) are enrolled in CCRP. Additionally, at least 2 million acres need to be enrolled in the CRP Grasslands Initiative by the end of the farm bill.
As part of this week’s announcement, FSA also announced that it is accepting offers through approved CREP agreements beginning June 3, 2019. CREP participants with expiring contracts also have until August 23 to apply to re-enroll.
As was the case with last year’s CCRP enrollment, only enrollment offers for a subset of the total practices available through CCRP will be available through continuous signup 52. Among those practices available, NSAC is glad that the offerings include conservation activities that are critical for protecting and enhancing water quality, including: filter strips, conservation buffers, grass waterways, and bioreactors. Recognizing the significant role that CCRP can play in protecting water quality, the 2018 Farm Bill authorized the CLEAR Initiative. Congress also directed FSA to ensure that at least 40 percent of all continuous acres enrolled go towards practices that help farmers limit nutrient and sediment runoff from their lands and improve neighboring water quality.
The chart below lists the practices that will be offered for participants enrolling in signup 52, and includes the FSA conservation practice code number.
|CP8A||Grass Waterways, Non-easement|
|CP9||Shallow Water Area for Wildlife|
|CP15A||Establishment of Permanent Vegetative Cover (Contour Grass Strips)|
|CP21B||Denitrifying Bioreactor on Filter Strips|
|CP21S||Saturated Filter Strips|
|CP22B||Denitrifying Bioreactor on Riparian Buffers|
|CP22S||Saturated Riparian Buffer|
|CP23||Wetland Restoration on Floodplain|
|CP23A||Wetland Restoration, Non-floodplain|
|CP27||Farmable Wetlands Pilot Wetland|
|CP28||Farmable Wetland Pilot Buffer|
|CP30||Marginal Pastureland Wetland Buffer|
|CP37||Duck Nesting Habitat|
|CP39||Farmable Wetland Program Constructed Wetland|
|CP40||FWP Aquaculture Wetland Restoration|
|CP41||FWP Flooded Prairie Wetland|
More details on the specific CRP conservation practices are available here.
NSAC was pleased to see the inclusion of these water quality and wetland practices. We were disappointed, however, that several other critical in-field (as opposed to edge of field or stream-side) conservation practices are not being made available for enrollment during this particular sign-up. For example, the contour buffer strips (CP15A) are included in this sign up, but the majority of other in-field practices that foster soil conservation and water quality protection (that would normally be eligible for enrollment in CCRP) are not made available. In-field conservation practices not available in this sign up include but are not limited to: upland buffers, field windbreaks, shelterbelts, living snow fence, cross wind trap strips, and pollinator habitat. Although these practices are relatively low in terms of current acreage enrolled, it is concerning that existing enrollments of these practices are unable to reenroll through this signup.
FSA has not yet provided clear guidance on the options for contract holders with expiring CCRP contracts that include practices not eligible through signup 52. NSAC remains concerned about the potential implications for these contracts, as well as the significant loss of conservation benefits that would result if they were not renewed. In-field buffer practices can also play an important role in sediment and runoff control, protecting water quality, and protecting and enhancing wildlife habitat.
Additionally, we are disappointed that this signup period’s available practices once again will have negative impacts on the CRP Organic Buffer Initiative, which is specifically targeted for organic farmers to install buffers on their land. These buffers help participants protect soil and water quality, improve biodiversity and habitat, and also protect organic farms against pesticide or genetic drift from neighboring operations. This year’s enrollment options will unfortunately make the Organic Buffer Initiative irrelevant, except in cases where an organic field is bordered by streams on multiple sides. Important in-field options that have been previously available as part of a CCRP Organic Buffer Initiative contract – including windbreaks, pollinator habitat, upland buffers – are not available as part of sign-up 52.
As was the case with last year’s CCRP enrollment, signup 52 does not include signup incentives (SIPs) or practice incentives (PIPs) for conservation practices adopted as part of this enrollment opportunity. Generally, FSA supports participating farmers in maximizing water quality and other environmental benefits through the use of SIPS and PIPs within CCRP and CREP. SIPs are a one-time bonus payment for the adoption of the specific practice, whereas PIPs are one-time additional cost share payments to help cover a percentage of the eligible installation costs of the practice.
The fact that incentives are not offered is especially disappointing, given the clear direction provided in the 2018 Farm Bill and the significant environmental benefits associated with the eligible conservation practices offered under signup 52. In addition to statutory authority for incentive payments, the 2018 Farm Bill also provides report language highlighting the importance of supporting these practices through CCRP:
“The Managers maintained continuous enrollment and incentives for continuous practices, including signing incentives, incentives to provide additional cost-share, and those related to specific practices, such as buffers, and wellhead areas, for certain high conservation value practices. These continuous practices are typically smaller, more targeted, and implemented only on parts of fields or farms with higher practice establishment costs, which often require higher payment rates.”
This year’s signup will further limit the financial incentives available for CCRP participants by reducing rental rates available. Rental rates are down to 90 percent of existing soil rental rates (SRR’s), as directed by the 2018 Farm Bill. Given the lower rental rate for continuous enrollments, it is especially important that FSA offer SIPs and PIPs for CCRP practices moving forward. NSAC urges FSA to make them available for future enrollments.
Last week’s announcement provided information for CRP participants who have expiring contracts of 14 years or less. These participants should expect to receive a letter from FSA describing their options, including the option for a one-year extension.
CRP contract holders who think they may be eligible for an extension should reach out to their local FSA office, and be on the lookout for a letter identifying their options. According to FSA data, there are more than 1.6 million acres set to expire at the end of this year, including 500,000 acres of CCRP. There are currently 7.9 million acres enrolled in CCRP.
While FSA has not yet released this year’s letter to expiring contract holders, we can expect that they will be presented with the following options:
NSAC urges FSA to move forward as quickly as possible with additional information for participants with expiring contracts in order to provide as much clarity and time as possible for decisions to be made.
USDA is currently in the process of interpreting the direction provided in the 2018 Farm Bill regarding programs and provisions where additional rules and regulations are needed; they are expected to issue rules later this year. For CRP, the rule is expected to be released later this fall, in advance of a General CRP signup (which is expected by the end of 2019). FSA also announced that there will be a CRP Grasslands signup, but has not provided a specific timeframe.
NSAC will continue to report on additional developments and opportunities for CRP in the weeks and months ahead.