July 8, 2015
The Conservation Stewardship Program (CSP) is a comprehensive working lands conservation program designed to help farmers and ranchers protect and improve natural resources on productive, profitable land. It is one of the farm bill’s two large working lands conservation programs, alongside the Environmental Quality Incentives Program. EQIP provides one-time practice-based assistance, whereas CSP provides ongoing performance-based support.
Administered by the U.S. Department of Agriculture (USDA)’s 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 on land in agricultural production.
The National Sustainable Agriculture Coalition (NSAC) has continuously advocated that CSP needs to be more transparent, more accessible, more farmer-friendly, and more appropriately reward environmental benefits.
We are optimistic that many of these concerns may soon be addressed, as NRCS is undertaking a major program “refresh” to be implemented beginning in 2016. This refresh presents an enormous and unique opportunity to address critical CSP concerns.
This is happening outside of the usual farm bill reauthorization and rulemaking processes, so is a bit of uncharted waters. To date, no stakeholder input process has been established.
Conservation Measurement Tool
A major change driving the “refresh” is the elimination of the Conservation Measurement Tool (CMT).
Since 2009, the CMT has been the computer-based evaluation tool used to determine ranking and payments for CSP. It scores existing and new conservation activities according to their projected environmental benefits, and then calculated payments based on those expected outcomes. The CMT is still being used in the 2015 enrollment process that is still ongoing, but the NRCS plan is to retire it for 2016 and beyond.
The 2014 Farm Bill removed the requirement that NRCS use one or more measurement tools to estimate environmental benefits of proposals submitted by farmers. NSAC did not support the elimination of this provision, though we have been quite critical of aspects of the CMT that NRCS came up with to implement the farm bill provision. We trust that, even without the farm bill mandate to base the program on measures of conservation performance and environmental benefits, the agency will still do that.
While some improvements have been made to the CMT over the past few years, applicants still lack access to the information necessary to understand the relative conservation outcomes of available conservation activities. Any new ranking system, in our view, must provide access to these details, because the more informed an applicant can be about the ranking and scoring processes, the higher their level of achieved stewardship will be.
Ideally, the removal of the CMT gives NRCS more freedom to incorporate newer, more effective conservation assessment tools and models in the future.
A Completely New and Simplified CSP?
While NRCS is still in the process of determining exactly how they will rank applications and assign points in the new CSP, NSAC believes that this new CSP must simplify the overall program structure and application process, while simultaneously strengthening the linkage between environmental benefits and program payments.
In the past, the CSP application process has been challenging not only for applicants but also for NRCS field staff. We are pleased to hear that the new CSP will simplify the program for applicants and NRCS staff while also making it more transparent, and we look forward to learning the details of these streamlining efforts.
One key criterion we will use to assess the emerging NRCS plan will be if the newly retooled program is based solely on conservation and environmental benefits and outcomes. To do this, the program must reward active management of advanced conservation systems and the adoption of additional conservation enhancements on an equal footing, rather than artificially giving more weight to new activities. If NRCS realizes this goal, then CSP payments will reflect actual or expected differences in environmental benefits plus costs and forgone income to the farmer, and nothing else. There is no program choice more fundamental or critical than this one.
Another indicator of an improved program will be the inclusion of a comprehensive conservation planning component, to assist farmers with a total farm conservation plan that can be advanced through CSP participation.
Reassessing Conservation Enhancements
An additional area of opportunity presented by the refresh is a closer linkage between the conservation enhancement choices available to applicants and the priority resource concerns CSP works to address.
As we understand it, the refresh process will include a review of all existing enhancements, in order to ensure that they are science-based and allow farmers and ranchers to achieve their desired stewardship goals.
We hope this review provides an opportunity for NRCS to drop certain enhancements that don’t appropriately support stewardship, and increase support for others, particularly for producers managing cover cropping, highly diversified crop rotations or managed rotational grazing, as well as those supporting or transitioning to organic production systems or advanced high level IPM.
NSAC will continue to provide feedback to NRCS on these key enhancements for CSP.
Who Gets to Play?
Another area of opportunity during the refresh is what steps the agency will take to make the program more inclusive of new and beginning farmers, specialty crop farmers, organic farmers, and farmers with relatively small acreage. This has been an area of great concern during the 2009-2015 CSP era. Some positive steps have been taken, but there is still a very long way to go to create fairness for farmers who do not have large acreages of the major commodity crops. As the refresh takes place, it is essential that NRCS make the program fair and accessible to all of agriculture.
How to Support the New CSP
The details of this major CSP overhaul are still very much in process, and there is a great deal we still do not know, but NSAC will continue to engage with NRCS over the course of the next few months. We will also provide information on opportunities to reach out to your local and state NRCS offices, ensuring that they are well aware of existing concerns and opportunities to improve CSP.
Given that CSP is the nation’s largest working lands conservation program, with over 60 million acres of productive land currently enrolled, this refresh provides a critical opportunity to ensure that the program truly works for the stewardship leaders it was initially designed to support. We are cautiously optimistic it will achieve that result.