May 6, 2020
The Regional Conservation Partnership Program (RCPP) has helped conserve thousands of acres across the country by promoting partnerships between producers and organizations, with support from the federal government. These partnerships, most often led by non-profit conservation organizations, involve sometimes hundreds of landowners and work to address resource concerns across landscapes and watersheds.
Earlier this year, the Natural Resources Conservation Service (NRCS) released their Interim Final Rule (the rule) on RCPP that details how they expect to implement changes to RCPP put in place by the 2018 Farm Bill since its inception in 2014. While many of the changes made in the rule track nicely with the changes made in the 2018 Farm Bill, here are a few areas of concern that NSAC is planning to raise in its comments on the rule:
Because RCPP’s stated goal is to maximize conservation, it is easy for NRCS to target the program to the largest landowners with existing connections with leading partner organizations. While some good conservation outcomes may come from these arrangements, it is important to include a broad and varied group of farmers and ranchers into these partnerships. Throughout our comments, we are asking that NRCS prioritize outreach to socially disadvantaged farmers and ranchers – especially farmers of color – who have systematically been excluded from many Farm Bill programs historically. Conservation benefits everyone, and we believe that our federal conservation programs should reflect that.
We also believe that the rule should contain guidelines to conduct significant outreach to bring small and midsize farms into the program.
In the Farm Bill, commodity and conservation program participation is denied if a person has adjusted gross (net) income of over $900,000 a year, or double that for most married couples. RCPP is unique in potentially allowing for waivers to that income-based needs test. The RCPP rule states that this limit can be waived if the NRCS Chief considers a project to be of sufficient environmental benefit. However, there is nothing in the rule that indicates what is considered environmentally beneficial, or why extraordinarily wealthy individuals would need such help to begin with. We believe it is important that those criteria are made public.
The 2018 Farm Bill made RCPP its own stand alone program, rather than an amalgam of other farm bill conservation programs. In doing so, however, Congress did not create a separate RCPP contract payment limitation, leaving that decision up to USDA in writing the rule. Unfortunately, USDA failed to supply one, potentially leaving the program, uniquely among all farm bill programs, without a payment limit. We believe this oversight must be corrected in the final version of the rule.
Allowing the super rich to participate, and giving some producers big contracts, necessarily means that there would be less money available for others to participate. Concentrated investments in a few, very costly RCPP projects could lead to fewer important conservation projects throughout the country, which is certainly not what Congress intended when it created this program.
NRCS has listed eight distinct regions as “Critical Conservation Areas” under RCPP. Some of these regions include places like the Chesapeake Bay watershed, the Mississippi River Basin, Prairie Grasslands, and other iconic American landscapes. Under the program, producers and their partners can apply for funding to address specific resource concerns in these Critical Conservation Areas. Each of these areas has unique needs – in some areas applicants can ask for funding to address wildlife needs, water quality needs, or a host of other needs.
Unfortunately, soil quality degradation is listed as a priority resource concern in only one of the eight Critical Conservation Areas: the Colorado River Basin. We are asking NRCS to list soil quality degradation as a priority resource concern in all eight areas. We know that soil health and quality is not only important in one part of the country, but rather it is important everywhere, whether it pertains to soil erosion, organic matter in the soil, or other soil health metrics that we know leads to healthier farms and landscapes.
If you are interested, we encourage you to submit comments on RCPP’s rule to NRCS by 11:59 PM on May 12. Please feel free to include any of the above information in your comments, your own thoughts on the rule, as well as any personal connection you might have to the program.
** Please note this post was updated on 5/6/2020 to correct an error related to payment limits