CSP Final Rule

National Sustainable Agriculture Coalition

For Immediate Release
June 3, 2010

Contact: Ferd Hoefner
PH: 202-547-5754

Final Rule for Conservation Stewardship Program Released
2010 Sign-Up Applications Extended Until June 25

Washington, D.C. June 3, 2010USDA today released the final rule for the Conservation Stewardship Program (CSP) created by the 2008 Farm Bill.

Earlier, USDA announced that farmers and ranchers wanting to enroll in CSP this year have until June 11 to get applications filed at their local USDA office.  Today, however, they extended the application filing deadline to June 25.

“With just weeks to spare before the application deadline, farmers and ranchers have now been afforded the opportunity to know what the final rules of the program are before making the decision whether to apply or not,” noted Ferd Hoefner, NSAC policy director.  “The bottomline is this is a strong program that producers engaged in advanced land stewardship should seriously consider.”

After filing the simple CSP application form, farmers and ranchers will also need to schedule an appointment to complete the CSP Conservation Management Tool (CMT), a set of questions related to their existing conservation baseline and new improvements they are willing to consider.  The CMT process is expected to last through mid-July, at which point USDA’s Natural Resource Conservation Service (NRCS) will rank all the proposals to determine the best offers for enrollment during this 2010 sign-up.  Field visits and contract signing will occur over the late summer months.

Each year CSP will enroll 12.8 million acres of crop, pasture, range, and private non-industrial forest lands.  By the fall of 2011, the new CSP will have over 38 million acres enrolled, making it at that point larger in scope than the Conservation Reserve Program (CRP).

The final rule makes several important changes to the interim rule that was used for the 2009 sign-up and ranking.  Special CSP payments for the adoption of “resource-conserving crop rotations” will be based on the definition used in the original Conservation Security Program (2004-2008) rather than the more expansive definition used for last year’s sign-up that included rotations consisting only of commodity program crops and did not include forages, perennials, or green manure crops.

Also, in the preamble to the final rule, NRCS has announced its intent to return another feature of the old CSP program.  Cropland that has been converted to grass and is being used as pasture for grazing will now be treated as “pastured cropland” and afforded a higher payment rate that was available in 2009.

“We applaud the decision to return to the original policies with respect to resource-conserving crop rotations and pastured cropland,” said Hoefner.  “These are established concepts and ensure that CSP encourages and appropriately supports more sustainable farming systems.”
While final data on the 2009 CSP sign-up is not yet available from USDA, the preamble to the final rule does note that farmer payments under CSP contracts signed so far are running at about a 63 percent/37percent split between rewards for actively managing and maintaining existing conservation activities and encouraging new, additional conservation activity, respectively.

NRCS explains: “More than 80 percent of the eligible applicants across all land uses were already meeting and frequently exceeding minimum stewardship levels on five of the eight resource concerns. Applicants in the initial CSP ranking period appear to be practicing stewardship at a fairly high level. As a result, one would expect to see conservation performance points earned for existing activities to be higher than performance points earned for additional activities.”

“The emerging information on CSP payments conforms exactly to the Farm Bill’s vision for the program and to common sense,” said Hoefner.  “There have been years of pent up demand for this program since it first became law in 2002.  Now, eight years later, it has had its first full-scale, nationwide sign-up and many of the best stewards have responded and been accepted into the program.  Over time, as the program expands and a wider range of farms become competitive, the ratio will naturally move toward balance.”

In the final rule, however, USDA is announcing its intention to change the payment formula, away from the Farm Bill’s directive for equal treatment for managing, improving, and adopting conservation activities to unequal treatment, with new practice adoption receiving a higher payment rate, beyond the amount justified by environmental outcomes, and ongoing conservation activities receiving a lower payment rate, below the environmental outcome level.

“It is unfortunate the Department has taken it upon itself to rewrite the farm bill and to move away from payments based on natural resource and environmental outcomes,” said Hoefner.  “This is a mistake, but one that can be minimized in actual program delivery by limiting the aberrations in the payment formula.  We intend to press for keeping the focus on outcomes to the maximum extent possible.”

The final rule also includes a new minimum contract payment amount not included in the interim rule.  The intent of the minimum contract payment is to encourage participation in the program by small acreage, high value fruit and vegetable farms who, despite the ability to provide important environmental benefits, might otherwise receive payments so small as to not justify participation.  However, the final rule limits the minimum contract payment to beginning, minority and limited resource farmers only.  If an annual contract payment amount would otherwise be less than $1,000, the final rule allows NRCS to increase the payment rate.

“We are glad to see the minimum contact payment in the final rule, but are very upset it has been limited in scope to just particular types of farmers,” said Hoefner.  “This is unfair to the specialty crop growers, including the increasing number of farms serving the expanding fresh, local market.  The limitation appears to fly in the face of the Administration’s professed interest in expanding this market and we hope they will reconsider.”

The Conservation Stewardship Program (CSP) is a comprehensive working lands conservation program established by the 2008 Farm Bill to provide 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 particular resources of concern in a given watershed, region, or state
•    Assist farmers and ranchers to 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
•    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.  Periodically during the year, NRCS will rank applications and then develop contracts with those farmers and ranchers with the highest rankings until funding for that ranking period is completely allocated.

NSAC plans to update and re-issue its widely-used Farmers Guide to the Conservation Stewardship Program in the near future.

The National Sustainable Agriculture Coalition is a grassroots alliance of farm, rural, and conservation organizations that advocates for federal policy reform supporting the long-term social, economic, and environmental sustainability of agriculture, natural resources, and rural communities.