OFAN Alert - April 8, 2009

Many of you have already submitted comments urging USDA to reward organic farmers for the conservation benefits of their farming systems – if you have not done so, please submit your comments to USDA by April 17, 2009. Talking points, instructions on how to submit comments, and background info are below.

Also, USDA has asked for public input on how EQIP can help reduce the impacts of global warming. This is your opportunity to let USDA know the many ways organic farming mitigates global warming – see the talking points below and please include personal examples from your farm if applicable.

Talking Points

The EQIP Rule should acknowledge organic agriculture as a new National Priority for the Environmental Quality Incentives Program (EQIP). The Chief of NRCS should issue a Directive to all State Conservationists reinforcing this change.

The EQIP Rule should clarify that the $80,000 cap (over six years) for Organic Conversion Support contracts does not apply to every organic producer seeking an EQIP contract. The regular cap of $300,000 should apply for organic operations applying to EQIP for other (i.e. non-conversion) contracts.

The EQIP Rule should ensure that Organic Conversion Support is available in all 50 states.

The EQIP Rule should ensure that Organic Conversion Support applications are ranked and processed as a separate subcategory.

The EQIP rule should recognize and reward the ways in which organic agriculture can conserve energy, reduce carbon emissions, facilitate climate change adaptation and mitigate global warming: it sequesters more carbon than conventional agriculture, it emits fewer greenhouse gasses than conventional farming, it produces higher yields during droughts than conventional systems, and it is more adaptable to changing climates than conventional systems.

How to Submit Comments

Include “Docket Number NRCS– IFR–08005” at the top of your correspondence or in the subject line of your email.

Mail to:
Financial Assistance Programs Division
U.S. Department of Agriculture
Natural Resources Conservation Service
1400 Independence Avenue, SW.
Room 5237S
Washington, DC 20250-2890.

3. On the next screen, click on “Send a Comment or Submission” and follow the instructions on the next screen. Be sure to scroll all the way down to the bottom of the page, underneath "Action" to the button that says "Next Step" to proceed.

4. On the next screen, you will have an opportunity to review your submission. Once you have done that, scroll all the way down to the bottom of the page, and click "submit" to send in your comment. You can also edit or print your comment.

Background

The Environmental Quality Incentives Program is a conservation program administered by the USDA Natural Resource Conservation Service (NRCS). EQIP provides financial and technical assistance to farmers to implement practices on their farm that conserve natural resources and promote environmental quality. In the 2008 Farm Bill, Congress directs NRCS to change EQIP so that it recognizes and rewards the conservation benefits of organic farming systems. Specifically, the Farm Bill includes supporting conservation practices related to organic production as one of three new purposes of EQIP. Additionally, the Farm Bill through EQIP mandates financial and technical assistance for growers converting to organic farming systems.

NRCS released their Interim Final Rule on January 16, 2009. Because it is an Interim Final Rule it went into effect immediately, but the public has until April 17, 2009 to submit comments to NRCS on the Rule. Comments on the Interim Final Rule must be considered prior to promulgation of the Final Rule.

NRCS later added a request for public input on how EQIP can further the Nation’s efforts to increase renewable energy production, conserve energy, mitigate the effects of climate change, facilitate climate change adaptation, and reduce net carbon emissions. Comments for this request are also due on April 17, 2009.

It is crucial that farmers submit comments to NRCS on the EQIP Rule. NRCS fell far short of fulfilling Congress’ intent to recognize the conservation benefits of organic agriculture. Additionally, organic agriculture will be instrumental in mitigating the impacts of climate change and reducing carbon emissions, and NRCS should promote and reward organic practices through EQIP in order to meet the Nation’s goals of global warming reduction, carbon sequestration, energy conservation, and climate change adaptability.

1. The rule does not adequately implement the language in section 2501(a)(4) of the 2008 Farm Bill to make supporting conservation practices related to organic production a new purpose for EQIP. The rule should acknowledge this purpose by making organic production a National Priority for EQIP and the Chief of NRCS should issue a Directive to all State Conservationists reinforcing this change.

2. The rule appears to limit all organic operators applying for any type of EQIP contract to an $80,000 payment cap. The legislative history overwhelmingly shows that the special $20,000 per year/$80,000 over six years limit is intended to apply to organic conversion assistance, in which new fields or herds are transitioning to organic production, not to existing organic producers on existing organic acres seeking basic EQIP assistance. The rule seems to apply the lower limitation to all organic producers, an interpretation that is simply not justified by the legislative history. An immediate clarification will help ensure there is no confusion on this point at the state and local implementation level.

The Final Rule should clarify that the regular cap of $300,000 applies to organic operators who are not seeking conversion support. Furthermore, the Final Rule should ensure that applications from organic operations could be recognized as providing “extraordinary conservation benefits” and thus eligible for a waiver of the $300,000 limit.

3.The rule does not require the new EQIP provision providing assistance for organic conversion be available to growers in all fifty states. The Final Rule should mandate that Organic Conversion Support is offered in every state.

4. There is no language in the rule that requires the ranking and processing of Organic Conversion Support applications as a separate subcategory. Applications for Organic Conversion Support should be ranked only against one another. Establishing this separate subcategory will increase the likelihood that farmers converting to organic systems will actually receive assistance.

5. EQIP should recognize the ways that organic agriculture can mitigate global warming: it sequesters more carbon than conventional agriculture, it emits fewer greenhouse gasses than conventional farming, and it produces higher yields during droughts than conventional systems. Additionally, organic systems are more adaptable to changing climates than conventional systems. By promoting and rewarding organic practices, EQIP can further the Nation’s efforts to conserve energy, reduce carbon emissions, facilitate climate change adaptation and mitigate the effects of climate change.

Talking Points

How to Submit Comments

Background

More Information