Help Shape the Conservation Stewardship Program
Send in Your Comments by October 28, 2009
Organic farmers have an important opportunity to help shape the implementation of the new Conservation Stewardship Program (CSP), the nation’s first and only "green payments" program for agricultural producers. CSP pays farmers for improving soil, water and air quality, reducing greenhouse gases and protecting wildlife habitat and biodiversity.
USDA has requested comments on the rules governing the implementation of this important new program. While the rules are positive overall, organic farmers still need to provide input to ensure that the new CSP recognizes and rewards the multiple environmental benefits of organic agriculture. Below are talking points on how CSP can be improved. Scroll down for instructions on how to submit comments, as well as background on each of the talking points, and additional information.
Talking Points
1. Organic crop and livestock systems should be recognized for their positive impacts on natural resources, including water, air, and soil quality.
2. Since many organic farms are also small acreage farms, a minimum contract payment should be added to the program to encourage participation of small acreage farms.
3. Resource-conserving crop rotations and management-intensive rotational grazing, two conservation practices organic farmers frequently use, should receive high ranking and payment points.
4. Farmers and ranchers applying to participate in CSP should be ranked and paid based on actual environmental outcomes, as opposed to just the practices employed.
5. The CSP payment limits should be retained and enforced.
(Scroll down for more information related to each of these talking points.)
How to Submit Comments
Below are instructions for submitting comments. Include “Re: Docket Number NRCS-IFR-09004 CSP” at the top of your fax or in the subject line of your email.
Email to: CSP2008@wdc.usda.gov
Fax to: (202) 720-4265
Online instructions:
You can submit comments using the Federal Government's online form for this comment period.
Read the related Federal Register Notice for the text of the CSP rules.
Time is running out to send in your comments -- please forward this email on to other farmers you know.
And let us know if you submit comments. Email Tracy Lerman, OFRF Policy Organizer: tracy@ofrf.org.
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Background on Talking Points
1. Organic crop and livestock systems should be recognized for their positive impacts on natural resources, including water, air, and soil quality. As part of the Food, Conservation and Energy Act, also known as the 2008 Farm Bill, Congress required USDA to make a special effort to reach organic farmers through CSP, in recognition of the elevated resource and environmental benefits that can accrue from organic systems.
The regulations and overall design of the program should specifically include organic conservation activities as well as ensuring that all conservation activities rewarded under the program include appropriate variations relevant to organic farms where the standard conservation practice may be inappropriate for organic systems. Ranking and payment point values should be roughly equivalent for ongoing organic management and new conversions or transition to organic.
2. Since many organic farms are also small acreage farms, a minimum contract payment should be added to the program to encourage participation of small acreage farms. The proposed rule contains maximum payment rates per farm, but not minimum payment rates. As a result, many farms of 50 acres and less, which includes a lot of organic farms, will be less likely to participate since their maximum payments may not be large enough to justify the time and expense of meeting the program requirements. A minimum payment could make it worthwhile for such farms to participate and thus bring about a greater degree of equity with respect to types of agriculture that operate on fewer acres.
The final rule should include a minimum annual payment rate of $1,500 to encourage small acreage farms to participate.
3. Resource-conserving crop rotations and management-intensive rotational grazing (two conservation practices organic farmers frequently use) should receive high ranking and payment points. Agricultural systems built around resource-conserving crop rotations and cover cropping and livestock systems based on rotational grazing are superior conservation approaches with multiple environmental benefits. In fact, the 2008 Farm Bill provides for supplemental CSP payments to farmers newly adopting or improving existing resource-conserving crop rotations.
Because of these benefits and because of the Farm Bill language, both resource-conserving crop rotations and management-intensive rotational grazing systems should receive high ranking and payment points and both should be fully rewarded whether they are an ongoing conservation system or a newly adopted one. The definition for resource-conserving crop rotations should specifically require a perennial grass, legume, or legume-grass mixture for use as a forage, seed for planting, or green manure to be part of the rotation. Rotations that include only crops eligible for Farm Bill commodity subsidies should not qualify as resource-conserving.
4. Farmers and ranchers applying to participate in CSP should be ranked and paid based on actual environmental outcomes, as opposed to just the practices employed. USDA has posed a specific question for comment: Should the program give greater weight to applications proposing new conservation practices? Or should the environmental outcomes of a farmer’s application be given greater weight?
The Environmental Quality Incentives Program (EQIP) and other conservation programs pay farmers for adopting new conservation practices. The CSP, however, is unique among working lands conservation programs. The CSP rewards farmers who are already farming at a high stewardship threshold (i.e. farmers whose operations demonstrate strong environmental benefits) and provides an incentive to maintain those standards.
If a farmer has previously adopted advanced conservation measures and systems, the program is designed to reward that behavior and help pay for continued active management and maintenance of those systems and practices. Many organic farmers already farm at a high stewardship level and would benefit if CSP rewarded existing practices and environmental outcomes. USDA should also require farmers to adopt new practices, and reward them for doing so. But CSP ranking and payments should be keyed to environmental outcomes and not the adoption of conservation activities.
CSP design and regulation should equally balance the benefits of both existing and new practices with the primary measure being the environmental benefits secured by the total conservation system regardless of the timing of adoption of various parts of the system. This is essential to making CSP a program that recognizes and rewards the multiple benefits of sustainable and organic farming systems.
5. The CSP payment limits should be retained and enforced. The proposed rule includes a $40,000 per year and $200,000 over five-year contract limit per farm. There is also a per person or legal entity limit to prohibit creating multiple farms to receive multiple payments. This is a fair payment limit system and one that reflects congressional intent to target payments to small and moderate sized farms and to control costs. The large majority of organic farms are small and moderate sized. The CSP payment limitation, however, has come under attack by some in the agricultural community who oppose targeting farms of a particular size and support benefits that increase proportionally to the size of the operation without enforceable limitations.
The payment limit should be maintained and then vigorously enforced. The final rule should retain both the per farm and per contract payment limitations contained in the proposed rule. The USDA should resist pleas to incorporate payment limitation loopholes.
Additional Background on CSP
The Conservation Stewardship Program (CSP) is a comprehensive working lands conservation program designed to protect and improve natural resources and the environment for generations to come. CSP provides 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 priority resource concerns in a given state, watershed or region
• 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. Priority resource concerns will still be set by watershed, but all watersheds will be eligible each and every year. CSP contracts run for five years and there is a $40,000 per year payment limitation.
Applicants will complete a Conservation Measurement Tool which will allow them to assess their current conservation activities and choose additional conservation activities they would like to implement. Periodically during the year, USDA’s Natural Resources Conservation Service (NRCS), the agency that administers CSP, will rank applications, selecting those with the highest rankings until funding all for that ranking period is allocated. Participants, working with NRCS, will then develop conservation plans and CSP contracts.
The new farm bill provides sufficient funding for the program to enroll 12.8 million acres each year. Acres are allocated to each state based primarily on the amount of farmland in that state relative to the national total.
For more information, visit OFRF's CSP Resource Page.
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