Sample CSP Comment Form for Organizations

CSP OrganizationThe Conservation Stewardship Program (CSP) needs your help. Read more about the CSP program and why it’s important here and then send in your comments before January 20th, 2015.Below is a Sample Comment form for Organizations along with guided questions and talking points about various issues in order to better help you tell your story.  Feel free to pick and choose between the different issues in order to comment on the ones that are most important to you. When finished, submit your comment online at http://bit.ly/csp15 or by mail. The mailing address can be found at the same link.

Re:  Conservation Stewardship Program Interim Final Rule, NRCS-2014-0008

[Name of organization] appreciates the opportunity to comment on the Conservation Stewardship Program Interim Final Rule.

[Customize your organization’s comment with your story: What is the mission of your organization? Who does your organization serve, and where is it located?  Why is your organization submitting comments on the Conservation Stewardship Program? How has your organization been involved with the program historically?]

The Conservation Stewardship Program (CSP) is a great program, one aimed at the long-term protection and enhancement of the natural resources that form the basis of a productive, sustainable agricultural system.  [Name of organization] is committed to ensuring CSP thrives, and we believe the Natural Resources Conservation Service (NRCS) has missed a great chance to correct some of the shortcomings of the current rule through this new, revised rule.  NRCS has failed to adequately address several significant barriers to participation, including – most importantly – the need to properly recognize and reward farmers who are committed to actively managing and continually improving existing conservation practices and stewardship activities.  [Customize your comment: Include any additional issues you believe form the crux of your organization’s comments, including the need to adequately support smaller-scale, more intensively managed farms, or the need to ensure the program is run responsibly so as many farmers can participate as possible, or both].

We urge NRCS to reevaluate aspects of this rule.  CSP is an invaluable resource for conservation-minded farmers, and with a few critical adjustments, tremendous opportunity exists for the program to reach its goal of addressing natural resource and environmental challenges that face agriculture and the country as a whole.

Specifically, we urge you to consider the suggestions enclosed below.

 [Name of Organization] looks forward to following this rule in the coming months and seeing positive changes made to CSP.  We are confident that with a few key adjustments, NRCS has the opportunity to make CSP—an invaluable program for conservation-minded producers—even better.

Thank you for your consideration of these comments.

Sincerely,

[Name of Organization]

 

1.     Base the ranking and payment rules for the program solely on environmental benefits and outcomes

The purpose of CSP is to address the priority resource concerns of a particular state or watershed by encouraging producers to actively manage and improve their ongoing conservation activities and to add new conservation enhancements.  Yet NRCS consistently and very dramatically overemphasizes the importance of additional conservation activities while failing to adequately recognize and support ongoing activities farmers are undertaking.  This is evident in the weighting of existing and ongoing versus newly adopted conservation measures, both in ranking applications and in determining per-acre payment rates.

This misses the mark, making the program more of a traditional cost-share program rather than the forward-looking stewardship incentives program it was meant to be.  At best, it forces the best stewards to accept lower payments than others, and at worst it keeps some of the best conservationists from accessing the program at all, while rewarding the late adopters of sound conservation systems.  The program should reward environmental benefits and outcomes, of both existing and new conservation activities equally, thereby recognizing the costs to the farmer and benefits to society of both ongoing and newly adopted conservation measures.

[Help NRCS understand why this matters:

Do/did any of your organization’s members participate in CSP, or try to participate? What conservation practices and activities did they already undertake before enrolling in the program?  What level of work and effort and expense does it require to actively manage their existing conservation activities?  If they applied but didn’t get in, do you know of other farmers that do less conservation than they do, but got in?  Why does your organization think it’s important to equalize treatment of ongoing and new conservation activities?]

Recommendation to NRCS:  NRCS should level the playing field so that CSP rewards environmental benefits and outcomes by equalizing the treatment of farmers who actively manage and improve ongoing conservation activities and farmers who adopt new conservation enhancements throughout both the CSP ranking and CSP payment structure.  Differences in ranking and payments should reflect nothing other than actual or expected differences in environmental benefits, financial costs, and forgone income to the farmer

 2.     Improve access for beginning & small-acreage farmers, including farmers growing fruits and vegetables and other high value crops

Our agricultural system includes a wide range of farmers and farming operations.  To truly encourage conservation across the agricultural landscape, CSP must be accessible to farmers of any experience level and farms of any scale.  The average age of the American farmer continues to climb, reaching 58.3 years old in the 2012 Census of Agriculture.  The next generation of American producers will need ample resources to establish themselves as good stewards of the land and effective conservationists.  In supporting their investments in advanced conservation, the public also receives a big payoff in the form of many decades worth of environmental benefits.

The program attempts to promote beginning farmer enrollment by setting aside 5 percent of CSP acres specifically for beginning farmers, and another 5 percent for socially disadvantaged farmers.  NRCS has met and slightly exceeded the set-aside.  This is a great start, but NRCS should “aim high” by setting its own higher enrollment goal for beginning farmers.  Given that beginning farmers currently make up over 17 percent of farms and 25 percent of farmers (according to the Census of Agriculture), it seems both reasonable and fair for NRCS to set a goal to have that same percentage of CSP acres going to beginning farmer contracts.

[Help NRCS understand why this matters:  Are you a beginning farmer or do you work with beginning farmers?  Tell your story (or their story) about getting started in farming and conservation.  What challenges do beginning farmers face?  How can CSP help beginning farmers address those challenges?]

CSP must not only be more accessible to beginning farmers but also to small acreage farming operations.  Almost 65 percent of U.S. farms are between 1 and 179 acres in size, with one-third of U.S. farms ranging between 1 and 49 acres, according to the 2012 Census of Agriculture.  Small acreage farms account for a significant portion of agricultural land and, as such, have tremendous potential to address resource concerns through CSP.  In addition, small-scale farmers tend to crop their land more intensively, which on the one hand entails greater risks of soil erosion, groundwater contamination and other resource concerns, but on the other hand makes it more feasible for the producer to adopt the highest level conservation measures such as intensive cover cropping and high level IPM, with correspondingly greater per-acre benefits.

Currently, the CSP minimum annual contract payment sits at $1,000 for historically underserved producers, with no minimum for other producers.  Given the time it takes for a farmer to go through the application and contracting process, payments below $1,000 offer little if any incentive to participate in the program.  More needs to be done to increase the programs attractiveness and accessibility to smaller-acreage producers and truly incorporate agricultural operations across all scales.  CSP payments are determined by multiplying payment rates by the number of acres.  Therefore, in most cases, small acreage farms lack the acreage for CSP to pay off, even if they’re doing more intensive and advanced conservation on those acres.  By increasing the minimum contract payment and making all successful applicants eligible, NRCS has a chance to make sure small acreage farmers can cost-effectively implement conservation practices through CSP.

[Help NRCS understand why this matters: Do you work with beginning farmers, historically underserved constituencies, and/or smaller acreage farmers? Would they be inclined to implement more conservation practices if they were more cost-effective?  Have they considered CSP but decided against it because it didn’t seem worth it?

Do you work with specialty crop or organic farmers? Does CSP work for them, and how could it be improved to better meet their specific needs? ]

Recommendation to NRCS: NRCS should make CSP more accessible to beginning and small-acreage farmers.  Specifically, NRCS should:

A. Set a goal of at least 15 percent of all CSP acres to be enrolled by beginning farmers;

B.  Raise the minimum payment level from $1,000 to $1,500 to ensure the program is cost-effective for smaller-acreage farming operations; and

C. Extend the new, $1,500 minimum payment level to all successful applicants to ensure that all farmers can benefit from the program.

3.     Ensure fiscal responsibility and efficiency

Farmers routinely have to find the best ways to work efficiently and get the most bang for their buck — and we expect NRCS to do the same when it comes to conservation.  Financial resources must be used wisely so as many farmers who are interested in CSP as possible have an opportunity to participate.  Allowing some farmers to accumulate excessively large payments through the CSP program drains the program’s resources and ultimately limits participation for other good stewards of the land.

By statute, CSP contracts are limited to $40,000 per fiscal year and $200,000 from fiscal year 2014 through 2018.  But the rule continues to allow for the doubling of the statutory limit for joint operations.  Worse, the rule neglects to require that beneficiaries be active farmers, and allows farms to have multiple contracts despite the statutory stipulation that the entire farm must be enrolled in the CSP contract.  Combined, these loopholes allow some farms to rack up very large contracts, far in excess of the statutory limit.   In order to ensure that CSP has sufficient funding to support many prospective conservationists, these payment limit loopholes must be closed.

[Help NRCS understand why this matters:

Why is your organization concerned about closing payment limit loopholes?  How will holding all CSP farms to the $200,000 payment limit impact farmers in your area?  Are you concerned that the reduction in available acres from 12.8 to 10 million nationally it will be harder to get a contract?  Does you think the reduction in acreage makes it even more important to ensure that conservation dollars go to family farmers and true conservationists, not passive investors or absentee general partners?  Does USDA’s general practice of creating loopholes to get around the intent of Congress in establishing payment limits offend your sense of fairness and fiscal responsibility?]

Closing the payment limit loophole is one way to improve the efficiency of CSP; another is to raise the standard of stewardship.  In order to be eligible for a CSP contract, applicants must meet or exceed a stewardship threshold for at least two priority resource concerns.  Having such a standard in place is incredibly valuable, but the current definition of stewardship threshold is vague.  The preamble to the rule outlines more specific language, stating that “NRCS guides its efforts to set stewardship thresholds at sustainable levels for natural resource treatment,” but such language is nowhere in the rule itself.  By using this preamble language to clarify the stewardship threshold definition, NRCS will be taking a step to ensure that CSP recognizes the best stewards of the land.

[Help NRCS understand why this matters:

Why is it important to your organization that CSP have high standards for stewardship?]

Recommendation to NRCS: NRCS needs to run CSP in an efficient and fiscally responsible manner.  Specifically NRCS should:

C. Close the loopholes that allow the largest farms to exceed the payment limits established by Congress.  Include a requirement that beneficiaries be actively engaged in the farming operation.  This will conserve financial resources to allow more farmers to participate in CSP.

BClarify and enhance the definition of stewardship threshold by using language from the preamble in the rule itself, ensuring that the stewardship thresholds used in CSP will be set at the sustainable use levels (also sometimes referred to as the non-degradation level or resource management system level), thereby ensuring that CSP has high standards to encourage more conservation and recognize the best stewards of the land.

4.     Create a more transparent and accessible program

Historically, NRCS has utilized a Conservation Measurement Tool (CMT) to determine eligibility for the program by ranking applications and verifying that producers met stewardship thresholds.  The CMT also is used to calculate payment points.  The new farm bill removes earlier references to conservation measurement tools and hence the rule removes all mention of the CMT, though NRCS is quick to add that this does not prohibit the agency from using the tool.  We concur.  NRCS should continue to use the CMT, but make it more transparent and accessible.

The most successful programs require adaptive capacity to integrate evolving science and technology, and CSP is no different.  Following this logic, the nominal removal of CMT from the rule may make sense, as it gives NRCS more freedom to incorporate newer, more effective conservation tools and models in the future.  However, we also believe the CMT is a valuable resource and can be improved with greater transparency and accessibility.

The CMT is used to determine CSP eligibility, ranking, and payments, yet presently, farmers cannot use the tool as a learning device, cannot test different conservation scenarios, and can obtain only limited explanation of how the CMT and the choices therein impact one’s ranking score and payment points.

An online, real-time CMT could alleviate these challenges for prospective CSP applicants as they conduct farm assessments or submit applications.  Affording farmers the opportunity to run through various conservation scenarios, understand the subsequent environmental benefits, and view their respective ranking scores will motivate producers to develop an optimal conservation plan.  Furthermore, a farmer-accessible, online CMT would not only provide greater clarity and attract prospective CSP applicants, but it also has the potential to reduce the administrative burden on the agency, as farmers can develop informed decisions before meeting with NRCS staff.

[Help NRCS understand why this matters:

Describe any experience you have in working with the Conservation Measurement Tool or in hearing from farmer members about their experience.  Was the process confusing?  Were you able to view multiple conservation scenarios?  Were the environmental benefits clear?  How would making the CMT more accessible and user-friendly improve CSP for your organizations, or for farmers in general?]

Recommendation to NRCS: Provide greater transparency around the Conservation Measurement Tool to make it more user-friendly and informative for producers. Specifically:

C. Develop a user-friendly, online CMT that allows farmers to test out different conservation scenarios and view their ranking score.

B. More clearly communicate the environmental benefits and the environmental benefit points associated with each conservation activity in the CMT so farmers can make informed decisions throughout the conservation planning process.

5.     Offer appropriate supplemental payments for particularly valuable conservation systems

Resource-Conserving Crop Rotations (RCCRs) are among the most effective systems for addressing resources concerns, and we applaud NRCS for wasting no time implementing 2014 Farm Bill language providing supplemental payments for producers who adopt or improve such systems.  Incorporating this language is a step in the right direction toward recognizing farmers leading the way in conservation by improving existing RCCRs.

Unfortunately, NRCS took a significant step backwards by lowering supplemental payment rates from $18 to $12 per acre.  Even the best stewards of the land must ensure that conservation activities remain financially feasible in order to be sustainable.  In the face of continuously soaring cropland values and rental rates, not to mention USDA commodity programs that pay significantly more per acre to encourage environmentally-destructive monoculture, the agency’s decision to reduce supplemental payment rates for RCCRs is inappropriate, as the newer rate fails to accurately reflect the value of RCCRs and the costs and forgone income incurred by farmers diversifying their rotations with the addition of resource-conserving crops.

[Help NRCS understand why this matters:

Does your organization work with farmers implementing RCCRs?  If yes, how do supplemental payments help?  Do you think increasing the supplemental payment rate would make RCCRs more appealing and more widely adopted?  More broadly, why is it important that conservation program payments keep up with cropland values and other economic realities that farmers face?]

Recommendation to NRCS: Provide an appropriate supplemental payment rate for farmers implementing Resource-Conserving Crop Rotations (RCCRs).  Specifically, in order to ensure that RCCRs remain attractive to producers, increase the supplemental payment rate for this valuable conservation system from $12 to $20 per acre to better reflect the economic realities producers face, including high cropland values and rental rates and continuing commodity subsidies that work strongly against the adoption of RCCRs.

6.     Keep conservation on the landscape by promoting CSP to other conservation program enrollees

The 2014 Farm Bill CRP-to-CSP transition provision allows CRP holders in the final year of their contract to enroll in CSP, making the transition more seamless and ensuring continuous conservation on the landscape.  NRCS should coordinate with the Farm Service Agency (FSA) to promote CSP to farmers with expiring CRP contracts to bring sensitive land back into production in an appropriate manner, through grassland farming and ranching options and sustainable cropland options.

NRCS has recognized the value of continuing conservation on retired CRP acres, evidenced by the ranking boost and elevated environmental benefit scores provided to activities done on expiring CRP land.  But when it comes to outreach directed at CRP landowners with expiring contracts, NRCS and FSA have fallen short.  We encourage NRCS to work with FSA to distribute a letter to all CRP participants with expiring CRP contracts informing them of the opportunity to enroll in CSP.  This letter should explain CSP in general and also explain the CRP to CSP transition process and the various options afforded by the new farm bill and enhancements offered within CSP for CRP coming back into production.  It should be sent to CRP landowners more than a year in advance of their contract end date so they have ample time to learn about the program and consider their options.

In addition, NRCS should be active in reaching out to CRP landowners and the beginning farmers they are working with as part of the CRP-Transition Incentive Program (CRP-TIP).  In order to maximize conservation values under CRP-TIP, beginning and socially disadvantaged farmers that gain access to land via this program should be encouraged to keep the eligible land in conservation.  These can be excellent ways for beginning farmers to get started or expand their operations while receiving support for advanced conservation.

CRP-TIP requires the new farmers or ranchers to develop and implement a conservation plan.  An option that will be available through CSP beginning in 2015 will allow for CSP payments to offset the time and management costs of developing a comprehensive conservation plan.  This will be a particularly good option for beginning farmers leasing or buying land through CRP-TIP as it is already a requirement of CRP-TIP participation.  NRCS should work with FSA to contact all CRP landowners well in advance of the final year of their CRP contracts to alert them to CRP-TIP and the requirement in CRP-TIP for the new operators – beginning or socially disadvantaged farmers and ranchers – to be enrolled in CSP as they begin their new ventures.

[Help NRCS understand why this matters:

Has your organization worked with farmers transitioning from CRP to CSP?  Do you know of any farmers who let their CRP contract expire and never heard about CSP?  Why is it important that NRCS make a strong effort to keep conservation continuing through CSP once CRP contracts expire?

Do you work with beginning farmers and CRP-TIP?  What would be the value of a beginning farmer getting a CSP contract as they transition that CRP land back into production?  What more can be done to help those beginning farmers learn about the option to enroll in CSP in connection with their participation in CRP-TIP?]

Recommendation to NRCS: Ensure continuous conservation by improving outreach to landowners with expiring CRP contracts.  Specifically:

A. Collaborate with the Farm Service Agency (FSA) to distribute letters to landowners with expiring CRP contracts, at least a year in advance of the CRP contract end date, informing them of the opportunity to enroll in CSP.

B. Collaborate with FSA to contact CRP landowners to inform them about CRP-TIP and the CRP to CSP transition for CRP-TIP participants, and also ensure that beginning farmers participating in CRP-TIP are aware of the option to and benefits of enrolling in CSP.

7.     Improve CSP’s ability to help farmers and ranchers mitigate and adapt to climate change.

NRCS is perfectly poised to take steps to support climate change adaptation and mitigation in the agriculture sector through CSP implementation.  CSP provides the opportunity both to enhance support for those practices and systems with the greatest adaptation and mitigation potential, and to encourage the transition away from those with negative climate effects and less ability to cope with the pressure imposed by increasingly extreme and unpredictable weather events.

CSP takes a systems approach to resource conservation and management, supporting those low input and biologically diverse agricultural systems, including certified organic agriculture, that play an important role in addressing climate change.  In addition to their ability to reduce GHG emissions and sequester carbon, these complex systems produce numerous co-benefits that will help farmers build resilient and viable systems of production.  Among these efforts, conservation practices can build soil organic matter to increase the soil water holding capacity and carbon storage ability and decrease the need for scarce water resources.

As one example, organic matter build-up can occur in well-managed grazing systems.  CSP Enhancement (PLT02) helps to monitor key grazing areas to improve management that results in better vegetation and soil conditions, improved water quality, and enhanced wildlife habitat.  Ranchers should be encouraged to use this enhancement for its climate benefits because it helps the operator use beneficial soil and plant practices instead of destructive ones.

As another example, CSP includes enhancements to support the use of legumes and organic inputs, like compost and manure, for nitrogen, as well as other conservation practices that reduce the use of synthetic nitrogen and improve management of unstable organic nitrogen.  These include specifically two enhancements, ENR10 (Using N provided by legumes, animal manure, and compost) and ENR12 (Use of legume cover crops as N source).  Applications containing these practices should be ranked, scored, and advertised to farmers for their climate co-benefits.

[Help NRCS understand why this matters:

What are the climate stressors that farmers and ranchers in your region face?  How can CSP help support these producers both adapt to these stressors, and reduce their climate impact?]

Recommendation to NRCS: NRCS should take advantage of the opportunity to make significant changes to the program through the CSP rulemaking process that enhance CSP’s ability to support the President’s climate agenda, and our nation’s farmers and ranchers.  Specifically, NRCS should:

A. Take greenhouse gas emission reduction and carbon sequestration increases into greater account in the CSP ranking and payment points system.

B. Incorporate on-farm energy audits into the new CSP comprehensive conservation planning activity and payment;  and

C. Develop climate change mitigation and adaption related “bundles” that bring together multiple practices that increase carbon sequestration, reduce overall greenhouse gas emissions, and improve resilience to a changing climate.  Such bundles can be developed for crop, pasture, and rangeland systems, focusing on soil, water, and livestock management practices that in combination offer some of the best approaches to reducing emissions and enhancing resilience.  To make bundles more attractive and rewarding, increased environmental benefits scores are needed as well as greater outreach and education about the bundle options and their associated benefits.

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