The US Department of Agriculture’s Natural Resources Conservation Service (NRCS) recently published the new rule for the Conservation Stewardship Program. The rule goes into effect immediately, allowing the agency to move forward with program sign-up. Meanwhile it's still open for public comment.
Farmers, ranchers, and other stakeholders should take this opportunity to provide feedback to the agency on how best to roll out the Conservation Stewardship Program. The due date for public comments is January 5, 2015. After reviewing the public comments, the agency will publish their final rule.
We are working closely with our friends and allies at the National Sustainable Agriculture Coalition to analyze the rule, and we've identified some key issues.
Let's start with the good news:
- Resource-Conserving Crop Rotations: The agency’s rule will allow supplemental payments for farmers who improve their resource-conservation crop rotation. Previously, the agency only provided supplemental payments to farmers who adopted these rotations for the first time. The 2014 Farm Bill addressed this issue, and we are pleased to see NRCS adopted this within the rule.
Areas of the rule that need improvement include:
- New vs. Existing Conservation: NRCS continues to put more weight behind adopting additional or new conservation practices versus simply focusing on environmental outcomes. The farm bill is clear on this issue. It provides a level playing field for both adopting new conservation practices and maintaining existing practices and systems. This puts the best stewards at a competitive disadvantage. It provides greater financial reward to those who only adopt additional practices because they are being paid to do so.
- Minimum Contract Payment: While the rule continues the minimum contract payment for underserved farmers, it fails to make this available for all small farmers who provide top-notch conservation.
- Payment Limitation Loopholes: The rule failed to correct a provision from the old rule that allows farms organized as general partnerships to double their Conservation Stewardship Program payments, and only one partner is required to be actively farming.
- Beginning Farmers: The rule needs to do much more to ensure beginning farmers are able to use the program effectively. It should also mention beginning farmers gaining access to land through the Conservation Reserve Program Transition Incentive (CRP TIP). Under this program, beginning farmers receive priority access to the Conservation Stewardshup Program when bringing that land back into production.
- Comprehensive Conservation Planning: According to the National Sustainable Agriculture Coalition, the rule does not provide information on NRCS’ thinking on creating a supplemental payment for comprehensive conservation plans, despite farm bill language that clarified that NRCS can and should offer payments for such plans. They believe the planning payment will be added starting in 2015, though would have preferred it to be explained in the rule to provide opportunity for public comment.
Stay tuned for more information on the Conservation Stewardship Program rule and how you can submit comments. Watch your inbox for action alerts, talking points, and more information.
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