In February, we submitted comments to the U.S. Department of Agriculture in response to "2018 Farm Bill Implementation Listening Session," Federal Register notice 84 FR 4041, published on February 14, 2019. Below is the text we submitted.
The 2018 farm bill contains several important changes for the U.S. Department of Agriculture (USDA) programs administered by the Farm Service Agency (FSA), the Risk Management Agency (RMA), and the Natural Resources Conservation Service (NRCS), and we thank Secretary Bill Northey for providing this opportunity to provide public comment on these changes. The below represents comments on farm bill implementation from the Center for Rural Affairs, but we hope that these comments are the beginning of a conversation with USDA about the 2018 farm bill rather than the end.
The Center for Rural Affairs is rooted in and advocates for healthy, vibrant rural communities, and we know the strength that diverse economic opportunity can provide to rural communities. Specifically, we have seen the important role that strong conservation and access to diverse markets can play for farmers and ranchers. We are pleased to have the opportunity to comment on implementation of the 2018 farm bill and the ways in which it can foster this opportunity for family farmers and ranchers. We begin with a few general comments, followed by responses to the questions specifically outlined by USDA.
We consulted several supporters and staff to draft these responses, and in addition to the specific feedback about particular programs below, we also heard the repeated message that soil health must remain a priority for USDA. Healthy soil allows for greater resiliency to extreme weather and improves both water quality and retention, and can help reduce input costs. But the practices that build soil health—such as planting cover crops, implementing resource-conserving crop rotations, or intensively managed rotational grazing—require farmer and rancher investments of time and funds. USDA conservation programs offer a crucial piece in that puzzle, and we urge all USDA officials to prioritize soil health as you proceed with implementing the 2018 farm bill.
We also urge you to start the sign up periods for conservation programs, particularly the Conservation Stewardship Program, as soon as possible so that farmers and ranchers can incorporate their support into their plans for the coming year. Also, as you move forward with the 2019 sign up for the Conservation Stewardship Program, we ask you to please incorporate the clear changes from the farm bill for increased payments for cover crops and resource conserving crop rotations prior to the release of an interim rule for the 2020 sign up.
Below are our responses to several of the questions posed in Federal Register Notice titled “2018 Farm Bill Implementation Listening Session,” as well as select general comments for each of the agencies. These comments have been drafted with input from several of the supporters and staff of the Center for Rural Affairs; we are deeply grateful for their input.
Farm Service Agency
1. Specific ideas to simplify program implementation and enhance customer service.
Several of the staff at the Center for Rural Affairs work directly with beginning, Latino, and veteran farmers. Often, they have found that these farmers hold full-time jobs and have difficulty getting the time off needed to visit FSA or NRCS field offices during business hours. This can effectively exclude them from accessing FSA and NRCS programs. We urge you to institute a more flexible schedule for field offices in order to better serve more diverse farmer and rancher populations. This comment is repeated under the similar question for NRCS program delivery.
Our staff have also done extensive work with women landowners, and have found that many of them would like to work with their tenants to enhance conservation on their land. We encourage FSA and NRCS, in your administration of conservation programs, to conduct outreach to women landowners on conservation programs.
4. The 2018 farm bill requires better coordination between FSA and NRCS regarding Conservation Reserve Program, Environmental Quality Incentive Program, and Conservation Stewardship Program. How can we better coordinate the programs?
Working lands conservation is an essential element for healthy rural communities. These practices allow farmers and ranchers to both raise crops and livestock on their land and implement conservation practices that provide a number of private and public benefits. Farmers and ranchers can benefit from improved conservation through the cost savings that long-term conservation can afford. The public benefits from cleaner water, increased habitat for wildlife, and similar impacts.
The Environmental Quality Incentive Program, the Conservation Stewardship Program, and Continuous Conservation Reserve Program are all examples of USDA’s support for working lands conservation. There are several ways that improved coordination between the programs would improve their impacts.
With the increased acreage for the Conservation Reserve Program under the 2018 farm bill, we encourage USDA to open the 2019 Continuous Conservation Reserve Program sign-up, and to speedily implement the Clean Lakes and Estuaries provisions, which emphasize enrollment in Conservation Reserve Program of marginal land and devoting it to prairie strips, riparian buffers, saturated buffers, and other water quality practices.
We also encourage USDA to increase its outreach to landowners with expiring and soon-to-expire Conservation Reserve Program contracts, to inform them of the options and benefits of enrolling in the Conservation Stewardship Program, the Environmental Quality Incentive Program, or the Conservation Reserve Program-Transition Incentive Program. This outreach could look like sending an official letter both one year in advance of a Conservation Reserve Program contract expiring and the customary few months before expiration. Further recommendations for Conservation Reserve Program-Transition Incentive Program are below.
Finally, the Conservation Stewardship Program is a flagship program for both rewarding high levels of conservation and providing farmers and ranchers with a path to further improve conservation on their farms and ranches. Environmental Quality Incentive Program offers a valuable pathway for farmers and ranchers to be introduced to conservation opportunities. We encourage USDA to provide ongoing training to NRCS staff on the distinct roles of these programs and to encourage farmers and ranchers to transition from the Environmental Quality Incentive Program to the Conservation Stewardship Program.
5. The 2018 farm bill provides a new Conservation Reserve Program pilot, the Soil Health and Income Protection Pilot Program. What can we do to most effectively implement this pilot? Specifically, what does the public recommend for perennial conserving use cover?
One of the most powerful tools in the Midwest for not only maintaining but also improving soil health is intensively managed rotational grazing. When done properly, the system is a win-win: soil thrives for long-term sustainability, and livestock thrive for profit potential. This Conservation Reserve Program pilot should include a strong focus on encouraging and supporting this hands-on management strategy of rotational grazing of land planted in diverse perennials that both builds healthy soil and supports livestock. To track the impact of the pilot, we also encourage the pilot to support voluntary soil testing and tracking of changes in soil health. Finally, given the limited funding available, we encourage USDA to focus efforts within this pilot on beginning farmer applicants.
General comments - Conservation Reserve Program - Transition Incentive Program (CRP-TIP)
While this is not a topic where USDA has requested specific input, we would like to turn readers’ attention to our recommendations for improving the CRP-TIP program, which are publicly posted at the below link and are summarized as follows.
The CRP-TIP program, at its core, relies on the building and maintaining of a strong working relationship between the landowner and the new farmer or rancher. The first step for fostering successful working relationships is for the landowner and new farmer or rancher to identify each other. USDA can both facilitate these introductions and generally raise awareness about the program in several ways:
- Identify organizations within each state who maintain networks of beginning, socially disadvantaged, and veteran farmers and ranchers. USDA-FSA state offices can work with these organizations to get the word out to these farmers and ranchers about CRP-TIP.
- Identify organizations and resources that can offer landowners support on the land transition process. Share such information with field staff and CRP contract holders.
- Through USDA’s Beginning Farmer and Rancher coordinators, develop state-level strategies for improving outreach and education about CRP-TIP and facilitate matches.
- Send formal notification to landowners with expiring CRP contracts. Notification about the CRP-TIP option should happen two years in advance of the contract expiring, to give landowners enough time to find and build relationships with an interested farmer or rancher and enter into a rental or sale agreement with them.
- Improve communication and outreach with landowners who rely on third parties to manage CRP contracts.
- Ensure county staff receive updates about CRP-TIP at least annually, and that they remain familiar with eligibility and sustainability requirements.
- Improve internal communication about CRP-TIP by standardizing the county office reporting process for CRP-TIP enrollment, and by sharing progress on TIP participation on a statewide basis to ensure that every office is aware of current funding availability.
- Release an annual report on CRP-TIP participation by state/county.
Risk Management Agency
2. Specific examples of how cover crop use has affected insurability or a claim determination. If so, what adjustments to the Cover Crop Termination Guidelines should RMA consider?
The Center for Rural Affairs is glad to see that the 2018 farm bill includes provisions that bring cover crops into RMA’s Good Farming Practices. No farmer should be concerned that their crop insurance will be in jeopardy if they plant cover crops, and this new provision provides this important assurance going forward.
We ask RMA to now amend Good Farming Practices to include and allow for all NRCS conservation practices and enhancements, without any additional restrictions. Just as farmers deserve the certainty that their crop insurance coverage is safe as they plant cover crops, they also deserve the certainty that participation in NRCS conservation programs presents zero threat to their insurance coverage. We ask you to incorporate these changes immediately.
3. Specific ideas to reduce paperwork and reporting requirements for Whole Farm Revenue Protection while ensuring program integrity.
The Whole Farm Revenue Protection pilot program offers a valuable pathway for farmers to insure crops and thereby manage risk by diversifying their production. We have a few specific recommendations for improving Whole Farm Revenue Protection administration.
We are glad that the 2018 farm bill includes a provision to institute a process to collect stakeholder input on Whole Farm Revenue Protection, and we look forward to participating in this process. We offer that one way to reduce the paperwork burden with Whole Farm Revenue Protection is to eliminate the requirement of collecting and reporting expense information. Finally, we recommend that RMA make easily available guidance for how to enroll in Whole Farm Revenue Protection under a crop share arrangement.
Additional comments for RMA
The Center for Rural Affairs was very glad to see that the 2018 farm bill includes Section 12618 regarding collection of information on conservation data. Conservation practices and activities have enormous potential to reduce risk for farmers and ranchers, and the agriculture sector is long overdue to acknowledge, study, and codify the impact that conservation practices have on risk. We ask you to carry out this provision with attention, care, and alacrity, and that the efforts and final report emphasize the goal of aligning conservation and insurance policy.
Natural Resources Conservation Service (NRCS)
1. Specific ideas to simplify program implementation and enhance customer service.
Several of the staff at the Center for Rural Affairs work directly with beginning, Latino, and veteran farmers. Often, they have found that these farmers hold full-time jobs and have difficulty getting the time off needed to visit FSA or NRCS field offices during business hours. This can effectively exclude them from accessing FSA and NRCS programs. We urge you to institute a more flexible schedule for field offices in order to better serve more diverse farmer and rancher populations. This comment is repeated under the similar question for FSA program delivery.
On a related note, our supporters have also shared with us that NRCS field offices often struggle with high workloads for the staff they have. We encourage NRCS to conduct internal reviews to assess workloads of field staff, and make this information public.
We would also like to share a few general comments. On-farm conservation and risk-management strategies need to be outcomes-based, and work best for farmers and ranchers when they are not reliant on boilerplate solutions that may not be either applicable or affordable in different locations or on differing operations. We ask NRCS to build and strengthen your human resources capacity so that technical staff have more flexibility to work closely with producers to develop conservation plans and projects geared to the goals and capabilities of the operator while still achieving the desired conservation outcomes. We also encourage NRCS management to help field staff balance workloads in order to get out of the office more and share their incredible expertise at outreach events and activities.
Our supporters have shared with us that in their experience, NRCS often exhibits a mindset of building a fix for a conservation problem (such as building terraces, waterways, or filter strips) rather than addressing the underlying causes of erosion and degradation caused by management practices. We encourage NRCS management incorporate this more flexible approach into their planning and training activities.
3. Mechanisms to improve the targeting of financial resources to address resource concerns.
One of the main barriers that NRCS faces in targeting financial resources to address resource concerns is that NRCS does not conduct evaluation of the conservation impacts of practices in any significant way. Standing up pilot projects that allow for this evaluation will provide data that would be incredibly useful in helping NRCS to target their activities.
We also encourage NRCS to increase their collaboration with Extension researchers to enhance the research focus and program implementation of each agency.
4. The 2018 farm bill introduced a new incentive contract enrollment option for the Environmental Quality Incentive Program that provides for practice installment and annual payments. How should the Environmental Quality Incentive Program and the Conservation Stewardship Program be used in conjunction with each other to prevent overlap and improve opportunities for producers to address resource concerns?
The Center for Rural Affairs has been a long-time advocate for working lands conservation programs that allow farmers and ranchers to enhance conservation on their operations while still maintaining production. The Conservation Stewardship Program provides an invaluable avenue for farmers and ranchers who are already committed to conservation practices to improve and increase their conservation efforts to address targeted resource concerns across their whole operation. In contrast, the Environmental Quality Incentive Program offers farmers and ranchers the ability to take on or install conservation practices on a case-by-case basis, and does not include a consideration of the resource concerns and opportunities of the whole operation.
The Environmental Quality Incentive Program is a valuable tool for farmers and ranchers to assist them in increasing their conservation activities on their operations, and ultimately help them become eligible for Conservation Stewardship Program. In this “on-ramp” scenario, incentive contracts under the Environmental Quality Incentive Program can provide a valuable stepping stone to help producers reach the eligibility threshold for the Conservation Stewardship Program. We ask NRCS to set up smooth processes to allow farmers and ranchers to move from Environmental Quality Incentive Program to Conservation Stewardship Program contracts.
In implementing the new incentive contracts under the Environmental Quality Incentive Program, we also encourage NRCS to work to ensure that these are implemented with producers’ future participation in the Conservation Stewardship Program in mind. This should include coordination of sign-up periods, timelines, and outreach. We also encourage NRCS to allow for a no-penalty early termination of an Environmental Quality Incentive Program incentive contract if a farmer or rancher wishes to transition to the Conservation Stewardship Program and is eligible to do so.
Finally, we encourage NRCS to promote management practices through the incentive contracts. In contrast to contracts that support structural improvements, contracts that support management practices provide a safety net for farmers and ranchers to climb the conservation practice learning curve, which they might not otherwise have the flexibility to do. Incentive contracts that support management practices will provide a path for more farmers and ranchers to incorporate conservation management practices on their operations long-term.
6. Both the Conservation Stewardship Program and the Environmental Quality Incentive Program have provisions for organic producers. How should the programs be used to maximize service to producers while avoiding overlap and competition between the Conservation Stewardship Program and the Environmental Quality Incentive Program?
We have a few general comments to offer to improve NRCS program delivery to organic producers. First, we encourage ongoing education to NRCS field staff about the scope of organic production and the number of certified organic producers in their state. We also encourage NRCS to consider the unique approaches to conservation that the Environmental Quality Incentive Program and the Conservation Stewardship Program offer—i.e. the comprehensive nature of the Conservation Stewardship Program and the targeted practices of the Environmental Quality Incentive Program—and ensure that each program extends these services to organic producers. Finally, we encourage NRCS field staff, when setting up Conservation Stewardship Program and Environmental Quality Incentive Program contracts with organic producers, to consider the particulars of a producers’ existing organic management plan. For example, often organic management plans are designed to preclude the need for fertilizer application, and instead build fertility through crop rotation and residue management. In these cases, Environmental Quality Incentive Program and Conservation Stewardship Program contracts for organic producers that address fertilizer management should account for the particulars of the producers' organic fertility management plans.
Other NRCS topics
The Center for Rural Affairs has many supporters who are farmers devoted to enhancing conservation on their operations. These farmers have shared with us time and again that they are concerned that the NRCS process to conduct spot checks on producers who manage Highly Erodible Land and wetlands is ineffective. Many farmers and ranchers violate the terms of their required conservation plans and mistreat these sensitive areas, and the threat of the NRCS spot check is not an adequate deterrent. However, neighbors are very reluctant to turn in neighbors who are violating plans. We ask USDA to take action to improve their administration of spot checks in order to create a more effective deterrent for mistreatment of sensitive lands.
Specifically, we ask USDA to speedily address the recommendations in the USDA-OIG report 50601-0005-31 in order to standardize the spot check procedures and counts across state boundaries. We ask that USDA take particular care to ensure that the spot check rate of 5 percent be implemented by state, rather than nationally. We also ask USDA to increase their outreach about the purpose and importance of the spot check process, and to assign spot check responsibilities in a county to NRCS staff who do not personally reside in that area.
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