Update Conservation Practice Standards pertaining to livestock management

On April 24, 2019, we submitted comments on the U.S. Department of Agriculture Natural Resources Conservation Service Practice Standards, Docket ID NRCS-2019-0003, via Regulations.gov. This is a copy of those comments.

The Center for Rural Affairs believes that strength and resilience is rooted in rural communities with diverse economic opportunities. Farmers and ranchers with diversified operations and strong environmental stewardship are an essential element of strong rural communities. Over many years of advocacy on conservation, the Center for Rural Affairs has seen the value that the Natural Resources Conservation Service (NRCS) working lands conservation programs of the Conservation Stewardship Program (CSP) and the Environmental Quality Incentives Program (EQIP) deliver to producers who wish to continue production while improving stewardship of their land. We appreciate this opportunity to comment on NRCS Practice Standards in Docket NRCS-2019-0003 and, in doing so, support NRCS in strengthening delivery of these programs.

We focus the majority of our comments here on practices that address livestock operations. The 2018 farm bill requires NRCS to lower the set aside of EQIP funds targeted for livestock to 50 percent. NRCS is also required to include new emphasis on support for grazing management practices in their distribution of these funds. Updating Conservation Practice Standards pertaining to livestock management is one important venue by which NRCS can engage in addressing these policy changes, and we offer our comments accordingly.

Specifically, we urge NRCS to place common sense limits on the use of EQIP funds for building new or expanding existing animal waste management facilities in environmentally sensitive regions. We also propose that EQIP place a limit as to the size of an operation which can access these programs based on a maximum number of animal units that an operation manages. These limits will allow NRCS to deliver these practices in a more targeted fashion to smaller, existing facilities and will limit incentives for producers to build more such facilities in areas with impaired watersheds or areas where the amount of animal waste currently produced exceeds the amount that can responsibly be applied to the land.

In turn, in accordance with the 2018 farm bill provisions highlighted above, we also encourage NRCS to promote practices that support pasture based systems, such as Conservation Practice Standard 528 - Prescribed Grazing. We support the National Sustainable Agriculture Coalition’s recommendations on this topic submitted to this and similar past dockets.

Finally, the Center for Rural Affairs is also offering technical comments for Conservation Practice Standard 340, Cover Crops. Section 11107 of the 2018 farm bill requires the Risk Management Agency to treat cover crops as a Good Farming Practice under crop insurance rules. We ask that language in Conservation Practice Standard 340 regarding Cover Crop Termination Guidelines be removed and/or updated accordingly.