USDA Needs Your Comments
on the Conservation Security Program!

February 1, 2004

Sample Letter:

David McKay
Conservation Operations
NRCS
P.O. Box 2890
Washington, DC 20013-2890

Dear Mr. McKay:

Thank you for the opportunity to comment on NRCS’s proposed rule for the Conservation Security Program (69 FR 194). The Conservation Security Program is an exciting opportunity to reward farmers and ranchers who engage in stewardship to protect our natural resources. It was intended to be an entitlement program whose purpose is to "reward the best and motivate the rest," and Congress and the President reaffirmed its status as an uncapped entitlement program with the recently-passed omnibus appropriations bill. Unfortunately, the NRCS rule, released before passage of the appropriations bill, administers the CSP as a capped program with limited funding. If administered as proposed, the program will be open to very few producers, will not address the full range of natural resource concerns, will fall short of rewarding those who are engaged in stewardship, and fails to provide adequate incentives to encourage people to enroll. I respectfully ask that you make the following changes to the Proposed Rule in order to make CSP truly "reward the best and motivate the rest":

The rule as currently drafted proposes to limit CSP enrollments to priority watersheds chosen by the NRCS based on "conservation and environmental quality concerns" at discreet signup periods. This process would unfairly exclude good stewards whose agricultural operations aren’t located in the chosen watersheds. It could also have the somewhat paradoxical effect of favoring actors within the worst watersheds, instead of those whose actions have demonstrably improved natural resource conditions. Furthermore, the NRCS proposes to sort producers into "enrollment categories and subcategories." These terms are vague and undefined in the proposed rule; they should be clarified or removed. With the removal of the funding cap, these restrictions have been rendered superfluous. The final rule should restore CSP to its status as a nationwide program available to all producers in all areas of the country, as provided for in the 2002 Farm Bill. In addition, producers should have the opportunity to enroll in CSP on a continuous sign-up basis; or at the very least, signups should be available on a predictable annual basis, avoiding the planting and growing seasons when farmers are too busy to apply.

NRCS is proposing that all CSP applicants address soil quality and water quality in order to enroll in Tier I or Tier II, and requires that participants address all of the Quality Criteria under these resource concerns before entering the program. There are two problems with this proposal: 1) It sets the entry point higher than the law, which says that relevant conservation standards must be met as a result of participation in the CSP, not as a condition for entry. While high environmental standards are very important, the rule as drafted could require producers to have up to two dozen different practices in place before being eligible for the program. 2) By requiring enrollees to address soil quality and water quality as resources of national concern, the program eliminates from consideration for Tier I or II those producers who are addressing or wish to address other resources of concern, such as air, plants and animals. Therefore, the only producers who would be rewarded for their efforts to protect wildlife habitat and biodiversity would be those willing to enroll in Tier III and address all resource concerns on their entire operation. This unfairly excludes good stewards of native wildlife and habitats. The final rule should allow farmers to achieve the minimum level of treatment as a result of their participation in the program, and should give producers enrolling at Tier I and Tier II the opportunity to choose to address two resources of concern from a suite of options (e.g., soil, water, air, plants, animals and energy).

The proposed rule adopts very low rates for base payments, cost share and enhancement payments. The proposed rule states that "NRCS assumes that producers would enroll in CSP if the program provided any positive net benefit to them (i.e. even as small as $1)" and the payment system seems to have been designed accordingly. This assumption is far from the meaningful incentives and financial rewards envisioned by the law, and goes beyond even the requirements for economy imposed by the once-capped program. The NRCS should redesign the payment program commensurate with the CSP’s status as an uncapped entitlement program:

Thank you for your attention to my comments on the Conservation Security Program. I hope the NRCS will quickly move forward to revise the rule to provide meaningful incentives to good stewards across the country.

Sincerely,

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