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Comment Now to Help Bolster the Conservation Stewardship Program
The Conservation Stewardship Program is something that Practical Farmers of Iowa has supported since the program began. CSP is widely popular with farmers; it’s grown to over 60 million acres in the US with 1.8 million acres in Iowa. The program is designed to help farmers maintain and improve existing conservation practices and adopt additional management. Participants are selected through a competitive process and earn payments for conservation performance – the higher the performance, the higher the payment (or at least that was the original intent, keep reading).
Following the most recent Farm Bill—however—new rules are making it harder for good stewards to access the program and receive support for the highest-impact environmental practices on their farms. The NRCS is now seeking public input on the “interim rule” until January 20.
Practical Farmers of Iowa hopes to use our institutional knowledge of CSP and the experiences of our members to help bring positive changes to the program. We are confident that with a few key adjustments, NRCS has the opportunity to make CSP—an invaluable program—even better.
So, how do we do that? 2 ways. Working with the PFI policy committee and the keen program analysis from our friends at the National Sustainable Agriculture Coalition we are writing an organizational comment for submission to NRCS. Second, and likely more influential, we are encouraging farmers with experience in CSP (successful or not) to provide comments.
For the organizational comments, we are focusing on two points that we feel will be most useful for the wide diversity of farm types in our membership.
Base the ranking and payment for the program on environmental benefits and outcomes.
The new CSP ruling significantly overemphasizes the importance of adding new practices while failing to recognize and support enduring conservation activities on a farm. For example, farmers like PFI members John Gilbert or Ron Rosmann—using 5-7 year rotations including small grains and forage, creating wetlands and windbreaks, and integrating production of crops and livestock—rank lower and receive lower payments than a farmer simply trying no-till on corn and beans for the first time. We applaud stewards both new and veteran, but we suggest that differences in CSP ranking and payments should reflect nothing other than differences in environmental benefits, costs, and forgone income to the farmer. We ask that NRCS reward farmers already at a high level of conservation with well deserved payment levels; this will inspire those farmers to do even more conservation on top of the high levels they are already doing. For those farmers interested in bringing single conservation practices into their system, EQIP is an effective (and better funded) support program.
Improve access for beginning & small-acreage farmers, including farmers growing fruits and vegetables.
CSP payments are determined by multiplying payment rates by the number of acres. In many cases, this means small acreage farms lack the acreage for CSP to pay off, even if they’re doing more intensive and advanced conservation than much larger farms enrolled in CSP. Consider the average CSP payment is $18 per acre – a farmer with 1500 no-till row crop acres has a lot more incentive to apply ($27,000) than a 15 acre vegetable and livestock operation ($270). To help overcome this we are asking that minimum payments be established and that all successful applicants eligible for the minimum payment of $1500 or more.
So how can you help? Any farmer or friend-of-farmers interested in the Conservation Stewardship Program can submit a comment. My two points mentioned above are only examples of how the program could be adapted to better serve stewards – don’t limit your thoughts to these alone. The NSAC blog is a great place for more information. They also have comment templates to help get you started.
Comments need to be submitted by January 20. They can be submitted online here. OR via snail mail to:
Public Comments Processing
Attn: Docket No. NRCS-2014-0008
Regulatory and Agency Policy Team
Strategic Planning and Accountability
U.S. Department of Agriculture, Natural Resources Conservation Service
5601 Sunnyside Avenue
Building 1-1112D
Beltsville, MD 20705