National Farmers Union urged USDA's Natural Resources Conservation Service to strengthen the Conservation Stewardship Program to better help farmers improve conservation practices on their operations in comments submitted on the interim rule. The comment period closed Jan. 13, 2020.
“Given the high demand for and considerable value of CSP, it is especially important that every single dollar set aside for the program in the farm bill be used prudently and in full," said NFU President Roger Johnson. "There are a number of ways to get more environmental bang for the program’s buck. For one, the application process should not penalize long-term stewardship by prioritizing applicants who have not previously engaged in best practices over those who have. Instead, contracts should be awarded based on overall environmental benefits provided."
Additionally, NFU calls for the CSP to benefit all size operations and those who are actively farming. USDA should enforce a $200,000 payment limit, Johnson said, and prohibit payments to cash-rent landlords.
"Finally, CSP should give greater consideration to soil health," Johnson said. "Healthy soil is the foundation of a healthy farm: not only does it boost crop yields, but it also mitigates climate change by storing carbon and helps farmers adapt by building resilience to extreme weather events."
In total, 110 comments were received. Here's a sampling of the comments from regulations.gov.
- From the National Young Farmers Coalition: ". . . We urge you to increase the actual minimum payment rate from $1,500 to $2,000 for FY 2020 and beyond. According to NASS, a majority of beginning farmers’ operations, specialty crop farms, and organic farms are under 100 acres. Although these farms provide many benefits, including sustaining the next generation of farmers, the acre-based payment formulas of CSP put them at a disadvantage and make this program less attainable."
- From Arizona Farm Bureau Federation: "We support the Natural Resource Conservation Services proposed expansion of the definition of eligible lands to include public lands that are associated with private or tribal agricultural lands. We agree with NRCS’s interpretation that associated lands should allow producers to enroll public land components of their overall operation if such lands are managed as part of the of their overall operation. . . . Furthermore, including public land in CSP contracts would be particularly helpful in Arizona where most working ranches are made up of a patch work of private and public land. The expanded definition of eligible lands affords producers the ability to adopt CSP practices in a holistic manner that addresses conservation on all the land they operate regardless of ownership classification."
- From the Center for Rural Affairs: "While we are concerned about how funding decreases will impact participation in CSP, we are glad to see several of the changes to the program, including new emphasis on soil health and advanced grazing management, expanded practices within bundles, and administrative flexibility to increase payments mid-contract."
- From Western Landowners Alliance: "WLA is concerned with the requirement that CSP contract renewals compete with new contract applications. We encourage the NRCS to recognize existing conservation efforts and, when ranking applications and calculating payments, do not penalize applicants that have a legacy of conservation and wish to sustain and build upon those efforts through the CSP. If new conservation activities are ranked higher than maintenance of existing conservation activities it is likely there will be fewer contract renewals – a failure to recognize the importance of ongoing conservation. WLA is concerned that this change, coupled with reduced funding, will result in decreased opportunities for landowners to implement long-term conservation and loss of conservation efforts that may not work financially without CSP financial support."