1/5/04
The good news is, thanks to pressure from Land Stewardship Project members and people like you from across the nation, the Bush Administration has now officially posted the draft rules for how they plan to run the Conservation Security Program (CSP). The proposed rules were posted on Friday, Jan. 2, at the Federal Register.

We are now in the midst of a 60-day public comment period, which ends March 2. The purpose of the comment period is to allow public input into how the CSP should be run. That’s good, because the bad news is that there are some big problems with the way the Bush Administration and USDA are planning to implement the CSP.

LSP’s Federal Farm Policy Committee is reviewing the proposed rules, and will be communicating with all LSP members soon about the rules and the kind of written comments that would be helpful. We will provide the e-mail address where comments can be sent, and an outline or sample comment letter. We are also interested in hearing from LSP members about your reaction to the rules, and any suggestions for comments you might have.

Briefly, here are a couple of the problems we’ve already identified (just to get you thinking):

1. CSP, by law, is to be implemented nationwide and made available for all farmers. The USDA’s proposed rule unnecessarily limits the benefits of CSP to a very small number of farmers who live within certain watersheds and also meet other, as yet unspecified, criteria. Such implementation as proposed by USDA is contrary to Congressional intent and the word and spirit of the law.

2. Management intensive grazing (rotational grazing) and resource-conserving crop rotations are both mentioned explicitly in the law passed by Congress as farming practices/systems that should qualify for “enhanced” CSP payments because of the excellent conservation and environmental protection they deliver. There is absolutely no recognition of these practices in the proposed USDA rules. That needs to be fixed.

If you want to look at the USDA’s draft rule yourself, go to the Federal Register at http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2004/pdf/03-31916.pdf and download the 32-page pdf document. We will be analyzing the proposed rules more as we move forward. Right now, though, it is clear USDA needs to issue what’s called a “supplemental rule” to fix the problems they created by trying to make CSP such a small and narrow program.

So, look for an action alert from LSP soon about sending in written comments. If you have any questions or ideas about CSP, give us a call at 612-722-6377, or e-mail marks@landstewardshipproject.org.