9/4/04

Dear Land Stewardship Project member,

Public Comments on proposed USDA rules for CSP due by October 5, 2004 – Please read on!

Background:
We are at another critical point in the national grassroots effort to win the Conservation Security Program.

The good news is that USDA has finally implemented CSP, after 18 months of delay. As of the end of August, 2,188 farmers have been accepted into the program, in 18 watersheds that were selected around the U.S. by USDA.

Also good news is last week’s action by the U.S. Senate Appropriations Committee, which fully funded CSP, in contrast to the efforts by the Bush Administration and the U.S. House to slash funding.

The bad news is that USDA’s implementation of CSP falls far short of what CSP is meant to be, in the law passed by Congress. The Administration inexcusably delayed implementation of this program for 18 months, and then made it available to farmers in only 18 small watersheds across the country. For us to really get a federal conservation program that rewards farmers based on how well they are protecting and improving the environment, we need to keep pushing, and hard.

USDA's rules for program implementation and operation are simply not for the same Conservation Security Program as passed by Congress. They are much too restrictive, drastically reducing the number of farmers who would be able to use the program by requiring that a farmer needs to farm in a "selected watershed" in order to be eligible. The USDA’s rules also severely gut all payment mechanisms to farmers for conservation results. Furthermore, the rules only allow farmers who are lucky enough to farm in one of USDA’s “selected watersheds” to sign up every eight years, instead of the open access program passed by Congress. The remedy: USDA must issue an improved final rule, that is designed to implement a fully funded, nationwide, continuous sign-up Conservation Security Program as passed by Congress. Properly implemented, CSP will deliver literally billions of much needed dollars to family farms over the next ten years for environmental stewardship. It will literally help change the landscape, motivating and rewarding real environmental benefits – like clean water, healthy soil, and increased wildlife habitat – that farmers can deliver, instead of just rewarding maximum production of a handful of heavily subsidized commodity crops, like corn, soybeans, wheat, cotton, and rice. That’s why CSP has been a top priority of the Land Stewardship Project since we helped to form the idea for the CSP in 1999. Thanks to all of you who have called, e-mailed, faxed, talked, worked to make this happen!

How can you make CSP the program it was meant to be.

Right now the Natural Resources Conservation Service (NRCS) of the USDA is taking written comments from the public on how their “Interim Final Rule” for the CSP should be improved. We need as many people as possible to send in comments to the USDA. Below is a list of seven issues LSP has flagged with the Interim Final Rule. Read through the points and expand or add you own personal comments (we are encouraging folks to personalize your comments), and then send it off to: Financial Assistance Program Assistance Division, Natural Resources Conservation Service, P.O. Box 2890, Washington, DC 20013-2890. OR you may submit comments by e-mail to FarmBillRules@usda.gov with Attn: Conservation Security Program on the subject line. For those e-mailing, using a “cut and paste” of the message below, and adding any comments of your own into the email text, will save time.

SAMPLE COMMENT on CSP RULES – Due to USDA by October 5, 2004

Dear Natural Resources Conservation Service,

The Conservation Security Program (CSP) passed in the 2002 Farm Bill is a significant shift in our nation’s approach to enhancing and protecting our environment and natural resources. A program established for working farmland and working farmers, CSP should recognize and reward actual conservation benefits produced by farmers and ranchers, which in turn also provides incentives for farmers and ranchers to address and solve critical resource problems.

Regrettably, significant changes are needed to the Interim Final Rule in order for CSP to make a major positive impact towards excellent conservation on working farmlands across America. Improvements NRCS should make to the Interim Final Rule include:

1. CSP should be nationwide, without geographical restrictions. Participation in CSP should not be limited to particular watersheds. Remove the restrictions that now limits enrollment to only a few watersheds and certain categories of farmers and ranchers.

2. Implement CSP on a continuous sign-up schedule, so that farmers don’t have to wait 8 years to apply for CSP if they didn’t get in the first time. UDSA’s 8-year cycle for sign-up is actually counterproductive to providing incentives for farmers and ranchers to do conservation on their land and achieve enrollment in the program. A continuous sign-up would stimulate conservation and stewardship on working farmland and allow CSP payments to function as powerful incentives to farmers to meet the environmental standards outlined in the quality criteria. It is necessary for fulfilling the purpose and the promise of CSP.

3. Reward farmers for continuing conservation on their land. Eliminate the newly implemented regulatory cap or “per acre” limitation to contracts. This cap discriminates against farmers on smaller acreages who are doing highly effective conservation management and favors large operators who can get higher overall payments for doing less on more acres.

4. Increase the base payment rates to levels outlined in the 2002 farm bill. The “stewardship payments” being offered by NRCS do not reward existing conservation adequately, and fail to provide enough of an incentive for further improvements in stewardship and enrollment in the program.

5. Expand enhancement payments to include the full range of options in the law, including resource conserving crop rotations, rotational grazing, organic farming, conservation and regeneration of plant and animal germplasm, native prairie restoration, and recognition of farmers with limited or no use of pesticides and commercial fertilizer. Continue enhancement payments for on-farm/ranch research and demonstration activities and for on-farm/ranch assessment and evaluation activities.

6. Restore the 15% additional cost share for beginning farmers and ranchers to the cost-share payment rate for new practices.

7. Continue to recognize “pastured-cropland” as a land use that is classified in and receives the same payment rates as Cropland. This was a good change made by the NRCS in responding to comments on the initial proposed rule for CSP.

The CSP can provide farmers and ranchers with meaningful incentives and rewards to protect the nation’s extremely valuable, natural resources. Please make the changes outlined above for the good of our nation’s farmlands and farm communities.

Sincerely,