My name is Dan French. I am a grass-based dairy farmer from Dodge Center, Minnesota, and a member of the Land Stewardship Project’s Federal Farm Policy Committee.

Five years ago, I joined other family farmers in an effort to “get ahead of the curve” on farm policy, to change the focus from always trying to make bad farm policy less bad, to drafting and passing good farm policy – good for people, rural communities, and the land. We need a farm policy based on rewarding positive outcomes, a policy that will help shift farming through the creativity of farmers towards more environmentally sound and sustainable systems. Such a policy would reward stewardship, instead of the maximum production of a handful of commodity crops.

In 1999, I went to Washington, D.C., with 13 other farmers on a trip organized by the Land Stewardship Project and the Sustainable Agriculture Coalition. In three days, we held 36 Hill visits about this kind of program, met with Senator Harkin among many others, and kept pushing until 5 months later Harkin introduced the Conservation Security Act, with a lot of our ideas in his bill. Congress saw fit to pass the CSP in the Farm Bill – which we saw as a big step forward.

In the CSP legislation, Congress provided for a comprehensive, nationwide entitlement program available to all farmers and ranchers who practice effective conservation.

Unfortunately, we are here today because USDA’s proposed rule for CSP is not at all consistent with the law passed by Congress, nor with the full, uncapped funding recently allocated by Congress. USDA should have immediately released a revised proposed rule on January 22nd, the day Congress passed full funding for CSP to start on October 1, 2004. Not to have done so is wrong – bad policy, and bad performance.

USDA should issue an interim final rule or a revised proposed rule as soon as possible, which is consistent with the law and full funding for CSP. The public needs to be given at least 30 days to comment on the revisions, to make sure the rule is based on what the program will be like starting on October 1, 2004, with nationwide, uncapped funding for CSP.

MOST IMPORTANTLY, the FINAL RULE for a nationwide, uncapped CSP must be issued by the Administration BY THE END OF AUGUST, so farmers like me and the others here today can complete the 2004 growing season knowing what CSP will be like and make fall decisions accordingly, with good planning and foresight. USDA must not continue its alarming pattern of delay upon delay. Remember, the final rule for the CSP was, by law, to be issued a full year ago, by February 2003. We’re here to say to USDA – no more delays, and no more excuses. Get the final rule for an uncapped, national CSP out to us by the end of August.

Properly implemented, the CSP has the potential to make a big difference for family farms and the environment. Here are some things to fix in USDA’s proposed rules:

• USDA must adhere to the law, and the recently appropriated full funding for CSP by Congress, and make CSP available nationwide to all farmers practicing effective conservation. The Administration needs to get rid of the idea of restricting sign-up for CSP to a few selected watersheds and undefined “categories.”

• Make payments based on positive environmental outcomes, including those results being delivered currently by existing stewardship farming practices, and make the amounts of those payments worthwhile. One way to do this is to get rid of the 90% reduction of the CSP base payments that are proposed by USDA; another way is to affix a value to the benefits delivered by exceptional conservation performance, and establish the enhanced payments based on that value – not on partial reimbursement of expenses. CSP should not primarily be a cost-share program, but an outcome-based stewardship incentives program.

• Specifically include and emphasize managed rotational grazing and resource-conserving crop rotations in the enhanced payments. These are excellent, proven, conservation-producing farming systems. Enhanced payments for them should be provided by CSP, for the benefits they produce and as an incentive for others to transition to these systems.

• I’m a dairy farmer and a grazier. USDA’s proposed rules penalize me for my environmentally beneficial farming system by paying me less per acre for cropland I use for grazing than if I were row-cropping it. That needs to go. Instead of rewarding conservation and stewardship, the USDA proposes to penalize rotational graziers despite the proven environmental benefits managed grazing delivers. The way to fix this is to establish CSP base payments based on NRCS land capability classes, not current land use. Land that can be cropped that is instead pastured and put into a managed rotational grazing system must receive equal base payment rates to other cropland, and not the lower rate of pastureland.

Thank you.

Dan French
Dairy farmer, Dodge Center, Minnesota
Land Stewardship Project Federal Farm Policy Committee