By Ferd Hoefner, Policy Director of the National Sustainable Agriculture Coalition
CSP’s footprint is enormous - including contract renewals, more than 70 million acres of working farm and ranch lands are enrolled in the program. 10 million new acres will be enrolled in CSP in 2017, at which time more than 12 million additional acres will also be up for renewal. CSP is the single largest program dedicated to supporting conservation practices on working lands. As such, its ongoing success has a direct effect on the sustainability and profitability of American family farmers.
In order to address transparency concerns from its local offices and partners, USDA’s Natural Resources Conservation Service (NRCS) is preparing to unveil a “reinvented” CSP this fall. NRCS originally intended to finalize the revisions in time for the 2016 CSP sign-up period, but delayed the overhaul in order to make additional updates, as well as to provide additional time for field staff to learn, understand, and promote the significant changes that had been made. Thus, the reinvented program is now scheduled to roll out during fiscal year 2017 – during a White House and USDA leadership transition and only a year before the next farm bill reauthorization.
The National Sustainable Agriculture Coalition (NSAC) played a central role in the development of CSP in the late 1990s, and has been a leading advocate for the program since its official adoption in the 2002 Farm Bill. We support the goals of making CSP more transparent, accessible, flexible, and farmer friendly and hope to see all that and more in the newly revamped version of the program. With a new administration in office and a new farm bill on the horizon, it is particularly important for the program to work effectively to advance farm and ranch stewardship goals in a manner that works for farmers and the environment.
NRCS has yet to provide the details of the upcoming revisions, but as we approach the public release of the reinvented CSP later this fall, there are several key questions that the agricultural community should be asking:
- 1. Will CSP payments continue to reflect conservation benefits?
As part of their program reinvention, NRCS is revising the formulas used to calculate CSP payments. Payments for new conservation activities will move to a “payment schedule” approach, which is similar to the system that is currently used by the Environmental Quality Incentives Program (EQIP). In order to ensure that the new CSP retains the program’s performance-based identity, as well as its alignment with statutory and regulatory authority, it is critical that conservation benefits be included as part of the new payment calculations – farmers will want to look out for this key detail as revised CSP materials are released this fall.
- 2. Will the CSP application ranking equation consider all conservation outcomes, both from the annual active management of existing conservation activities and from the expected conservation outcomes of newly adopted activities, in equal measure?
CSP was designed to address the natural resource concerns of a particular state or watershed by encouraging producers to add conservation practices to their farm management activities, as well as to actively manage and improve ongoing conservation systems.
As part of the overhaul, NRCS has developed a new CSP ranking process (what the agency calls the Application Evaluation and Ranking Tool – or AERT for short), which will include specific questions that will determine whether or not an application will be funded. The ranking process can make or break a participant’s ability to qualify for CSP.
Given that only 25 percent of eligible program applicants were funded in 2015, it is crucial that the ranking process take into account applicants’ existing conservation levels and set of annual land management activities. Statute requires that NRCS rank applications on six key ranking factors, one of which is the “level of conservation treatment on all applicable resource concerns at the time of application.” When the final version of the ranking tool goes public, we will be looking to see that its questions directly consider an applicant’s level of conservation at the time of application, and also that substantial ranking points are assigned to those questions.
- 3. Will the revised conservation activities reflect and reward participants addressing multiple resource concerns?
The farmers and ranchers who participate in CSP go above and beyond in their commitment to conservation stewardship. In order to support this commitment, as well as to provide a stronger linkage to other NRCS conservation programs, NRCS is redesigning CSP enhancements (i.e., advanced conservation activities) to directly link each one to a single NRCS conservation practice standard.
In order to ensure that participants are appropriately ranked and rewarded, the new enhancements should be linked to all of the resource concerns they address. For example, intensive cover cropping not only increases soil organic matter, it can also help control water and wind erosion, and limit nutrients or pesticides in surface or ground water. The entire suite of an enhancement’s benefits should therefore be reflected in the scoring process. The scores used for the previous set of conservation enhancements appropriately reflected the multiple resource concerns that each addressed, and it is imperative that the revised enhancements achieve this objective as well.
- 4. Will the new screening tool provide appropriate options and flexibility for a diversity of operations?
No two CSP applicants are exactly alike, and thus we will be looking to see that the new screening tool provides appropriate flexibility for a diversity of applicants. We applaud NRCS for setting a high bar in terms of the level of stewardship that an applicant must meet for a given resource concern and land use, but also want to ensure that applicants are not unintentionally made ineligible, due to the specificity of particular screening requirements.
NSAC will be looking to see that the new requirements enable all qualified applicants – from diversified fruit and vegetable operations to dairy operations that are harvesting corn silage for feed – are able to meet the stewardship thresholds based on their existing level of ongoing conservation stewardship and adoption of new conservation activities. The new stewardship requirements must also take into account the fact that conservation challenges vary by state and region; therefore flexibility must be allowed for modifications and the introduction of new conservation enhancements based on unique, geographic resource needs.
Finally, it is important to recognize that unexpected shifts in plans and priorities are a fact of life in farming and ranching. The CSP overhaul must therefore be sure to provide adequate flexibility for mid-contract modifications, both in terms of practice changes that might occur do to changing markets or to reflect how the land responds to newly added conservation, as well as in circumstances wherein a producer gains or loses a lease and must add or subtract land from their CSP contract.
As the 2017 CSP changes become public in the coming months, NSAC hopes to see all of the above questions addressed and thoughtfully considered. We will continue to provide thoughtful analysis, as well as practical advice for family farmers who are currently enrolled or are considering applying to the redesigned program.
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