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Sample Comment for Farmers

[DOWNLOAD THE FULL COMMENT TEMPLATE AS A WORD DOCUMENT HERE]

LEARN MORE ABOUT THE ISSUES

What is CSP?

The Conservation Stewardship Program (CSP) is the premiere federal working lands conservation program designed to reward farmers for adopting and managing smart conservation practices on their farms.  By providing comprehensive conservation assistance to whole farms, CSP offers farmers the opportunity to earn payments for actively managing, maintaining, and expanding conservation activities like cover crops, rotational grazing, ecologically-based pest management, diversified, resource-conserving crop rotations, conservation tillage, and the transition to organic farming – even while they work their lands for production.

CSP covers more acres of working farm and ranch lands on a multi-year basis than any other federal conservation program.  It targets funding to:

• Address particular resources of concern in a given state or region, such as water quality or soil erosion;
• Assist farmers and ranchers to improve soil, water, and air quality;
• Provide increased biodiversity and wildlife and pollinator habitat;
• Sequester carbon and reduce greenhouse gases to mitigate climate change; and
• Conserve water and energy.

Farmers and ranchers anywhere in the country can apply for CSP funding every year at any time of the year. Enrollment is competitive and, typically once each year, NRCS will rank applications and develop contracts with those farmers and ranchers who have the highest-ranking applications until funding for that ranking period is exhausted.

Fast CSP facts:

• CSP (and its predecessor, the Conservation Security Program) has been in existence since the 2002 Farm Bill.
• Nearly 60 million acres of crop, forest, and pasture, and rangeland are currently enrolled in the program – accounting for nearly seven percent of farm and ranch land nationwide.
• The 2014 Farm Bill provides sufficient funding to enroll 10 million additional acres in CSP each year in the future, on top of the 60 million acres already enrolled under the previous farm bill.
• CSP provides five-year payment contracts.  Participants may renew their participation in the program.  During the first round of contract renewals, 75 percent of eligible participants filed an application to renew.

Get details on the program in our Grassroots Guide: http://sustainableagriculture.net/publications/grassrootsguide/conservation-environment/conservation-stewardship-program/

Why does this CSP comment period matter?    

CSP has been in operation for many years, but with the passage of the 2014 Farm Bill, NRCS was directed to make changes to CSP, hence these new rules, published on November 5, 2014. 

Although the CSP Interim Final Rule (IFR) issued in November is effective immediately, it also subject to a public comment period, during which time the public can provide comments on the agency’s interpretation of their new authority under the Farm Bill and other programmatic issues. 

The comment period will close on January 20, 2015, at which time the agency must consider all comments received before publishing a final rule.

CSP matters because this program directly benefits thousands of farmers and millions of acres of working farmland every single year – by rewarding practices that improve and sustain our shared natural resources.

However, in operating CSP, NRCS has failed to adequately address several significant barriers to participation, including – most importantly – the need to fully and properly recognize and reward farmers who are committed to actively managing and continually improving existing conservation practices and stewardship activities.

To put it in plain language: CSP is designed to address the priority resource concerns of a particular state or watershed (e.g., water quality – it’s responsive to different regional needs!) by encouraging producers to actively manage and improve their ongoing conservation activities AND to add new conservation enhancements.  Yet NRCS overemphasizes adding new conservation activities while failing to adequately recognize ongoing activities farmers are undertaking.  This has the unintended effect of penalizing some of our nation’s best conservation-oriented farmers by keeping them out of the program, and making it harder for the program to reward and support great conservation efforts.

Further, NRCS is not doing enough to ensure that CSP is accessible to beginning farmers and small acreage farmers, and they have yet to close loopholes that allow some farmers to exceed the farm bill’s per farm payment limits and thus reduce available funding for more farmers.

It’s important to speak out during this comment period because we only get this opportunity every five years or so with a new farm bill.  Now’s our chance to impact how this critical program operates for the years ahead.