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Farm conservation program plan still misses the mark

(Friday, June 11, 2004 -- CropChoice news) -- From a Sustainable Agriculture Coalition news release:
Washington, D.C.-- In announcing its long overdue implementation plan for the 2002 Farm Bill’s Conservation Security Program (CSP) today, the Bush Administration made clear it will ignore the largest outpouring of public comment in the history of conservation programs and continue to go its own way. Rejecting the views expressed in over 14,000 comments received from farm and conservation organizations, individual farmers, and concerned citizens, the interim final rule issued today continues to put the implementation plan directly at odds with the law passed by Congress and signed into law by the President.

“Today’s announcement does include some improvements important to the conservation and sustainable agriculture communities and we applaud those at the Natural Resources Conservation Service who have worked hard to make those possible,” said Ferd Hoefner, SAC Policy Director. “Unfortunately, the interim final rule still falls way short of anything that could be called a comprehensive stewardship incentives program.”

The CSP is designed in the 2002 Farm Bill as a comprehensive, nationwide program on a par with federal farm commodity programs, but the Bush plan limits the program to a few local watersheds each year. Rather than the continuous sign-up envisioned by the law, the Bush program would give farmers the chance to enroll in the program at best once every 8 years. The right of the farmer to renew CSP contracts and stay in the environmental program over the long-term, guaranteed in the law, is effectively voided by the Administration’s rule. Despite a legal ban on using a ranking system to select farmers to participate in the CSP, the Administration bases its CSP enrollment process precisely on such a ranking system.

“The CSP interim final rule remains fundamentally at odds with the law and, left unchanged, will seriously shortchange the prospects for environmental improvement on working farmland,” said Ferd Hoefner, SAC Policy Director. “In January the Administration promised to issue a substantially revised rule if Congress removed the funding cap from the CSP. Congress removed the cap for 2005 and all future years, but unfortunately for American farmers the promise to substantially revise the rule has been left unfulfilled.”

The interim final rule makes some improvement in the CSP payment rates. Rather than reducing the statutory base payments rates by 90 percent, as in the proposed rule, the interim final rule reduces the rates by 75 percent, 50 percent, and 25 percent for Tier I, II, and III participants respectively. At the same time, however, the interim final rule reduces CSP cost share payments from up to 75 percent, as required by law and included in the proposed rule, to not more than 50 percent.

Most importantly, the interim final rule adds a new overarching payment constraint not found anywhere in the statute. This “contract limitation” would limit the total CSP payment, including the bonus or “enhanced” payments for outstanding environmental performance, to not more than 40 percent, 25 percent, and 15 percent of local land rental rates for Tier III, II, and I participants respectively. The brand new limitation will hit small acreage, high value crops and rangeland livestock operations particularly hard, even those with some of the best conservation improvements. The result may well be that few of these producers, if any, will enroll, including many farmers and ranchers who have been conservation leaders.

“The new rule takes one step forward and two steps back on payment rates,” according to Hoefner. “Consistent with the proposed rule, the Administration helpfully aims to make the CSP the most environmentally demanding program in the history of USDA conservation efforts, but then wants to do it without reasonable incentives. This will be a very tough sell in farm country.”

One significant improvement in the interim final rule is the decision to value cropland that has been converted to pasture-based farming as higher valued cropland for CSP payment purposes. This change eliminates the earlier perverse incentive for choosing annual cropping over grass-based, resource-conserving systems.

The Coalition expects a CSP notice to be issued in the near future, separate from the interim final rule, to include another extremely important improvement. Buried in the fine print of the Administration’s May 4 th announcement of the ranking process which will be used to pick farmers and ranchers within the selected watersheds to participate in the CSP, there was a startling revelation: for cropland, preference was given to farms with concentrated program crop production, provided they use conservation tillage practices, over sustainable and organic operations with diversified, resource-conserving crop rotations. It now appears this problem will be fixed in soon-to-be-announced revisions to the ranking categories. This change was welcomed by the sustainable agriculture community and will help retain the CSP’s “green box” trade compliant status in the context of international trade rules.

“We urge the Administration to show its support for the future of the CSP by ceasing its advocacy of a funding cap on the CSP and to return to their previous support for the CSP’s entitlement program status,” said Hoefner. “Next the agency needs to reconsider this interim rule and issue a final rule before the end of the calendar year that reflects the provisions of law and provides real and comprehensive stewardship incentive contracts.”


Contact: Ferd Hoefner, (202)-547-5754