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CSP: Cheat the best and ignore the rest

by Jeff Schahczenski
Executive Director, Western Sustainable Agriculture Working Group

(Thursday, Jan. 29, 2004 -- CropChoice guest commentary) -- In legislation President Bush will sign into law this week, Congress has restored full, uncapped funding for 2005 and beyond to the ConservationSecurity Program (CSP), the landmark ‘green payments’ initiative from the 2002 Farm Bill to provide stewardship payments in support of excellence in private working farmland conservation.

Unfortunately, less than a month earlier, the Administration issued a “proposed rule” to guide implementation of the CSP that assumed the program would be limited to a capped, very low spending level each year. In fact, the proposed rule is so restrictive and proposes such low levels of financial assistance it is doubtful whether many farmers could qualify or if any would bother trying.

The Conservation Security Program can offer one of the best opportunities in United States history to build a sustainable western agriculture on working lands. With so much potential at stake, it is truly amazing that the United States Department of Agriculture can now propose rules for this innovative conservation program that are so completely out of touch with the intent of Congress.

In announcing the proposed rules for this innovative conservation program last month the Secretary of Agriculture, Ann Veneman stated that the proposed rules for the Conservation Security Program “will reward the best and motivate the rest”. However by any reading of these rules, what we really have is a program gutted of all its potential to be a truly new way to support conservation in agriculture. What these proposed rules offer is a program that will cheat the best and ignore the rest. With Congress fully funding the CSP, three major items must be addressed quickly:

First, the USDA must immediately write a supplemental rule to this program that recognizes that this program is an uncapped entitlement program. The current proposed rules must reflect the reality that this program was created to last at least seven years. The NRCS and USDA should not be wasting time creating a narrow set of rules that worry too much about the unfortunate fact that Congress has appropriated only $41 million dollars for this program in the current fiscal year (which is almost half over already anyway). Given the incredible foot dragging of this administration in implementing this program, it is unlikely that there will be final rules ready to spend much of the $41 million dollars appropriated this fiscal year anyway and it would seem prudent to at least “trial run” a few CSP contracts under rules that reflect its true entitlement status.

Remember entitlement means that “all who are eligible” have the opportunity to participate and that the cost of the program should NOT be the critical issue addressed in the implementation of this program. As an example, the commodity programs are also an entitlement program, and all those who grow the commodity crops that the federal government supports are eligible for that support. When the commodity title of the 1992 Farm Security and Rural Investment Act was passed, it was “estimated” that these commodity entitlement programs would cost some $133 plus billion dollars over the life of the Act. Of course the actual expenditures will be more or less depending on many factors not controllable by the federal government. The Conservation Security Program is also “estimated” to cost $7.2 billion dollars over the life of the Act that authorized it. We need to make the same commitment to this entitlement program as we do to the commodity programs and we need rules that reflect that commitment; the current proposed rules do not.

v Second, the proposed rules set a series of eligibility criteria that are so out of step with the legislation that if one could effectively sue the USDA for violating the intent of Congress it is very likely that the plaintiffs would easily win a settlement. For instance the proposed rules set incredibly high standards of eligibility, limits support to un-named priority watersheds, set two resources of concern as the only resources of importance, have limited program sign-up periods, and wish to limit support to an again, un-named set of restricted conservation practices.

Finally, the benefits of the program outlined in the rule are so limited that even if one can become eligible for the program it is doubtful that it would be worth applying. As one major example, the cost-share rates proposed under the rule are only 5% of the estimated conservation practice costs. This is unreal considering that other conservation programs (like the Environmental Quality Incentive Payment Program) that try to bring farmers and ranchers in compliance with federal environmental laws will get up to 75% cost-share! Thus a program supposedly rewarding proven conservation farmers only provides 5% cost share from the USDA while another government program provides 75% cost share with no assurance of positive environmental outcomes.

These proposed rules highjack one of the most important new conservation programs in our nations history. As Senator Gorden Smith, one of the original sponsors of the CSP relates in recent comments, “ this is too good a program to shortchange. We have the opportunity to help farmers in their efforts to protect the environment, and we should be doing all we can to realize its’ full potential”. While this administration gives the impression of wanting to make new serious efforts for conservation in agriculture, when rhetoric meets reality we are left with a monumental failure of delivery.

Contact Mr. Schahczenski at 406-494-8636 or wsawg@ncat.org