POLICY :: CAFF submits comments on proposed rules for Conservation Security Program

• Allow for continuous rather than periodic sign-up.
• All farmers and ranchers who meet all the pertinent conservation standards established at the local level should be allowed to enroll.
• The CSP should use local and flexible determination regarding definition of resource concerns; practices that qualify for cost-share and maintenance payments; and how enhanced payments can attract meaningful participation.
• Enrollment categories and the watershed limitation should be eliminated from the rule.
• A significant increase in proposed payments to farmers must be made.

• "Enrollment categories" should be eliminated so that farmers and ranchers who meet the pertinent conservation standards established at the local level, are eligible to enroll. The program should establish the conservation goal and objective and let all farmers and ranchers willing to implement the goals to achieve established objectives participate without discrimination against any particular categories or classes of producers.

Enhancement Activities:
• Enhancement payments should reward additional efforts and exceptional performance conducted by farmers and ranchers.
• The statute includes rewarding farmers and ranchers for crop rotations, managed rotational grazing, and comprehensive conservation buffer practices. These practices must be added to the rules.
• On-farm research and demonstration projects and on-farm monitoring and evaluation projects should be encouraged, with farmers' time and labor compensated along with direct costs. CAFF, through our biological farming program, has seen the acceptance and adoption of on-farm demonstration projects by other farmers and ranchers.

• CAFF is concerned that neither the preferred approaches nor the alternative approaches listed implement the intent of the CSP law.
• CAFF believes that farmers and ranchers should be allowed to sign-up continuously and that all applications that meet the established standards should be approved. Approved applications should be funded based on their application date and any unfunded contracts should be awarded as money becomes available, provided that no substantial changes in the farmer's or rancher's situation occurred which would require a major revision in the Plan or Contract.

• To provide the opportunity for participation by limited resource producers the cost-share rate should be 75 percent. Promoting the most cost-effective practices that require the least expenditure for the farmer's share of the cost to address conservation resource concerns will be beneficial to limited resource producers.
• Beginning farmers and ranchers with limited resources should be provided with a cost-share rate of 90 percent.
• Increasing the base and enhancement payments for all producers will assist limited resource farmers to come up with their portion of cost share.
• CSP rule should include specific language for set-aside for small and limited resource farmers and ranchers

• The opportunity exists within the 2002 Farm Bill for greater leveraging and the collaboration among state and local agencies, Indian tribes, and non-governmental organizations. NRCS should implement the Partnerships and Cooperation provision of the 2002 Farm Bill. The initiative specifically calls for collaboration to encourage cumulative conservation benefits through cooperation of producers spanning multiple operations.
• The proposed rule should be modified so that it does not require farm families to carry the financial load of participation. The list of practices should not be so short and with such low cost-share rates and limited enhancement payments that it is a disincentive to participate.
• It is important that farmers and ranchers who otherwise qualify for CSP, yet may need to include a certain structural or vegetative practice(s) to reach resource enhancement levels should not be forced to apply, and be approved by, other conservation programs before qualifying for CSP. The interest in capped conservation programs normally exceeds the funding by two to three times. A requirement of waiting would delay implementation of enhanced conservation.

• In the proposed rule, the evaluation process begins with a benchmark inventory of the resource concerns. It serves as a baseline level for implementation of the conservation plan and establishes measurable goals for further enhancement of those resources.
• NRCS should provide stronger incentives for on-farm monitoring and evaluation activities, and encourage the integration of farm level data into landscape and macro-level monitoring, evaluation, and analysis.

• CAFF urges that concern priorities for resource conservation be set at the state level so the program is effective in responding to resource issues in every region of the country.
• CAFF recommends that soil and water quality be included in the top five resource concerns of each state. The resulting flexibility would enable diverse resource challenges, like water, soil, air and energy as are faced in California, to be addressed.

• Agricultural operations should include all land owned and leased by the operator.
• CAFF does not support a requirement that farmers and ranchers carry out conservation practices without financial assistance on leased land for which they cannot prove control for the entire length of the contract. Contract modification should be allowed, if a change in a lease or rental situation arises, rather than the requirement for creation of a new contract.

• Although the definition of forest proposed by NRCS may work in some parts of the USA, it will not work everywhere. We urge that state definitions be allowed so that efforts can be made to focus on the actual land use of the forested area. This would enable such practices as windbreaks, shelterbelts, forest farming, nut harvest, alley cropping, forest buffers, silvopasture systems, etc. to be eligible in this category.

• Incidental forestland, including agroforestry practices that assist the producer to improve resource conservation, should meet relevant quality criteria and be eligible for all forms of CSP payments through enhanced payment formulas.

• CAFF believes that the rules should clearly provide for significant enhancement payments nationwide for resource-conserving crop rotations, managed rotational grazing and comprehensive conservation buffer practices.
• NRCS should emphasize enhancement payments for on-farm research, demonstration, monitoring and evaluation. These payments need to reflect the direct costs, including the costs of the farmers' and ranchers' time.
• The state should be authorized to approve enhancement payments for additional practices or systems that address local priority resource concerns and reaching participation targets in targeted areas.

• Contracts should attribute all payments to real persons directly involved in the resource conservation implementation and management of the working land.

• The CSP program is a nation-wide program designed to reward producers on working lands for resource conservation practices. The CSP program should set reasonable eligibility standards, set a high environmental goal and approve all submitted CSP plans that meet those standards. CSP Plans should be approved for funding based on application date. As of October 1, 2004 the remaining CSP Plans would be eligible for funding based on application date, providing that no substantial changes occurred in the farmer's or rancher's operation that would require a major revision.

• Since land capability classes vary significantly by state, and within a state like California, the state NRCS, state conservationist and state Technical Advisory Committee should be given the flexibility to determine the basis for the calculation of CSP base payments. The bottom line for determining the base payment should be that it contributes to the making of a CSP program that is attractive to operators of lands with resource concerns.

• CAFF believes that all land should be in compliance with the basic conservation requirements of the 1985 farm bill, even if it is outside of the land covered under Tier l contract. The proposed rules include the entire farm or ranch operation in Tiers Two and Three. The rules of the CSP program should provide the incentive to encourage producers to move to Tier Two as soon as possible.
• CAFF supports the flexibility to provide special dispensation for destroyed or damaged resource practices by forces beyond human control.
• The CSP tiered approach and enhancement payments can foster the program goal of farmers and ranchers achieving regeneration and enhancement of resources. CAFF requests that the rule be changed to allow states to establish the resource conservation criteria, including soil and water as two of at least five concerns. The producer would then be required to meet one of the two either soil or water criteria for enrollment in Tier One. This will provide the incentive and opportunity for participants to achieve all relevant quality criteria required within the timeframe of their first contract.
• Although use of the self-screening tool can be helpful for the producer and for NRCS to manage the workload, farmers and ranchers should be free to come into their local NRCS office to seek assistance. The opportunity for continuous signup would enable better management of NRCS workload as well.

• As stated earlier in our comments, CAFF calls for the elimination of enrollment categories. CAFF believes that contracts should be funded by date of application. CAFF does not support pro-rating of payments or partial payment; this is a disincentive for program participation.

• The full range of NRCS-approved practices should be allowed for consideration as part of CSP conservation plans. The rule should also allow for states to include new practices that include non-traditional conservation objectives that foster a working landscape approach to ecosystem restoration to create more wildlife-friendly farms and ranches.
• Flexible and local discretion should be allowed to achieve resource conservation objectives. This will encourage farmers and ranchers to participate and not set sustainable agriculture apart from what is commonly referred to as conventional agriculture.

• NRCS must be responsible for review and oversight of the CSP plan and its implementation. NRCS should conduct the training and certification programs for Technical Service Providers (TSP) to provide a qualified pool of individuals who can offer technical assistance over a wide range of relevant resource management practices as well as the evaluation and assessment of the producer's operation.

• CAFF again expresses it support for state and local discretion in the establishment of significant resource concerns, two of which would be water and soil. CAFF believes that if we include one of the two as a requirement in Tier One we will be able to include more farmers and ranchers. The reward of the program is compensation to working farmers and ranchers addressing conservation resource concerns on their working lands. It is counter productive to create tiers in the program that function as a disincentive to participate.

• CAFF supports making the transition to a higher tier an objective of the program. However, the delay of tier transition and higher payments for 18 months is unacceptable. The cost-share and enhancement payments adjustment should begin at the time of contract modification. If a payment delay is absolutely necessary, it should only apply to the base payment.

• CAFF agrees with the proposed rule that provides for reasonable time periods to return to compliance as well as producer retention of CSP payments in cases of good faith participation and in cases of compliance problems resulting from hardships beyond the producer's control.
• CAFF does call for a change in the section on contract requirements that reflects the agency's discretion so that the penalty, if any, fits the particular circumstance.

• The proposed rule should be revised to establish base payments at a reasonable percentage of agricultural use land valuation. The bottom line is that the base payments should contribute to making the program attractive to operators of lands with resource concerns. Setting the rate factor too low would be another deterrent to producers wishing to participate.

• CAFF wants to emphasize the benefit of on-farm monitoring and evaluation to the farmer. Good on-farm monitoring and evaluation can help farmers and ranchers continually adapt their conservation system to achieve optimal benefits. These practices also provide the opportunity to motivate communities to make locally-appropriate changes.

• Enhancement payment rewards for environmentally important management changes that do not necessarily require significant out-of-pocket costs are entirely appropriate.
• Enhancement payments should reflect cost plus an incentive or bonus to achieve performance outcomes. If little or no cost is required, a flat bonus rate that achieves and maintains resource conservation concerns should be made.