The Bush administration's recently released plan for implementing the landmark Conservation Security Program (CSP) established in the 2002 farm bill will severely limit eligibility to a few priority watersheds across the country. According to the Sustainable Agriculture Coalition and the Kansas Rural Center, the U.S. Department of Agriculture announcement flies in the face of the 14,000 plus farmers and citizens who submitted comments on a draft rule released earlier this year. Virtually all comments opposed the restrictive approach of offering the program in selected watersheds, instead of following the 2002 farm bill which orders a nationwide program open to enrollment by all farmers who practice effective strict conservation practices.
The USDA plan sets out a two-tiered approach to drastically limit the number of farmers who will be eligible to participate in the CSP. Only farms in certain "priority watersheds" and only some "categories" of farmers within those limited number of watersheds will be allowed to participate in the CSP.
"Why did they bother with a public comment period if they were going to ignore us? Farm groups, conservationists, and environmentalists have never been so united in support of a national farm conservation program," said Mary Fund, Communications Director for the Kansas Rural Center." The farm bill says the Conservation Security Program is to be offered nationwide, without any ranking system."
Commentaries on the proposed rule also decried low payment rates, requirements that farmers meet high conservation standards as a precondition for applying rather than using the program to achieve standards, severe limitations on choice of conservation practices, and limitations on which resources can be addressed. It is not known how USDA will treat these concerns in the final rule.
The Bush administration intends for the restrictive approach to eligibility to be permanent, even though the tight $41 million CSP budget cap for fiscal year 2004 comes off at the beginning of the new fiscal year in October and the program returns to its 2002 farm bill status as a conservation entitlement program. The notice being released May 5 clearly states that the same watershed and enrollment category restrictions will also appear in the final rule for the program when it is published later this spring, meaning the restrictions are intended to apply for 2005 and all future years.
"The administration is now declaring its intent to deny the country's best conservation farmers the opportunity to participate in the CSP unless they are lucky enough to live in a selected watershed," said Ferd Hoefner, policy director for the Sustainable Agriculture Coalition. "Their exclusionary approach is at odds with the law and will effectively eliminate the CSP as the nationwide, comprehensive environmental program intended by Congress in the 2002 farm bill. The eligibility test for the CSP should be top-notch conservation and environmental performance, not where you happen to live. We urge the administration to heed the overwhelming public input and reverse course in the upcoming rule to implement the CSP for 2005 and beyond."
"We understand the difficulty in implementing CSP in a hurry for this year. But we believe the Bush administration could use the admittedly tight $41 million available now by letting the state offices of the Natural Resources Conservation Service (NRCS) enroll farms on a pilot basis without a rule, as has often been done for other new programs," said KRC's Fund. "This will help work the kinks out of the system while a better final rule is developed. The Bush administration should keep its eye on the long-term promise of this program, and not cripple it with a poorly drafted and unsupported set of rules."
The Conservation Security Program is a comprehensive stewardship incentives program that provides financial and technical assistance to farmers and ranchers to reward them for investments of labor, management, and capital aimed at fostering healthy, productive, and non-eroding soils, clean air and water, energy savings, wildlife habitat, and prairie, wetland, and other ecosystem restorations. Unlike the U.S. commodity programs which are under attack in the WTO, the CSP is a trade rule-compliant "green box" program aimed not at increasing production but rather at maximizing long-term environmental benefits. The sustainable agriculture community was a leading proponent of the initiative during the 2002 farm bill debate and continues to monitor implementation closely. The Kansas Rural Center is a member of the Sustainable Agriculture Coalition.