I received this action alert yesterday from The National Sustainable Agriculture Coalition. We have until September 28 to tell the USDA to base Conservation Stewardship Program application approval on environmental outcomes, not on when a conservation practice is implemented. See below:
Since the 1930s, we've been paying farmers to produce corn, wheat, rice and cotton. What if we paid farmers for producing healthier soil, cleaner water, climate change mitigation and greater bio-diversity instead? That's the "Big Idea" behind the Conservation Stewardship Program (CSP). Pay farmers to produce environmental outcomes that contribute to the public good.
Sustainable and organic farming advocates have an important, urgent opportunity to help shape the implementation of this working lands conservation program. The USDA has requested comments on the administrative rules that will govern implementation of the new CSP.
The USDA is considering giving a higher rank to CSP applications proposing the adoption of new conservation practices vs. the maintenance of existing practices. Current rules give equal weight to existing and proposed conservation practices. Please tell the USDA that CSP applications should be ranked on the basis of environmental outcomes and not on the basis of when a conservation practice is implemented.
The USDA has posed a specific question for comment: Should the program give greater weight and therefore a higher rank and a higher likelihood of acceptance into the program to applications proposing new conservation practices? Or should existing and new practices be given equal weight?
The Environmental Quality Incentives Program (EQIP) and other conservation programs pay farmers to adopt new conservation practices. The CSP, however, is unique among working lands conservation programs. The CSP rewards farmers who are already farming at a high stewardship threshold and provides an incentive to maintain those high stewardship standards.
If a farmer has previously adopted advanced conservation measures and systems, the program is designed to reward that behavior and help pay for continued active management and maintenance of those systems and practices. Farmers should also be expected to and be rewarded for adopting new practices. But CSP ranking and payments should be keyed to environmental outcomes and not on when conservation activities are adopted.
CSP design and regulation should equally balance the benefits of both existing and new practices with the primary measure being the environmental benefits secured by the total conservation system regardless of the timing of adoption of various parts of the system. This is essential to making CSP a program that recognizes and rewards the multiple benefits of sustainable and organic farming systems.
Comment letters can be as short or as long as you want. Put your comments in your own words, and raise the points most important to you. You can submit a comment from the National Sustainable Agriculture website, or you can email comments directly to the USDA at CSP2008@wdc.usda.gov.
If you send your own email: Be sure to identify the Docket Number at the top of your letter: RE: NRCS-IFR-09004. Address your comment letter to: Mr. Gregory Johnson, Director, Financial Assistance Programs, US Department of Agriculture, Natural Resources Conservation Service, 1400 Independence Avenue SW, Room 5237-S, Washington, DC 20250-2890. Be sure to identify yourself by providing your name and contact information. You may also mail your letter to this address if you prefer not to email it. The deadline is September 28.