Share Your Views on EQIP and CSP

By Bruce Knight

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The Natural Resources Conservation Service (NRCS) is currently accepting comments on new rules for the Environmental Quality Incentives Program (EQIP) and the Conservation Stewardship Program (CSP) to bring these programs in line with the 2014 Farm Bill.  On the one hand, the changes set forth in the interim rules are mostly straightforward reflections of the provisions of the farm bill, but the comment periods offer farmers and ranchers an opportunity to go beyond simply commenting on these changes to suggest innovations for these programs.

The rules themselves simply establish how NRCS will manage these two programs, but the agency will welcome suggestions for ways to improve both programs, so even if your idea does not relate specifically to one of the rule provisions, I encourage you to send it in.  This is your chance to make your voice heard.  I believe NRCS is eager to hear good ideas for ways to improve, to make both programs more workable.

Lets Talk Food

For CSP, I'd like to see more enhancement opportunities, more priorities established and decisions made at the local and state level as they are for EQIP.  We need to have greater transparency so that every state has its priorities clearly identified on its website for landowners to see.  Both programs need to be more transparent in their management and decision making. 

The real challenge on CSP is whether farmers receive adequate credit for maintenance of conservation innovations they established on their land before specific practices were developed for those strategies.  A decade ago CSP recognized the investment farmers made as early adopters of conservation practices. We need a way to use CSP to help offset costs for those who are out in front on conservation efforts.  I am thinking specifically about those farmers who today are improving their land's soil health even though the NRCS programs do not yet have ways to measure, monitor or encourage the full suite of soil health advancements.   

We ought to also reward those who rapidly embrace and adopt new technologies.  An example is the use of saturated buffers (a new tool for cost effectively filtering drainage tile water),  We need a national practice standard in EQIP for that technology that some farmers have already put in place.

Take advantage of the current comment periods to share your ideas on the future directions for both CSP and EQIP.  This is a good time and a good opportunity to expand the discussion and offer your recommendations.

Submit your comments on the CSP interim rule no later than January 20, 2015, a 15-day extension from the original January 5 due date.  View the document at https://www.federalregister.gov/articles/11/05/2014-26295/conservation-stewardship-program-csp-interim-rule.  Send your thoughts by email to http://www.regulations.gov for Docket No. NRCS-2014-0008 or submit a paper copy through the U.S. mail or by hand delivery to Public Comments Processing, Attn: Docket No. NRCS-2014-0008, Regulatory and Agency Policy Team, Strategic Planning and Accountability, U.S. Department of Agriculture, Natural Resources Conservation Service, 5601 Sunnyside Ave., Building 1-1112D, Beltsville, MD 20705.

For EQIP, the interim rule appeared in the December 12, 2014 Federal Register and comments are due February 10, 2015.  Check it out at  https://www.federalregister.gov/articles/2014/12/12/2014-28941/environmental-quality-incentives-program-eqip#h-24.  You can submit comments by email to http://www.regulations.gov for Docket No. NRCS-2014-0007.  Or you can submit a paper copy through the mail or by hand to Public Comments Processing, Attn: Docket No. NRCS-2014-0007, Regulatory and Agency Policy Team, Strategic Planning and Accountability, U.S. Department of Agriculture, Natural Resources Conservation Service, 5601 Sunnyside Ave., Building 1-1112D, Beltsville, MD 20705.

About the author: Bruce I. Knight, Principal, Strategic Conservation Solutions, was the Under Secretary for Marketing and Regulatory Programs at the U.S. Department of Agriculture (USDA) from 2006 to 2009. From 2002 to 2006, Knight served as Chief of Natural Resources Conservation Service. The South Dakota native worked on Capitol Hill for Senate Majority Leader Bob Dole, Rep. Fred Grandy, Iowa, and Sen. James Abdnor, South Dakota. In addition, Knight served as vice president for public policy for the National Corn Growers Association and also worked for the National Association of Wheat Growers. A third-generation rancher and farmer and lifelong conservationist, Knight operates a diversified grain and cattle operation using no-till and rest rotation grazing systems

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