Five former Natural Resources Conservation Chiefs are joining specialty crop growers in calling for a loosening of income restrictions for conservation programs, but opponents worry that easing the means test will make it harder for smaller farmers to obtain assistance. 

Current rules bar farmers with adjusted gross incomes of more than $900,000 from enrolling in a wide slate of conservation programs, including the Environmental Quality Incentives Program and the Conservation Stewardship Program.

AGI for a farmer is based on net farm income, the profit or loss left after expenses and deductions. 

The group of former NRCS chiefs — Bruce Knight, Arlen Lancaster, Dave White, Jason Weller and Leonard Jordan — argue in a letter to the leaders of the House and Senate Agriculture committees that the restrictions are “counterproductive” to efforts to reduce greenhouse gas emissions and improve water quality, soil health and wildlife habitat.

The solution suggested by the former chiefs is for Congress to create “categorical waivers” for certain categories of projects or give the Agriculture Secretary the power to do so. One waiver, for instance, could remove AGI restrictions for programs that include greenhouse gas emission projects, while keeping them in place for other types of projects.

The goal, the former chiefs argued in their letter, is to “better leverage NRCS’s critical resources, improve timely conservation outcomes, and reduce the administrative burden on both producers and the NRCS.”

“We shouldn’t be discouraging large operations from participating,” Bruce Knight, who served as NRCS chief during the George W. Bush administration, told Agri-Pulse. “If you want early action on climate and you want to do it at scale, you’ve got to go where the acres are.”

Knight said the current $900,000 AGI restrictions often keep out large, multi-family agricultural operations, particularly those with adjoined processing businesses, such as dairy farmers who also operate processing plants or apple orchard operators that run packing houses.

Bruce KnightBruce Knight Knight also said AGI limits are unnecessary since the programs already have restrictions on how much producers can be paid.

“It’s a bit like putting on a belt and suspenders,” Knight said of both AGI and payment limits. “We all want to keep our pants up, but you don’t really need both a belt and suspenders to be able to do that.”

Lancaster noted that the former NRCS chiefs aren't seeking to change the limits on the amount of money individual producers can receive. The payment limit for EQIP is $450,000.  CSP payments are capped at $200,000.


He told Agri-Pulse that to enroll conservation practices on as much land as possible, the agency needs to be able to look beyond the producers it is currently restricted to.

“It’s really about the land that we’re talking about here and not the ownership,” said Lancaster, who served as chief from 2006 to 2009.

But Jesse Womack, a policy specialist for the National Sustainable Agriculture Coalition, said the proposal would disadvantage small and historically underserved producers by adding more competition to the current applicant pool.

“I really think farms that are larger and, therefore, better resourced are in a far better position to implement conservation themselves,” Womack said. “We really need to preserve public funding for farms that are less well resourced in order to make sure we’re getting conservation on the maximum amount of acreage.”

Womack said if Congress wants larger farms to get more involved in conservation, they should look at creating additional conservation requirements for farms enrolled in federal commodity support or crop insurance programs.

Scott Faber, senior vice president of government affairs for the Environmental Working Group, expressed concern that removing AGI limitations would open the door to attempts to increase payment limits, which he says would further disadvantage current applicants.

“It clearly is the camel’s nose under the tent,” Faber said. “Once we start waiving limits on who can participate, it’s only a matter of time before we start waiving limits on how much they can receive.”

AGI limitations are a particular concern for growers of high-value specialty crops in California and other Western states. Don Cameron — who raises almonds, walnuts, tomatoes and around 22 other types of crops in California’s Central Valley — said his annual AGI often exceeds the $900,000 limit due to the value of these crops.

While Cameron has done some native pollinator hedgerow, groundwater recharge and solar power projects on his own farm, he’s often had to rely on his own money or state or private grants to do so. He said the lack of access to the NRCS program dissuades other Central Valley farmers, often in similar situations, from pursuing similar projects.

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“I think California gets the short end of the stick because we do have high-value crops here," Cameron told Agri-Pulse. "I think we could be doing a lot more conservation programs with NRCS and really providing a lot of benefit to the state.”

Cameron said he did try applying for an AGI waiver from the NRCS “quite some time ago,” but was told by the agency that it was unlikely to be approved. He hasn’t tried since, he said.

“We don’t qualify, so I’m not going to spend my time trying to beat the door down,” Cameron said.

Dennis Nuxoll, vice president of federal government affairs for the Western Growers Association, said several specialty crop farms in the West are similarly barred from enrolling in conservation programs due to the AGI restrictions. 

According to USDA’s Economic Research Service, 55.6% of high-value crops in 2017 were produced by large-scale family farms. which have gross cash farm incomes of $1 million or more. Gross cash farm income is different from AGI and measures annual income before expenses. It does not include adjustments. 

Distribution of the value of production by farm type for selected commodities, 2017Note: Gross Cash Farm Incomes not adjusted“We have a disproportionate portion of our industry that doesn’t have access to conservation at all,” Nuxoll told Agri-Pulse.

Large-scale family farms also produced 68.4% of the nation’s dairy and 54.5% of its cotton, according to the ERS.

Nuxoll said he supports the general idea of the letter, though his preferred solution is to exempt producers that get 75% of their income from farming, agri-tourism, or other agricultural-related activities from AGI limitations. The Growing Access to Environmental Sustainability (GATES) Act, introduced by a bipartisan group of six lawmakers last month, would do that for CRP, EQIP and CSP. 

Knight said he knows the thought of adjusting AGI requirements is going to “give people pause” due to its controversial nature, but he believes a conversation on the topic is needed before the next farm bill is introduced. 

“We think now’s the time to put this on the table,” Knight said. 

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Editors note: This article was updated with language clarifying the difference between AGI and gross cash farm income.