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CSP: Cheat the best and ignore the rest
by Jeff Schahczenski
(Thursday, Jan. 29, 2004 -- CropChoice guest commentary) -- In legislation President Bush will sign into law this week, Congress has restored full, uncapped funding for 2005 and beyond to the ConservationSecurity Program (CSP), the landmark ‘green payments’ initiative from the 2002 Farm Bill to provide stewardship payments in support of
excellence in private working farmland conservation.
Unfortunately, less than a month earlier, the Administration issued a
“proposed rule” to guide implementation of the CSP that assumed the
program would be limited to a capped, very low spending level each
year. In fact, the proposed rule is so restrictive and proposes such
low levels of financial assistance it is doubtful whether many farmers
could qualify or if any would bother trying.
The Conservation Security Program can offer one of the best
opportunities in United States history to build a sustainable western
agriculture on working lands. With so much potential at stake, it is
truly amazing that the United States Department of Agriculture can now
propose rules for this innovative conservation program that are so
completely out of touch with the intent of Congress.
In announcing the proposed rules for this innovative conservation
program last month the Secretary of Agriculture, Ann Veneman stated that
the proposed rules for the Conservation Security Program “will reward
the best and motivate the rest”. However by any reading of these rules,
what we really have is a program gutted of all its potential to be a
truly new way to support conservation in agriculture. What these
proposed rules offer is a program that will cheat the best and ignore
the rest. With Congress fully funding the CSP, three major items must be
addressed quickly:
First, the USDA must immediately write a supplemental rule to this
program that recognizes that this program is an uncapped entitlement
program. The current proposed rules must reflect the reality that this
program was created to last at least seven years. The NRCS and USDA
should not be wasting time creating a narrow set of rules that worry too
much about the unfortunate fact that Congress has appropriated only $41
million dollars for this program in the current fiscal year (which is
almost half over already anyway). Given the incredible foot dragging of
this administration in implementing this program, it is unlikely that
there will be final rules ready to spend much of the $41 million dollars
appropriated this fiscal year anyway and it would seem prudent to at
least “trial run” a few CSP contracts under rules that reflect its true
entitlement status.
Remember entitlement means that “all who are eligible” have the
opportunity to participate and that the cost of the program should NOT
be the critical issue addressed in the implementation of this program.
As an example, the commodity programs are also an entitlement program,
and all those who grow the commodity crops that the federal government
supports are eligible for that support. When the commodity title of the
1992 Farm Security and Rural Investment Act was passed, it was
“estimated” that these commodity entitlement programs would cost some
$133 plus billion dollars over the life of the Act. Of course the
actual expenditures will be more or less depending on many factors not
controllable by the federal government. The Conservation Security
Program is also “estimated” to cost $7.2 billion dollars over the life
of the Act that authorized it. We need to make the same commitment to
this entitlement program as we do to the commodity programs and we need
rules that reflect that commitment; the current proposed rules do not. v
Second, the proposed rules set a series of eligibility criteria that are
so out of step with the legislation that if one could effectively sue
the USDA for violating the intent of Congress it is very likely that the
plaintiffs would easily win a settlement. For instance the proposed
rules set incredibly high standards of eligibility, limits support to
un-named priority watersheds, set two resources of concern as the only
resources of importance, have limited program sign-up periods, and wish
to limit support to an again, un-named set of restricted conservation
practices.
Finally, the benefits of the program outlined in the rule are so limited
that even if one can become eligible for the program it is doubtful that
it would be worth applying. As one major example, the cost-share rates
proposed under the rule are only 5% of the estimated conservation
practice costs. This is unreal considering that other conservation
programs (like the Environmental Quality Incentive Payment Program) that
try to bring farmers and ranchers in compliance with federal
environmental laws will get up to 75% cost-share! Thus a program
supposedly rewarding proven conservation farmers only provides 5% cost
share from the USDA while another government program provides 75% cost
share with no assurance of positive environmental outcomes.
These proposed rules highjack one of the most important new conservation
programs in our nations history. As Senator Gorden Smith, one of the
original sponsors of the CSP relates in recent comments, “ this is too
good a program to shortchange. We have the opportunity to help farmers
in their efforts to protect the environment, and we should be doing all
we can to realize its’ full potential”. While this administration gives
the impression of wanting to make new serious efforts for conservation
in agriculture, when rhetoric meets reality we are left with a
monumental failure of delivery.
Contact Mr. Schahczenski at 406-494-8636 or wsawg@ncat.org | |
