Hi all, This is what I sent to folks in my area. Please read, comment and send to folks in your area.
Merla * * * * * HELP SMALL GROWERS GET USDA SUBSIDIES FOR CONSERVATION--CSP and EQIP Send two emails to [EMAIL PROTECTED] 1. Subject: Conservation Security Program--due by March 10 2. Subject: Environmental Quality Incentive Program--due by March 12 Your comment will be printed in the official record. If many small and mid-sized farmers who retail locally, and their consumers, don’t write and make a direct case for these programs, they will be underfunded, unfunded and changed to only benefit large industrial growers. Some issues cut across all areas of the country and all small and mid-sized farms. The term "resource of concern" is different for different types of agriculture in different parts of the country. You need to let them know that you as an Idaho retail market farmer of some of the highest quality produce in the country are doing significant conservation which is economically and socially important in your community. You want the program to work for a farmer such as yourself. Such management practices as composting,, cover cropping, crop rotations, mulching, compost tea applications, conservation of sparse water resources in drought conditions, use of a gravity-feed watering system and drip irrigation, use of a solar electric system, diverse cropping, use of cold frames and other season extenders, animals integrated into your system, marketing strategies such as CSAs, Farmers Markets, Farmstands, etc., your contribution to your Farmers Market and the Market’s contribution to the community, how you increase profitability with value added products, how you manage your woodlot to heat your home, how you protect your crops from deer, elk, moose, and bears with such things as New Zealand game fences. Get them to make the CSP a conservation program that works for your land and for you. If you need to understand more, there are fact sheets on <www.landstewardshipproject.org> and I have a draft of the CSP comment by Western SAWG and would be glad to forward it to you if you request it. Please take the time to understand this and to make comments about both of the programs. The CSP action notice is from the Land Stewardship Project <landstewardshipproject.org> and the EQIP action notice is from Western Sustainable Agriculture Working Group <westernsawg.org>. Thanks so much, Merla Barberie Farmers Market at Sandpoint Sandpoint, Idaho 208 263-0366 * * * * * >From the Land Stewardship Project URGENT ACTION NEEDED! PUBLIC COMMENT DEADLINE ON CONSERVATION SECURITY PROGRAM IS MARCH 20th 2/28/03 Now is the crucial time to send the message loud and clear: We want a full and quickly implemented Conservation Security Program (CSP)! CSP holds great promise for rewarding farmers based on how they are protecting and improving the environment-and therefore helping us move to a more environmentally sound and sustainable agriculture and food system in theUnited States. The Natural Resources Conservation Service (NRCS) is asking for general input on how to implement the CSP, in the form of an Advanced Notice of Proposed Rulemaking. The letter below is a sample of written comments it would be very helpful to make - please add one or two points of your own, expand on a particular point, or add a personal story or comment. NRCS will accept comments by e-mail or regular mail. Comments from both individuals and organizations are important. Send your written comments by March 20, 2003 to Mark Berkland, Director, Conservation Operations Division, USDA Natural Resources Conservation Service, P.O. Box 2890, Washington, DC 20013-2890. Send your comments by e-mail to [EMAIL PROTECTED] The Sustainable Agriculture Coalition (SAC) has prepared a full set of comments on the Advanced Notice. All groups and individuals are asked to endorse those comments as well. These comments are also available (or will be very soon) at <http://www.landstewardshipproject.org/programs_csp.html> To read the Advanced Notice (there are 15 questions asking for input), go to <http://www.nrcs.usda.gov/programs/farmbill/2002/rules/csp030110.html> or call Mark Berkland at NRCS at 202-720-1845 and ask for a copy to be sent to you. If you have any questions or suggestions, call: Mark Schultz, Policy Program Direction at 612-722-6377 SAMPLE LETTER for WRITTEN COMMENTS on CSP: (NOTE: The sample letter has sections at the beginning and the end in ALL CAPITALS that are notes to you about the letter. Please review the letter and add the information suggested before sending it in to NRCS. Thank you!) RE: Advanced Notice of Proposed Rulemaking for the Conservation Security Program (CSP) published in the Federal Register on February 18, 2003 (Fed. Reg. Vol. 68, No 32, pages 7720-7722). Mark W. Berkland Director, Conservation Operations Division USDA Natural Resources Conservation Service P.O. Box 2890 Washington, D.C. 20013-2890 Dear Mr. Berkland: PLEASE INTRODUCE YOURSELF AND SAY IF YOU ARE A FARMER, CONSUMER, ETC. AND MENTION THAT YOU BELONG TO THE LAND STEWARDSHIP PROJECT (IF YOU DO). IF YOU ARE SUBMITTING THE COMMENT ON BEHALF OF ANOTHER ORGANIZATION, PLEASE INCLUDE A BRIEF DESCRIPTION ABOUT THE GROUP. The Conservation Security Program has the potential to be a very innovative and effective way to achieve excellent land stewardship and a critical new component of U.S. farm policy. I urge you to ensure that the program fulfills its promise. Many of us have waited years for a program such as this, which rewards conservation farmers who have been doing what's right all along and encourages them to do more. Conservation farmers provide many benefits to all Americans in the form of clean air, clean water, habitat and soil protection, and more. This program needs to recognize and reward actual conservation benefits produced by farmers on their farms and provide incentives for farmers to address and solve critical resource problems. I agree with NRCS' statement: "In short, CSP should reward the best and motivate the rest." The Administration should make the Conservation Security Program a major priority. In light of the events that have occurred since the CSP was signed into law by the President last May, I urge you to: 1. Accelerate the rule making process and launch the CSP in time to allow for significant enrollment opportunities in fiscal year 2003. The statutory deadline for writing rules to implement the CSP has already passed. 2. Ensure immediate implementation on a comprehensive, nationwide basis. The CSP is intended for all regions of the country and all types of agriculture. 3. Uphold and defend CSP's status as a conservation entitlement program, as the law requires. Once producers meet the requirements for approval of an effective and meaningful conservation plan, they should be enrolled in a contract-no delays, selection processes, bidding systems, or waiting lists. 4. Require strong conservation and environmental standards, and reward strong environmental performance. Positive environmental outcomes achieved by innovative producers should be a major objective of the CSP, more than funding specific practices with little emphasis on outcomes. 5. Retain the real payment limitations required by the law that was passed by Congress, signed by the President, and supported by the American people. No loopholes or exceptions should be enacted via regulation, manual, or practice. Enforcement of the limitations should be strict. We must not allow CSP to become a handout of hundreds of thousands of dollars to individual producers. 6. Support restoration of full funding. The recently signed omnibus appropriations bill caps the CSP at $3.77 billion through 2013. We urge you to give strong support to the bipartisan Senate leadership commitment to remove this cap in upcoming legislation and restore the program to its full 2002 Farm Bill funding. I (or OUR ORGANIZATION NAME) would also like to support the detailed comments submitted in response to the Advanced Notice of Proposed Rulemaking on behalf of the Sustainable Agriculture Coalition. I concur with their answers to your questions and endorse their recommendations. Thank you for the opportunity to comment. I look forward to watching the program as it develops. Sincerely, YOUR NAME AND ADDRESS (AND ORGANIZATION, IF RELEVANT) HERE * * * * * >From Western SAWG URGENT! ? ONLY 30 DAYS TO SEND IN PUBLIC COMMENT TO SAVE THE INTEGRITY OF THE EQIP PROGRAM MASSIVE PUBLIC RESPONSE NEEDED TO STOP ABUSE AND GET REAL CONSERVATION BENEFITS Send comments to: Mark W. Berkland, Director, Conservation Operations Natural Resources Conservation Service, USDA 400 Independence Ave. SW, Room 5241 Washington, DC 20250-2890 Or to Mark W. Berkland via the internet by going to www.nrcs.usda.gov and then submitting comments to [EMAIL PROTECTED] The proposed rule itself can also be accessed at the same website. ALL PUBLIC COMMENT MUST BE RECEIVED BY MARCH12th ACTION: Write to Mark Berkland and tell him you are providing comments on the proposed rule for the Environmental Quality Incentives Program (EQIP) that appeared in the Federal Register on February 10, 2003. Make some or all of the points made in the 4 bulleted ‘action’ sections that follow. Add any additional points you care to make. Remember, the 2002 Farm Bill provides EQIP with $11.6 billion over the next 10 years, making it the second largest agricultural conservation program in history. And 60% of these funds are targeted to livestock. When this rule is finalized, it will have the force of law and will set EQIP policy for many years to come. Please respond today and encourage others to send in comments as well! Thank you for taking action and submitting comments! Each additional response puts USDA and the Administration on notice that the public is demanding major changes to the proposed rule to support family farms and real environmental benefits. SAMPLE LETTER: Dear Mr. Berkland: [PLEASE INTRODUCE YOURSELF AND SAY IF YOU ARE A FARMER, CONSUMER, ETC. AND MENTION ANY AGRICULTURAL GROUPS YOUR BELONG TO. IF YOU ARE SUBMITTING THE COMMENT ON BEHALF OF AN ORGANIZATION, PLEASE INCLUDE A BRIEF DESCRIPTION ABOUT THE GROUP.] STOP FUNDING ENVIRONMENTALLY RISKY CAFO EXPANSION The Environmental Quality Incentives Program (EQIP) should first andforemost be an environmental quality program, not a program to subsidize production, expansion, or equipment purchases. Large Confined Animal Feeding Operations (CAFOs) have a long history of severe air and water pollution and animal and human health problems. CAFO expansion and consolidation also places family farm livestock producers at risk. Tragically, the proposed rule does nothing to prevent EQIP from becoming an environmentally and economically harmful subsidy program encouraging CAFO expansion and overproduction at the expense of the environment and family farms. Specific actions include: • Amend the rule by adding new language to the Section 1466.10, the section dealing with "conservation practices" that would: • Prohibit EQIP payments to new and expanding large-scale Confined Animal Feeding Operations (CAFOs). There should be no payments to build new CAFOs, expand AFOs to CAFO size, or expand existing CAFOs. EQIP should be an environmental quality program, as its name implies, not a subsidy to encourage overproduction of animals and increased environmental risk. • Prohibit EQIP payments to CAFOs located in floodplains, unless the funding is to help them move out of the floodplain. EQIP should not spend taxpayer money on accidents waiting to happen in environmentally-sensitive areas. • Direct State-level NRCS officials to develop funding allocation and application ranking criteria that give top priority for EQIP assistance for livestock operations to sustainable practices such as managed rotational grazing, pasture and range management, hoop houses, composting and other environmentally-sound alternatives to large-scale animal factories. DON’T FOCUS FUNDING ON THE BIGGEST, WORST, OR MOST EXPENSIVE The EQIP "application ranking system" at the state and local levels determines which producers and which conservation systems and practices get priority access to EQIP dollars. The proposed rule (at Section 1466.20) directs states to rank proposals based on use of: cost-effective practices; magnitude of environmental benefits; treatment of multiple resource concerns; longer-term environmental enhancement; compliance with regulatory requirements; and other locally defined factors, including the extent of natural resource degradation. On the surface, these criteria sound reasonable. However when these criteria are made operational at the state and local level these ranking criteria can, and often do, result in the largest agricultural operations being favored over small and moderate-sized farm, capital-intensive approaches being favored over lower cost management-intensive and integrated farming systems approaches, and environmentally-flawed technologies being favored over sustainable methods. In addition to these potential problems with ranking criteria details, the proposed rule also does direct, outright damage to the application selection process -- it specifically prohibits states from choosing to fund those EQIP projects that achieve environmental values at lower cost relative to other approaches. This misguided provision will all but ensure that the largest farms or the most capital intensive approaches will win out. Why is this perverse directive in the proposed rule? The 2002 Farm Bill corrected an earlier EQIP rule problem that in some cases resulted in larger or wealthier farms or ranches outbidding smaller operations simply by agreeing to lower cost share rates for a given conservation practice. Regrettably, rather than simply prohibiting competition based on acceptance of lower than prescribed cost share rates for a particular practice, the new proposed rule makes a completely erroneous interpretation of this positive, pro-small and medium-size farm provision in the law by declaring that cost can in no way be a consideration in evaluating contract offers and payments. In so doing, it turns the law completely on its head, once again giving the biggest contracts and most expensive practices the winning hand. Specific comments include: • Rewrite the ranking system factors (Section 1466.20(b) of the proposed rule) to prioritize the best solutions, not the biggest problems. Throwing money at problems does not necessarily make the problems go away. Instead, the ranking factors should explicitly reward sustainable practices and exceptional performance. • Insert new language into Section 1466.20 (b) to ensure the application ranking systems cannot and will not discriminate against small and moderate-sized family farms and ranches. Large operations should not be allowed to come out on top in the competition for EQIP dollars solely because of their size. • Eliminate language (Section 1466.20(c) in its entirety) that prohibits states from prioritizing the lowest cost approaches to achieving environmental benefits. This prohibition contradicts the law (which specifically accords a higher priority to cost-effective practices) and does a disservice to innovative farmers and ranchers and to the taxpayer. Cost effectiveness should in fact be a primary consideration in both ranking offers and setting payment rates for conservation practices. Section 1466.20(c) should be rewritten to simply prohibit the use of competition bidding based on payment rates. REVERSE DECISION TO ELIMINATE CONSERVATION PLANNING It is shocking that the proposed rule runs completely contrary to the Natural Resources Conservation Service’s historic approach to conservation and to its own national policy, by eliminating the conservation planning requirement from EQIP. Gone from the rule that guided EQIP from 1996-2002 are provisions to: develop a conservation plan for the farm or ranch; assess farm enterprises and operations with respect to natural resource concerns; incorporate soil maps, water and habitat locations, and other resource characteristics; focus on the most cost-effective practices to solve identified problems; and strive for plans that help the farmer achieve "resource management system" or sustainable use levels. In its place, the proposed rule provides for an "EQIP plan of operation" that focuses just on the immediate practice(s) to receive EQIP funding, in isolation from any sound conservation planning process. This virtually eliminates any means of evaluating whether the proposed practices fulfill the statutory mandate to optimize environmental benefits and promote cost-effective conservation systems and practices. Specific actions include: Amend Section 1466.9 to: • Restore all of the conservation planning language from the 1996 EQIP rule. NRCS should not surrender its most basic, historic approach to conservation in the name of expediency. • Reinstitute a provision to encourage "progressive planning" toward a "resource management system" level of conservation to ensure sound minimum standards will be retained in EQIP. (Note: "Resource management system" is the NRCS term for a plan that solves resource problems and reaches the sustainable use level. "Progressive planning" is the NRCS term for working toward the ultimate RMS objective even if it is not immediately achievable.) IMPROVE PUBLIC ACCOUNTABILITY The proposed rule makes several potential improvements in program accountability. It establishes national EQIP priorities for water and air quality, soil erosion, and wildlife habitat (Section 1466.4) in order to guide allocation of dollars and guide annual reviews of program effectiveness. The proposed rule continues the old EQIP system of allocating dollars to states based on the size of their agricultural sector and the extent of their resource problems, but also establishes a new, secondary system of allocating EQIP dollars to the states by providing "incentive awards" to those states with high levels of effectiveness (Section 1466.5(b)). In addition, the rule proposes to use an "Integrated Accountability System" (Section 1466.5(c)) to establish state performance goals and to make national, state and local implementation information available to the public electronically (Section 144.5(d)). These improvements, if thoughtfully developed and expanded in scope, have potential for improving the accountability and effectiveness of the program. Specific actions include: • Retain the "incentive award" provision (Section 1466.5(b) in the final rule and urge that a very substantial share of total EQIP dollars be reserved for this secondary allocation system based on results and performance. • Add new language in Section 1466.5 to declare NRCS’s intent to move toward assessment, evaluation, and accountability based on actual natural resource and environmental outcomes and results, not just bean counting numbers on contracts, acres, and practices enrolled. • Add new language in Section 1466.5 to direct that all information about spending and practices be reported by farm, not by contract or any other method that prevents the public from knowing how much total funding was received by an operation and for what practices. A single farm operation can have multiple EQIP contracts, so reporting by contract, as has historically been the case, misrepresents the size of EQIP payments to individual operations. Sincerely, [YOUR NAME, title}
