1. Specific ideas to simplify program implementation and enhance customer service.
Several of the staff at the Center for Rural Affairs work directly with beginning, Latino, and veteran farmers. Often, they have found that these farmers hold full-time jobs and have difficulty getting the time off needed to visit FSA or NRCS field offices during business hours. This can effectively exclude them from accessing FSA and NRCS programs. We urge you to institute a more flexible schedule for field offices in order to better serve more diverse farmer and rancher populations. This comment is repeated under the similar question for FSA program delivery.
On a related note, our supporters have also shared with us that NRCS field offices often struggle with high workloads for the staff they have. We encourage NRCS to conduct internal reviews to assess workloads of field staff, and make this information public.
We would also like to share a few general comments. On-farm conservation and risk-management strategies need to be outcomes-based, and work best for farmers and ranchers when they are not reliant on boilerplate solutions that may not be either applicable or affordable in different locations or on differing operations. We ask NRCS to build and strengthen your human resources capacity so that technical staff have more flexibility to work closely with producers to develop conservation plans and projects geared to the goals and capabilities of the operator while still achieving the desired conservation outcomes. We also encourage NRCS management to help field staff balance workloads in order to get out of the office more and share their incredible expertise at outreach events and activities.
Our supporters have shared with us that in their experience, NRCS often exhibits a mindset of building a fix for a conservation problem (such as building terraces, waterways, or filter strips) rather than addressing the underlying causes of erosion and degradation caused by management practices. We encourage NRCS management incorporate this more flexible approach into their planning and training activities.
3. Mechanisms to improve the targeting of financial resources to address resource concerns.
One of the main barriers that NRCS faces in targeting financial resources to address resource concerns is that NRCS does not conduct evaluation of the conservation impacts of practices in any significant way. Standing up pilot projects that allow for this evaluation will provide data that would be incredibly useful in helping NRCS to target their activities.
We also encourage NRCS to increase their collaboration with Extension researchers to enhance the research focus and program implementation of each agency.
4. The 2018 farm bill introduced a new incentive contract enrollment option for the Environmental Quality Incentive Program that provides for practice installment and annual payments. How should the Environmental Quality Incentive Program and the Conservation Stewardship Program be used in conjunction with each other to prevent overlap and improve opportunities for producers to address resource concerns?
The Center for Rural Affairs has been a long-time advocate for working lands conservation programs that allow farmers and ranchers to enhance conservation on their operations while still maintaining production. The Conservation Stewardship Program provides an invaluable avenue for farmers and ranchers who are already committed to conservation practices to improve and increase their conservation efforts to address targeted resource concerns across their whole operation. In contrast, the Environmental Quality Incentive Program offers farmers and ranchers the ability to take on or install conservation practices on a case-by-case basis, and does not include a consideration of the resource concerns and opportunities of the whole operation.
The Environmental Quality Incentive Program is a valuable tool for farmers and ranchers to assist them in increasing their conservation activities on their operations, and ultimately help them become eligible for Conservation Stewardship Program. In this “on-ramp” scenario, incentive contracts under the Environmental Quality Incentive Program can provide a valuable stepping stone to help producers reach the eligibility threshold for the Conservation Stewardship Program. We ask NRCS to set up smooth processes to allow farmers and ranchers to move from Environmental Quality Incentive Program to Conservation Stewardship Program contracts.
In implementing the new incentive contracts under the Environmental Quality Incentive Program, we also encourage NRCS to work to ensure that these are implemented with producers’ future participation in the Conservation Stewardship Program in mind. This should include coordination of sign-up periods, timelines, and outreach. We also encourage NRCS to allow for a no-penalty early termination of an Environmental Quality Incentive Program incentive contract if a farmer or rancher wishes to transition to the Conservation Stewardship Program and is eligible to do so.
Finally, we encourage NRCS to promote management practices through the incentive contracts. In contrast to contracts that support structural improvements, contracts that support management practices provide a safety net for farmers and ranchers to climb the conservation practice learning curve, which they might not otherwise have the flexibility to do. Incentive contracts that support management practices will provide a path for more farmers and ranchers to incorporate conservation management practices on their operations long-term.
6. Both the Conservation Stewardship Program and the Environmental Quality Incentive Program have provisions for organic producers. How should the programs be used to maximize service to producers while avoiding overlap and competition between the Conservation Stewardship Program and the Environmental Quality Incentive Program?
We have a few general comments to offer to improve NRCS program delivery to organic producers. First, we encourage ongoing education to NRCS field staff about the scope of organic production and the number of certified organic producers in their state. We also encourage NRCS to consider the unique approaches to conservation that the Environmental Quality Incentive Program and the Conservation Stewardship Program offer—i.e. the comprehensive nature of the Conservation Stewardship Program and the targeted practices of the Environmental Quality Incentive Program—and ensure that each program extends these services to organic producers. Finally, we encourage NRCS field staff, when setting up Conservation Stewardship Program and Environmental Quality Incentive Program contracts with organic producers, to consider the particulars of a producers’ existing organic management plan. For example, often organic management plans are designed to preclude the need for fertilizer application, and instead build fertility through crop rotation and residue management. In these cases, Environmental Quality Incentive Program and Conservation Stewardship Program contracts for organic producers that address fertilizer management should account for the particulars of the producers' organic fertility management plans.
Other NRCS topics
The Center for Rural Affairs has many supporters who are farmers devoted to enhancing conservation on their operations. These farmers have shared with us time and again that they are concerned that the NRCS process to conduct spot checks on producers who manage Highly Erodible Land and wetlands is ineffective. Many farmers and ranchers violate the terms of their required conservation plans and mistreat these sensitive areas, and the threat of the NRCS spot check is not an adequate deterrent. However, neighbors are very reluctant to turn in neighbors who are violating plans. We ask USDA to take action to improve their administration of spot checks in order to create a more effective deterrent for mistreatment of sensitive lands.
Specifically, we ask USDA to speedily address the recommendations in the USDA-OIG report 50601-0005-31 in order to standardize the spot check procedures and counts across state boundaries. We ask that USDA take particular care to ensure that the spot check rate of 5 percent be implemented by state, rather than nationally. We also ask USDA to increase their outreach about the purpose and importance of the spot check process, and to assign spot check responsibilities in a county to NRCS staff who do not personally reside in that area.