Dear USDA: Here's our thoughts on farm bill implementation

Farm and Food

In February, we submitted comments to the U.S. Department of Agriculture in response to "2018 Farm Bill Implementation Listening Session," Federal Register notice 84 FR 4041, published on February 14, 2019. Below is the text we submitted.

The 2018 farm bill contains several important changes for the U.S. Department of Agriculture (USDA) programs administered by the Farm Service Agency (FSA), the Risk Management Agency (RMA), and the Natural Resources Conservation Service (NRCS), and we thank Secretary Bill Northey for providing this opportunity to provide public comment on these changes. The below represents comments on farm bill implementation from the Center for Rural Affairs, but we hope that these comments are the beginning of a conversation with USDA about the 2018 farm bill rather than the end.

The Center for Rural Affairs is rooted in and advocates for healthy, vibrant rural communities, and we know the strength that diverse economic opportunity can provide to rural communities. Specifically, we have seen the important role that strong conservation and access to diverse markets can play for farmers and ranchers. We are pleased to have the opportunity to comment on implementation of the 2018 farm bill and the ways in which it can foster this opportunity for family farmers and ranchers. We begin with a few general comments, followed by responses to the questions specifically outlined by USDA.

We consulted several supporters and staff to draft these responses, and in addition to the specific feedback about particular programs below, we also heard the repeated message that soil health must remain a priority for USDA. Healthy soil allows for greater resiliency to extreme weather and improves both water quality and retention, and can help reduce input costs. But the practices that build soil health—such as planting cover crops, implementing resource-conserving crop rotations, or intensively managed rotational grazing—require farmer and rancher investments of time and funds. USDA conservation programs offer a crucial piece in that puzzle, and we urge all USDA officials to prioritize soil health as you proceed with implementing the 2018 farm bill.

We also urge you to start the sign up periods for conservation programs, particularly the Conservation Stewardship Program, as soon as possible so that farmers and ranchers can incorporate their support into their plans for the coming year. Also, as you move forward with the 2019 sign up for the Conservation Stewardship Program, we ask you to please incorporate the clear changes from the farm bill for increased payments for cover crops and resource conserving crop rotations prior to the release of an interim rule for the 2020 sign up.

Below are our responses to several of the questions posed in Federal Register Notice titled “2018 Farm Bill Implementation Listening Session,” as well as select general comments for each of the agencies. These comments have been drafted with input from several of the supporters and staff of the Center for Rural Affairs; we are deeply grateful for their input.