The Public Comment Period Deadline for the Amended Interim Final Rule for the Conservation Security Program has been extended from Monday, July 25 until Friday, September 9, 2005. The extension notice was posted in the Federal Register Tuesday, July 19.

The Sustainable Agriculture Coalition (SAC) requested an extension after learning that the USDA email address to file comments electronically had not been working and that the U.S. mail address provided in the Federal Register was incomplete. NRCS has stated that they hope to have the electronic address back up and working soon.

The USDA Natural Resources Conservation Service (NRCS) is once again requesting public comments on the rules for the Conservation Security Program (CSP). The amended Interim Final Rule is a slight variation of the Interim Final Rule issued in the spring of 2004. Neither version of the rule contained important program changes requested in thousands of public comments previously submitted.

All stakeholders, especially those with direct experience with the program such as farmers, organizations, and conservation professionals, are encouraged to submit comments on the current rules. It is time to sit down, take an hour out of your day, and submit input about the changes needed in CSP. Identify yourself, describe your organization or farming operation, and explain your experience with the Conservation Security Program. Comments may be long or short, and they may address one or many aspects of the CSP rules. Every part of the rule is open for comment.

Send comments by September 9, 2005 to:

• FarmBillRules@usda.gov, Subject: Conservation Security Program
• OR, by mail to Financial Assistance Programs Division, NRCS, P.O. Box 2890, Washington, DC 20013-2890
• OR, by fax to: (202) 720-4265
• OR, review and comment via the Federal Government's centralized rulemaking Web site at www.regulations.gov

Suggested Points

1. Enhancement payments for existing practices should be restored to full payments, without declining, variable rates. This new provision punished farmers who were already doing excellent conservation by phasing out their payments. Also the cap on enhancement payments should be removed because it limits new improvements farmers may want to make.
2. Expand the list of enhancements to reward resource-conserving crop rotations as well as all the other purposes enumerated in the CSP law.
3. Change eligibility barriers into performance expectations. High enrollment standards for conservation are laudable — but farmers should be allowed to meet those standards in the first year of their CSP contract, not be excluded from CSP.
4. Eliminate enrollment categories because the statute prohibits ranking of eligible applications. Instead, strict performance standards should be the “brake” used to keep enrollment matched to available funding. If enrollment categories are retained however, Tier 2 and 3 applications should be ranked on the category of their best acres, not their worst acres, so Tier 1 applications do not have an unfair enrollment advantage.
5. Provide nationwide, continuous enrollment. Drop watershed selection and limited signup periods which have posed staggering problems for farmers and staff who must cope with enormous amounts of work to implement CSP in a few short weeks, only to have the program disappear for another eight years in their watershed.

For more information go to www.mnproject.org/csp.