NCGA
Comments on Interim Final Rule for CSP (10-06-04)
National Corn
Growers Association (NCGA) President Leon Corzine sent a letter
Oct. 5 to Craig Derickson, Conservation Security Program (CSP) manager
at the Natural Resources Conservation Service (NRCS), commenting
on the Interim Final Rule for CSP and expressing comments on the
sign-up process experience of two corn growers accepted into the
program this year.
NRCS published
an Interim Final Rule for CSP on June 21, (69 FR 34502). Deadline
for comments was Oct. 5.
In his letter,
Corzine said NCGA was disappointed with the rule in previous comments
to NRCS because it did not meet corn grower expectations and that
corn growers anticipated the proposal would create unnecessary difficulties
for those attempting to participate in the program.
NCGA supports
the watershed approach for the early years of the CSP program, his
letter continues, stating NCGA’s main concern is that the
program gets off to a meaningful start, that it must work for farmers
and that it should demonstrate a commitment to conservation. “It
is in the best interest of farmers and the agency to get it right
from the beginning,” said Corzine.
A commitment
to conservation by farmers and producers should parallel a commitment
by NRCS staff to help those involved clearly understand the program
and its application process, Corzine continued. NCGA commended NRCS
employees on their efforts to make the process easier for farmers
who wanted to apply, however urged the agency to educate the NRCS
staff on the oversight necessary to ensure only qualified candidates
were enrolled.
“While
NCGA appreciates the clarification of eligibility requirements in
the interim final rule, corn growers continue to be concerned about
this issue. NCGA does not believe NRCS recognizes the trend toward
renting,” said Corzine. “Today, very few farmers have
control of all the land they farm for the five to 10 years envisioned
by CSP.”
Additionally,
the letter cites that growers who signed up for the program feel
large amounts of land may not be involved in the CSP program. “Our
growers found that they had to enroll smaller acreages in order
to meet the program requirements, even if they farmed rented land
that met the requirements,” said Corzine.
In general,
corn growers reported that the application process, including the
benchmark inventory, did not hinder participation in the program.
NCGA urged the agency to continue to focus on the many benefits
of this program and not on the potential work involved in applying.
The letter concluded:
“NCGA strongly encourages NRCS to ensure only eligible acreages
are enrolled in CSP. NCGA supports the motto of Reward the Best;
Motivate the Rest. If some farmers have attempted to use CSP for
other reasons, they will only hurt the program, the agency and other
farmers. Corn growers ask NRCS to conduct the appropriate and necessary
oversight to preserve the integrity of the program.”
CSP is a voluntary
program that provides financial and technical assistance to promote
the conservation and improvement of soil, water, air, energy, plant
and animal life, and other conservation purposes on Tribal and private
working lands. Working lands include cropland, grassland, prairie
land, improved pasture, and range land, as well as forested land
that is an incidental part of an agriculture operation. The program
is available in all 50 States, the Caribbean Area and the Pacific
Basin area. The program provides equitable access to benefits to
all producers, regardless of size of operation, crops produced,
or geographic location. CSP is administered by USDA's Natural Resources
Conservation Service (NRCS).
The Interim
Final Rule may also be accessed via the Internet through the NRCS
homepage, at http://www.nrcs.usda.gov,
and by selecting Programs. All comments, including names and addresses
when provided, are placed in the record and are available for public
inspection.