CSP Review Report_Final (1)

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December 2015 Conservation Stewardship Program (CSP) Review Report By Rex Dufour, Western Regional Office Director, National Center for Appropriate Technology (NCAT); and Eric Cissna, Kelly Damewood, and Jane Sooby, California Certified Organic Farmers (CCOF)

Transcript of CSP Review Report_Final (1)

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December 2015

Conservation Stewardship Program (CSP) Review Report

By Rex Dufour, Western Regional Office Director, National Center for Appropriate Technology (NCAT); and Eric Cissna, Kelly Damewood, and Jane Sooby, California Certified Organic Farmers (CCOF)

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I. IntroductionCalifornia leads the country in agricultural production, particularly specialty crops and certified organic acres, but ranks far behind many other states in number of acres enrolled in the Natural Resources Conservation Service’s Conservation Steward-ship Program (CSP). From 2009-2014, California enrolled 972,000 acres, ranking 22nd in the country, while the top-ranking states enrolled upwards of 3.5 to 5.5 million acres. Historically, organic grower enrollment has been very low throughout the state; however in 2015, CSP organic acreage in California jumped considerably, from 4,969 to 32,643 acres.

Fiscal Year Type of Contract

Number of Contracts

$ amount of Contracts

Acres under Contract

Counties

2014 New 23 $673,870 57,533 Colusa, Glenn, Marin, Modoc, Mon-terey, San Bernardino, San Joaquin, Siskiyou, Sonoma, Stanislaus, Sutter, Tehama and Tulare

2015 Renewal* 110 $2,023,940 277,444

2015 (projected)

New 34 $631,864 124,000 Alameda, Amador, Butte, Glen, Hum-boldt, Imperial, Lassen, Monterey, Placer, Plumas, Riverside, San Luis Obispo, Santa Barbara, Shasta, Siski-you and Tehama

* initial contracts obligated in 2010. CSP contracts run for five years.

The NRCS intends a major revamp of CSP for the 2017 sign-up period, which provides an important opportunity for vital feed-back. NRCS hopes to increase accessibility and make the program more farmer-friendly.

To leverage this opportunity, CCOF partnered with the National Center for Appropriate Technology (NCAT) to identify bar-riers farmers face throughout the CSP enrollment process and the lifetime of the CSP contract with the ultimate goal of recom-mending improvements in CSP to NRCS. CCOF developed information from the farmer point of view and NCAT developed information from the NRCS field staff point of view.

ContentsI. Introduction ................................................................................................................2

II. Common themes ......................................................................................................3

III. NRCS Field Staff Perspectives ..............................................................................3

IV. Organic Farmer Perspectives .............................................................................5

Appendix 1. NRCS Staff Survey Questions ............................................................8

Appendix 2. Summary of Responses to Questions ............................................8

NCAT would like to thank all the Natural Resources Conservation Service (NRCS) employees who helped with providing content for this report, particularly Alan Forkey and the field staff who took time out of their very busy schedules to respond to these questions.

NCAT and CCOF would like to thank the National Sustainable Agriculture Coalition (NSAC), which provided funding to make this report possible.

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II. Common themesBoth NRCS field staff and organic farmers that CCOF surveyed agreed on four general themes.

1. The complex application procedure is a disincentive for both farmers and for field staff.

2. The program is inflexible. It is difficult to amend contracts, contract length is too long for some producers, and the require-ment that all of a farm’s acreage be enrolled in CSP causes logistical problems for farmers who lease farmland.

3. Small farms are unlikely to apply for CSP because allocating funds on a per acre basis provides little incentive for them to participate.

4. Highly diversified and organic farms experience a number of disincentives to signing up.

Please note that suggested improvements to address issues raised by these 4 themes are noted in Sections III and IV.

III. NRCS Field Staff Perspectives

ApproachNCAT staff developed six questions relating to CSP use and implementation that were sent to 16 NRCS field staff, most of whom work as District Conservationists (DCs) and a few of whom work as Soil Conservationists or Engineers for NRCS. See Appendix 1 for the list of questions.

In three instances, extended phone conversations were held with NRCS field staff to drill down into details of implementation, obstacles, and possible improvements. For 10 of the responses, NCAT staffer Rex Dufour sent out questions to NRCS staff. Alan Forkey (NRCS/CA Assistant State Conservationist for Programs) emailed the questionnaire on behalf of Rex Dufour, resulting in six additional responses.

Summary of FeedbackSee Appendix 2, Summary of Responses to Questions, for a verbatim summary of field staff answers to these questions.

From the responses received, CSP is not a popular program with nearly all the field staff surveyed, and is also not a popular program in their respective counties among farmers. Only four staff in four locations out of the 16 surveyed had any positive comments about this program.

There were many different reasons provided as to why CSP is not popular with field staff and they can be distilled down into the following themes, some of which overlap. Under each theme is a suggested “improvement.” These improvements are not termed “solutions” because they likely won’t “cure” or “solve” the problem but these suggestions provide some ideas and directions to improve the program. These ideas were suggested by NRCS staff or they were implied by NRCS staff responses.

1. Complexity of the Program. It’s too complicated for the farmers, and it’s too complicated for field staff. A couple staff noted that there was little mandatory training provided by NRCS about CSP. The CMT (Conservation Management Tool, which is used to rank applications) for cropland consists of 12 pages of detailed questions requiring a fair amount of documentation on the farmer’s part as well as significant time on the part of field staff to inspect the farm on the front end and review documents—all for a relatively low payment. The CMT for rangeland is shorter (only six pages of questions).

The application requires a lot of preliminary paperwork/field work for relatively low return to farmer (and, several staffers noted, a low “conservation bang for the buck”). This is a burden on both farmers and field staff.

Suggested Improvements

a. “Simplify” the CSP application and review process, especially for cropland.

b. Provide additional staff to work on CSP and staff training about how to efficiently use the CMT and how enhancements an bundles can be used to support good conservation. Field staff need to be better incentivized to promote and use the program. Develop a simpler application process which supports conservation “bang for the buck” by better prioritizing practices which increase soil health and function, water use efficiency, and support biodiversity.

c. Another option would be to do away with CSP and target the funds to EQIP conservation programs.

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2. Inflexibility of the Program. Several NRCS staff noted that making changes or amendments to contracts is difficult, and the contracts are generally too long. Most landowners would prefer “bite-sized” contracts of two to three years (CSP contracts run five years). Also, several staff noted that all of a landowner’s land must be enrolled into the program, and it’s difficult to accurately quantify and characterize (and therefore qualify) a large farm’s acreage.

Another staffer commented that one farm cannot have both CSP acreage and EQIP acreage, which reduces the options of apply-ing both programs.

Another staffer had questions concerning one farmer leasing multiple parcels from different landlords, saying “Another reason it’s not so popular in rangeland is you have to include all the land you control in the application. When you have lots of leases and different landowners, it’s tricky. Also one property might not qualify and puts you out of the program.”

Suggested Improvements

a. Provide an option for two to five year contracts.

b. Provide for the option of enrolling a given farm’s acreage into more than one program. Especially with larger acreages, there are often some parts of the land with resource concerns that could better be addressed through EQIP rather than through CSP. Consider allowing both programs on a particular acreage.

3. Challenges for smaller acreage farms. Since nearly all enhancements are acreage-based, there is not much to offer smaller landholders. This is a systemic problem, particularly when combined with the low payment rates and time requirements for both NRCS staff and farmers to complete an application. Though perhaps suitable for larger acreages, some questions on the CMT are very difficult to answer for the extremely diversified rotations used by many smaller organic farmers, with dozens of crops planted in one year.

Several staff noted that the relatively low payment rates for enhancements are unattractive to farmers, particularly for smaller-acreage farmers. Combined with the up-front investment of time required by busy NRCS staff (not to mention the farmer’s time) to enroll farmers in the program, the program doesn’t receive enthusiastic support among most NRCS staff.

Suggested Improvements

a. Increase payment rates for enhancements, or provide increased payment rates for a “bundled” selection of enhancements.

b. Include a “bundle” specific to organic production systems.

c. Provide a minimum payment for smaller acreage farmers.

4. Not well suited to California’s complex rotations or organic farms. CSP is not very well suited to cropland in California. The first two questions in the 2013 CMT document under ”Cropland Existing Activity Conservation Performance/Rotation and Adjacent Habitat Information” are specifically geared to low-diversity rotations typically found in the Midwest. Though perhaps suitable for larger acreages, some questions on the CMT are very difficult to answer for the very diversified rotations used by many California and smaller organic farmers, with dozens of crops planted in one year.

Also in this vein, a couple of staff noted that they think the CMT does a fair job of functioning as a ranking tool, but because it is designed to be used nationwide on all crops, the questions had to be watered down to the point that many of the questions are quite general and the categories are very broad, which may not be conducive to supporting good conservation.

Suggested Improvements

a. NRCS could develop an application more suited to typical California cropping systems and rotations; for example, an application specific to perennial cropping systems such as vineyards and orchards.

b. Develop various “flavors” of CSP application forms which apply to different types of cropping systems and crops grown in California. Any application processes that specifically target very diverse rotations or use of CSP in perennial crop- ping systems would likely have multi-state applications (for example, if a CMT-type tool/application were developed for perennial crops, it could be used in California, Florida, Texas, Oregon and Washington). Perennial cropping systems may need to have their own CMT form because of their unique differences compared to both annual cropping systems and rang land.

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IV. Organic Farmer Perspectives

ApproachCCOF interviewed and surveyed organic growers who have experience with CSP. Seven growers responded to CCOF’s sur-vey. Many of them provided written answers to open-ended ques-tions about their experiences with CSP. CCOF also researched a range of reports and literature on the program.

The themes which emerged from their responses echoed those identified by NRCS field staff.

1. Application process is a challenge

Many farmers continue to view the current application process as daunting, time consuming, and not worth their effort. This can be a barrier to enrollment, as farmers will avoid applying for CSP because of these issues. The CSP application process still has room to be simplified. (Note: The assistance of NCAT and the NRCS is needed to determine areas of the application that can be streamlined).

The application process itself posed a challenge to both farmers and, in some cases, to NRCS staff. “The sign up process needs to be more streamlined and clear,” wrote one farmer.

“The CSP paperwork is daunting, more so for the NRCS employee than the farmer. If the farmer can sit through about one to two hours of questions from the NRCS, and can make up his/her mind about installing additional conservation practices, the rest of the paperwork is not too bad,” commented another.

“It seemed like I was learning about the program along with the office administering the program,” observed another.

Some, though, had a positive experience with NRCS staff: “Knowledgeable staff made the process easy in my county,” wrote one. Another reported, “The staff helps you step by step, you’re made to feel welcome and the process is fairly simple.”

Suggested Improvement

Further streamline the application process in order to make it as easy for applicants to apply as possible. Remove unnecessary steps that have proven to be burdensome.

2. Inflexibility of the program poses challenges

The five-year CSP contract requirement is a significant barrier in many regions of California, particularly where leases are short and fewer owner operated family farms exist. Farmers who do not own the land that they farm are often on leases for less than five years. Since the farmer will not control their land for the duration of the five-year contract period, they are ineligible to enter into a CSP contract with the NRCS unless an agreement is made with the landowner. This excludes farmers who could be eli-gible for CSP from applying solely based on the fact that their lease is less than five years long.

The ownership requirement was a barrier noted by some farmers. “Both [CSP and EQIP] have the ownership requirements which can be tough (and I don’t see any way around them).”

Farmers who lease or rent land may face difficulties in convincing their landlord to participate in conservation programs. A grower commented, “I have one parcel that I cannot enroll in the program because the landowner refuses to be in a government program.”

Another noted, “The company owners do not believe in government subsidies of any kind.”

Suggested Improvements

a. Create a two-year contract option in addition to the five-year option. The two-year contract option would allow farm- ers who are on a shorter term lease to enter into a CSP contract and take advantage of CSP payments for their conserva- tion activities.

b. Tenant farmers need more flexibility in contract terms. Contracts should not be outright cancelled or nullified if leases change or evolve during the lifetime of the five-year contract.

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3. CSP is a better fit for large rather than small farms

As CSP payments are partly determined by acreage, farms with small acreages do not receive the same pay-off as farms with larger acreages, making the program less attractive for farmers with smaller acreages. A large farm with 1,000 acres will receive a much higher payment than a smaller farm with 10 acres, while the cost of implementing and maintaining many conservation activities does not necessarily increase with a rise in acres. CSP payments below $1,000 per farm do little to incentivize enroll-ment in the program.

CSP does not seem as suited to smaller-scale producers as EQIP is because the payments are made on a per-acre basis. Com-mented one farmer, “If you are an organic farmer like I am (2 acres), the amount of paperwork far exceeds the benefit of a few dollars of cost sharing.”

Similarly, another farmer observed, “It is currently paid by performance points per acre, so the big farms with couple enhance-ments get big payments, whereas my small farm had to have 10 plus enhancements for small payment amount. Should be a flat rate per farm not acres.”

One experienced grower tried CSP but found that the time and effort weren’t worth the small amount it paid him.

Suggested Improvements

a. CSP should have a minimum contract payment between $1,500 and $2,000 per farm in order for the program to pay off for smaller acreage farms.

According to the most recent USDA Census of Agriculture (2012), the median size farm in California is 20 acres, implying that most farms reside on the smaller end of the acreage spectrum in the state. This minimum payment will make CSP payments more effective for smaller farms. This, in turn, should increase the enrollment of smaller acreage farms as they would be the ones taking advantage of the minimum payments.

b. A sliding scale incentive for smaller farms could be utilized as well. To make up for smaller acreage farms receiving less money, the CSP payment rate could be implemented on a sliding scale based on acreage. As a given farm’s acreage decreases, the payment rate should increase slightly. This would further make CSP worthwhile for smaller acreage farms.

4. CSP is not well-suited to many organic farms

There are a number of reasons why organic farmers do not feel that CSP is a good fit for them. Here is a list of those reasons fol-lowed by suggested improvements.

a. Additional conservation practices are weighted higher than existing practices.

Suggested Improvement: New and existing conservation practices should be weighted equally.

Ranking additional or new conservation practices higher than existing practices does not reward the farmers who are the best land stewards for their existing conservation efforts. Instead, it benefits farmers who have implemented a smaller number of con-servation practices instead of rewarding those that have done the most. This is of particular concern for organic farmers, as they may be ranked lower than many of their conventional counterparts because of the numerous existing conservation practices they already have in place. Organic farmers and other farmers who have implemented conservation practices should be rewarded for the conservation work they have done, not punished for it by receiving a lower ranking or a smaller payment rate. Equalizing the payment rates for existing conservation activities so that they are on par with additional conservation activities should help level the playing field for organic farmers.

b. The NRCS’s conservation enhancements and practices list does not contain an option for an organic-specific bundle.

Suggested Improvement: Create an organic-specific bundle that garners a high environmental benefit score.

Bundles are a group of conservation practices that make sense for farmers to incorporate and practice together. Bundles allow farmers to receive a higher environmental benefit score and thus a higher CSP payment. However, the NRCS list of bundles does not contain an organic-specific bundle. A bundle with the most common organic practices may improve enrollment because organic farmers would receive higher payments. This would make the program more accessible for organic farmers.

The organic bundle could include any mixture of conservation activities such as cover cropping (leguminous and/or non-legumi-nous), composting, integrated pest management, hedgerows, mulching, riparian areas, and more, and include an environmental

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benefit score of between 180-210 points. (Note: The assistance of NCAT and the NRCS is needed to determine the exact con-servation activities and environmental benefit score that an organic-specific bundle would necessitate). The bundle should include practices that are commonly used on organic farms because it would make CSP payments more accessible to organic farmers.

In sum, organic farmers employ many conservation practices and they should be rewarded for their stewardship and environ-mental benefit through an organic-specific bundle.

c. Organic certification status or a valid Organic System Plan (OSP) is not available as a conservation practice for which farmers may receive performance points.

Suggested Improvement: Make organic certification status or a valid Organic System Plan available as a conservation activity.

Certified organic farmers should receive ranking priority to qualify for CSP payments because they have an annually verified Organic System Plan (OSP), which explains how the certified organic farmer maintains or improves soil quality and other natural resources. The OSP outlines on-farm conservation practices to meet the requirements of organic certification under the National Organic Program. The OSP is designed to conserve and optimize the use of natural resources and is a legally binding contract between the organic farmer and their certifying agency. The organic farmer invests a significant amount of time into developing an OSP, which guarantees that conservation activities will be employed by the organic producer. As such, valid organic certifica-tion for an OSP should be available as a conservation activity on its own. (Note: The assistance of NCAT and the NRCS is needed to determine the exact number of performance points organic certification or an OSP would receive as a conservation activity).

d. Performance points for conservation enhancements or practices that relate to organic operations are relatively low.

Suggested Improvement: Performance points for conservation activities that relate to organic operations should be increased.

The NRCS should increase the performance points (or environmental benefit score) that organic farmers receive for common conservation practices used on organic farms, such as integrated pest management, beneficial pollinator habitat, and cover crops. The points for many of these practices do not reflect their immense environmental benefit. Additionally, farmers contemplat-ing the transition to organic should have higher scoring practices available to them because they invest in a three-year transition period. Increasing the overall point values for conservation activities related to organic and organic transition agriculture should help increase organic farmer participation in the program.

Organic farmers think they receive lower payments than conventional farmers. One organic farmer said, “Why do the conven-tional guys get so much more than me?”

e. Comprehensive Conservation Planning is not available as a conservation practice.

Comprehensive conservation planning is used by farmers, usually with the technical assistance of the NRCS, to develop short- and long-term plans for addressing resource concerns and prioritizing conservation practices on their farms. The farmer or land-owner invests a significant amount of time and money into developing this plan, which focuses on reducing on-farm resource issues. The comprehensive conservation plan mirrors the OSP for organic farmers in that they are both developed to outline the practices and procedures required to maintain and improve natural resources. Currently, there is no CSP payment option avail-able to famers who undertake either of these planning processes (Congress authorized funding for comprehensive conservation planning, but it was never implemented).

Suggested Improvement: Make funding available for comprehensive conservation planning as a payment option under CSP.

Making funding available for comprehensive conservation planning will 1) reward farmers who have already developed a comprehensive conservation plan, 2) provide an incentive for other farmers to cre-ate a plan, and 3) provide an incentive for farmers to work with a conservation professional who can give them technical advice and expose them to new ideas and practices that will help alleviate their resource concerns.

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Appendix 1. NRCS Staff Survey Questions1. Is CSP a popular program in your county?

2. If CSP is not popular, why do you think CSP is not being used?

3. What kind of farmers (row crop, perennial, organic, etc) typically apply to CSP out of your office?

4. Are you aware of bundles of CSP practices being used in your county?

5. What bundled or stand-alone CSP practices have been used in your county?

6. Roughly how many CSP program contracts has your office done in the last two years? (check the best answer)

5 or fewer 5-15 15-25 more than 25

Appendix 2. Summary of Responses to QuestionsThis is a verbatim summary of different folks’ answers to the six questions. Each bullet under a particular question represents a different NRCS staffer’s response. After the summaries of the questions, there are some emails and notes from telephone calls with NRCS staff, edited to retain anonymity.

1. Is CSP a popular program in your county?

Thirteen answered “no”, 3 answered yes.

2. If CSP is not popular, why do you think CSP is not being used?

• It is kind of an unknown quantity for growers and it is hard to understand how it works. Also payment levels are very low for cropland.

• While there are landowners in “x” County who are willing to participate in longer term contracts and easement programs (we’ve had 10 year EQIP and AWEP contracts, WRP, CRP (though FSA) and yes CSP; most of our clients including folks who haven’t worked with NRCS regularly, often voice a strong preference for ‘bite-sized’ agreements, ones that wrap up in 2, maybe 3 years max. EQIP as it is currently constructed fits that bill well. CSP does not.

• Many of our growers don’t meet the AGI and others don’t want the paperwork. Also, some have said they don’t want to reveal personal information. This is with all programs, not just CSP.

• For NRCS employees, the program is a nightmare. I have not spoken with one NRCS employee that likes to deal with it. It is exceedingly complex to understand, plan for, and administer. I understand that the program is going through an overhaul right now for 2016; watch out, though – every time a program gets “improved,” it turns out to be even more complex than the previous version. In Area III of NRCS (the San Joaquin Valley), most offices do not even know what CSP is. They want nothing to do with it. Their EQIP workload is much too heavy. This program, in its present form, is broken, and needs to be fixed, or else, no one (farmers or NRCS personnel) will want to have much to do with it.

• EQIP seems a better fit for cropland.. CSP isn’t really popular among staff; not as flexible as EQIP; 5 year contracts, and very hard to modify the contracts, so it’s not flexible administratively. It’s cumbersome to deal with from the NRCS side. It’s not easy to get farms “in” the program—need to get a lot of info for the CMP (conservation measurement tool—used to rank applications)—lots of info-gathering on the up-front side; lots of documentation, and fairly cumbersome for the farmers to produce the documentation, and requires a lot of fieldwork to verify implementation, payment levels very low for cropland especially.

• It’s a whole other realm of workload/admin/ and he doesn’t really have bandwidth to do the CSP work in addition to EQIP. It’s based on a per acre payment, which is not good for smaller growers.

• Responder is not that familiar with CSP.

• They don’t do a lot with CSP—notes that they’re difficult to implement and manage; all their land has to be in the project. It’s a real rigorous process for both the grower AND the NRCS, with a lot of detailed questions on a property.

• Question not applicable, CSP relatively popular in county.

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• Moderately, 20 contracts initially with landowners I targeted with outreach who had existing EQIP contracts. Down to 5-6 actually renewing.

• CSP not popular to due large admin burden.

• Not worthwhile for the small farmer. Too much paperwork for a small amount of funding. Really need 100+ acres to make it worthwhile. I have over 180 organic growers as well, but their fields are much too small to utilize CSP. There needs to be a minimum guaranteed amount that would be enough to interest small farmers..

• Lack of awareness and limited number of sizeable farms to work with who would be interested. The very small truck farms are generally not interested.

• No response to question.

3. What kind of farmers (row crop, perennial, organic, etc) typically apply to CSP out of your office?

• Most recently we have had rangeland and vineyards. It’s a very small number of contracts in our county, so not representative.

• [This] County has only had 2 CSP contracts, one was a row crop, the other was both row crops and perennial.

• [This] County is typically a mono-culture – just wine grapes. Two CSP contracts were range.

• With the original Conservation Security Program back in the mid-2000’s [now the Conservation Stewardship Program], we had 10 contracts, I believe. We had row crops and rangeland. Much of the eligibility of the program depended on a posi-tive SCI (Soil Conditioning Index). Much of this index is tied to the amount of crop residue that is left after harvest. With tomatoes, our main cash crop, the crop residues have withered by 90% or more just days after harvest. I do not believe any tomato growers made it into the program.

• Don’t do CSP in this county.

• Vineyards/orchards, dairies, and rangeland are 3 major types of farms in this county. They’ve done CSP with small organic grower (actually worked out OK)—the paperwork was a lot for the low payment rate.

• All land uses for the most part including Forestry, Range, Pasture, Irrigated Cropland etc.

• Pasture / ranchers, little Forestry (activities not applicable on west coast = required burning). Recently a couple new small organic farms (min payment helpful)

• Perennial Orchards and annual rice, potential for grazing operations

• Large landowners, mostly dairy farmers and forage farmers in my area. Long term leases are also a problem – some farmers only get a year to year lease.

• Primarily rice growers and orchard

• We have 4 range contracts and 1 crop/orchard contract.

4. Are you aware of bundles of CSP practices being used in your county?

• We did not use bundles. We used mostly stand alone and chose from there.

• I’ve heard of them, but quite frankly, I do not see any advantage, whatsoever, of using them. They just add more to the con-fusion and complexity of the program.

• Five answered “no,” bundles were not being used in their county.

• Not sure if bundles would be very helpful, and so there’s always reasons for folks not to like specific sections of the bundle, so it’s too prescriptive. Would like the freedom to do their own bundles, for example, to choose 5 of 8 practices, for example.

• They know about the idea of “bundles” and they looked at the bundles, but the bundles didn’t have enough flexibility to implement bundles.

• Bundles have rarely been used due to the number of enhancements required per bundle

• Yes initially but not applicable for most now (or too hard to meet requirements)

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• We are aware of bundles but many do not fit our applicant’s operations

5. What bundled or stand-alone CSP practices have been used in your county?

• Cropland (vineyard): cover crop mixes (SQL04); Using N from legumes, manure and compost for 90-100% of N needs (ENR 10); Irrigation pumping plant evaluation (WQT 03). Rangeland: Intensive rotational grazing (PLT 16); managing calving (ANM 26); monitoring key grazing areas (PLT 02) ; Retrofit watering facilities for wildlife escape (ANM38).

• On cropland: IPM including plant tissue testing, deferred crop production on seasonal wetlands, applying nutrients no more than 30 days before planting date. On rangeland: biological suppression for herbaceous weeds, invasive species, and for brush management.

• Soil Quality (cover crops), Energy (use of legumes), Air Quality (replace burning), Water Quality (plant tissue test N man-agement), Water Quality (Regional weather networks), Animal Enhancement (extending riparian forest buffers), Air Quality (drift reducing nozzles), Water Quantity (irrigation pumping plant), Air Quality (replacing oil and wood fired heaters), Energy (locally grown), Plant Enhancement (establish pollinator habitat), Water Quality (controlled release N), Water Quality (use of legume cover crops for N), Water Quantity (Remote monitoring of Irrigation)

• None that I know of

• Five respondents did not provide any info on bundled or stand-along practices.

• Most common enhancements used are grazing related or nutrient application related on cropland typically. Water Quality is the most commonly addressed resource concern.

• Easiest ones to do with minimum effort on landowners part

• Pump evaluation, nutrient balancing

• IWM [Irrigation Water Management], Nutrient Mgt.

• ANM18 Retrofit watering facility for wildlife escape; ANM29 On-farm forage based grazing system; ANM65 Monitoring nutritional status of ruminant livestock using the NUTBAL system; PLT02 Monitor key grazing areas to improve grazing management; WQL03 Rotation of supplement and feeding areas; ANM17 Monitoring nutritional status of livestock using the NUTBAL PRO System; AIR04 Use drift reducing nozzles, low pressures, lower boom height, and adjuvants to reduce pesticide drift; WQL04 Plant tissue tests and analysis to improve nitrogen management; WQT01 Irrigation system automa-tion; WQT03 Irrigation pumping plant evaluation; WQT05 Remote monitoring and notification of irrigation pumping plant operation

6. Roughly how many CSP program contracts has your office done in the last two years? (check the best answer)

5 or fewer 5-15 15-25 more than 25

• 10 responded “5 or fewer”

• 4 responded “5-15”

• No response from 2

Emails

From NRCS Engineer: CSP is way too complex and confusing to administer. We get way more bang for our buck using EQIP. Another reason it’s not so popular in rangeland is you have to include all the land you control in the application. Well when you have lots of leases and different landowners it’s tricky. Also one property might not quality and puts you out of the program.

From an NRCS District Conservationist (DC)

I have always been taught by my predecessors in the Soil Conservation Service (many of which went back to the early days hav-ing started in the early 1940s) that you “sell” conservation on its merits and that it pay dividends at the end of the day. That’s the incentive not a reimbursement from the government. When you spend the time upfront building trust and a relationship with the grower he/she will likely develop a conservation ethnic when they see the return on their conservation investment and all that it leads to in the way of other benefits (including environmental benefits) as well.

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After nearly 42 years with SCS/NRCS of working in the field with farmers and ranchers I have found that it’s not the money we’re giving them that gets conservation applied on their lands it’s the advice and how it is presented. We spend so little time these days in the field building trust and lasting relationships with growers and we think we can do it all behind our computers using mapping tools, e-mail, etc. Personally, I think we have way too much “conservation infrastructure” on the landscape. I spend as much time in the field talking growers out of practices they don’t need then I spend helping to see how many practices they can get the government to pay for. I definitely think that “No Practice” should be a BMP.

When we speak to the economics and to all the other benefits of conservation practices most growers will apply on their own dime because it make business sense and that is what they are doing, in business to make money.

If we are really serious about increasing participation in CSP then we have to spend time with clients in the field, and we need to be able to attend events with limited resource farmers (such as the ones I attend that are sponsored by such groups as Farm-link each year) to promote the funding program designed to help them. CSP to be honest with you is confusing even to many NRCS employees. Many NRCS employees also don’t want to promote more farm bill programs because it will likely result in more work without any extra staff to do that work.

Notes on Telephone calls with NRCS Field Staff. These are notes that Rex Dufour took during extended telephone calls with several NRCS staff. No names, locations or gender are provided to protect anonymity.

Telcon with DC #1: This DC worked more with it when it was the “security” program. It’s cumbersome to deal with from the NRCS side. It’s not easy to get farms “in” the program—need to get a lot of info for the CMT (conservation measurement tool—used to rank applications)—lots of info-gathering on the up-front side; lots of documentation, and fairly cumbersome for the farmers to produce the documentation, and requires a lot of fieldwork to verify implementation, payment levels very low for cropland especially. Not sure if bundles would be very helpful, and so there’s always reasons for folks not to like specific sections of the bundle, so it’s too prescriptive. Would like the freedom to do their own bundles, for example, to choose 5 of 8 practices for example. Especially for cropland, you need a lot of acres for CSP to make sense, which explains why rangeland folks do CSP is more popular. For cropland, for some of the enhancements paying too much, and for others, too little. Since it’s all calculated on acres, smaller growers don’t get much benefit. Not much mandatory training on CSP (NRCS puts out webinars, trainings). Notes that EQIP seems a better fit for cropland.. CSP isn’t really popular among staff; not as flexible as EQIP; 5 year contracts, and very hard to modify the contracts, so it’s not flexible administratively. If CMT could be modeled after a “sustainability index” so that it wouldn’t be watered down so much for each individual crop. Doesn’t think the CMP does a good job of being a ranking tool, and because it was to be used nationwide on all crops, so it was watered down a lot—the questions are really general and categories are very broad

CMP on rangeland should be verified (and it’s really hard NOT to qualify due to the way the questions are framed. So the over-generalized and watered-down questions don’t really support good conservation, and can’t address resource concerns (since they’re already doing good conservation). Can’t do part EQIP and part CSP as ALL land must be enrolled into the CSP.

For the crops, CA is at a disadvantage (with respect to the “length of rotation” question), as rotations will change according to market and climate conditions.

Doesn’t really handle permanent crops very well.

Telcon with DC #2: CSP is very unpopular with field staff, but seems to be popular with Washington. In DC’s county, this DC doesn’t do CSP—it’s a whole other realm of workload/admin/ and DC doesn’t really have bandwidth to do the CSP work in addition to EQIP

Based on a per acre payment, which is not good for smaller growers. DC’s not that familiar with CSP, though. DC doesn’t like the whole concept of payments that CSP provides. DC doesn’t feel it provides technical assistance to do good conservation—CSP doesn’t do that…DC notes that DC does understand NRCS’s effort to implement the program, and notes that if DC was provided another soil con[servationist] to do that program, DC would support it more. DC notes that the office simply doesn’t have the staff to do the program.

Notes during the DC/State Staff meetings, DC observes that CSP is pretty universally disliked around the state. DC notes that one of the greater issues of conscientious USG[overnment] employees is the idea of efficient use of tax-payer money—and DC doesn’t feel guilty about not offering the program, and DC doesn’t want to feel bad about the money they’re spending. DC notes that when DC gets CSP emails, generally just deletes them. DC notes that CSP contracts can’t be modified, and the contract is pretty long…DC knows folks that went into early retirement because of CSP. DC doesn’t know anybody in the field who

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is comfortable with the program, and DC’s had only one person request CSP, and this individual was out of compliance with EQIP contract, so DC said no to a CSP contract.

Telcon with two NRCS Field Staff: They don’t do a lot with CSP—notes that they’re difficult to implement and manage; all their land has to be in the project

Vineyards/orchards, dairies, and rangeland are 3 major types of farms They’ve done CSP with small organic grower (actually worked out OK)—the paperwork was a lot for the low payment rate—they get paid for things they’re already doing, and also for doing new practices. Can’t make an adjustment to existing contracts, but can roll over for another 5 years, and can delete and add new things. Did a CSP with a vineyard. If there’s any changes in the land unit (sale of land or adding land), they have to reapply for a new contract.

They know about the idea of “bundles” and they looked at the bundles, but the bundles didn’t have enough flexibility to imple-ment bundles.

It’s a real rigorous process for both the grower AND the NRCS, with a lot of detailed questions on a property. Not a whole lot for perennial crops…for the organic guy—crop rotation, owl boxes.

Going forward—they’re looking for folks that are already doing a lot of things. Implementation is so arduous for NRCS person-nel, and very arduous for the farmer. The NRCS staff tries to do as much as they can for the farmer, but it requires a number of interviews with the farmer.

One staffer would like to see a more up-front screen process (quicker/shorter/sweeter) that would help rank folks (pro or con) earlier in the process—it would save a lot of hours of labor, and then streamline down the CMT questions. Had to do at least 2-3 resource concerns on the farm, and then . CMT tool does take a lot of time

CSP overall is a good idea, but the process is a bit “bumpy”—there are certain practices in CSP that aren’t available in EQIP. Intercropping is not available in EQIP. Bundled practices would likely be more appropriate for folks that are new to NRCS OR new to CSP. These two individuals thought that the bundles were a good idea. They didn’t think bundling options (pick 5 out of 10 practices offered), wouldn’t offer too much to growers, although one individual thought it was a good idea. Might make CSP process more complicated than it already is.

Number of CSP contracts in county: 6 since 2011. It’s not real tempting for the NRCS staff to promote…The 5 year commit-ment, they think, make it less attractive to farmers, and they’re locked in to doing what they’re doing for 5 years, but there is flexibility in the number of years any practice is done. CSP is a headache for the field staff to manage, rank and implement.

They note large crop diversity in CA is trickier to implement CSP in. A LOT of the questions in the CMT are clearly developed for the mid-west. We [farmers in CA] don’t have the set rotations here that other states have. CMT focuses on “what’s the crop rotation”—the rotations in any particular field—why even ask questions about the rotation.—doesn’t make sense to try to pin down the farmer on the rotations….

CSP should be revamped to focus more on cover crops and soil health/soil quality bundles…Bottom line: program is not living up to its potential due to considerations noted previously

They’re using it, and trying to target folks that would benefit from it, but it’s unwieldy program. Basically a good program, but could be improved.