AFT Comment on CSP Interim Final Rule

October 5, 2004 Financial Assistance Programs Division Natural Resources Conservation Service P.O. Box 2890 Washington, DC 20013-2890 COMMENT ON THE CONSERVATION SECURITY PROGRAM INTERIM FINAL RULE Please find below American Farmland Trust’s (AFT) comments on the Interim Final Rule for the Conservation Security Program (CSP) published in the Federal Register on June 21, 2004 by the Natural Resources Conservation Service (NRCS). The NRCS faced a difficult task in getting the CSP up and running during fiscal year 2004. Despite budget constraints and a short timeline, the agency issued a notice and an interim final rule to implement the program in 18 watersheds. While it deserves recognition for all it accomplished, the version of the CSP that the NRCS implemented is far from the program passed by Congress in the 2002 Farm Bill. This is evident by the fact that only 2,188 out of an estimated 27,300 eligible farms and ranches received CSP contracts during the recent sign-up. The CSP is the nation’s first comprehensive stewardship incentive program and we believe it should become a central component of future U.S. farm policy. In order for it to do so, however, the NRCS must implement the program in a manner that is national in scope, financially attractive to producers and predictable. In our comments on the proposed rule, we recommended that the NRCS reject the proposed watershed approach, eliminate the system of enrollment categories ...