Title 2 Recommendations

by: AFA In News, Policy RecommendationsTagged

The following are recommendations that can prioritize sustainable fiber-rich foods in farm policy. In general, AFA supports Title 2 recommendations from the National Sustainable Agriculture Coalition and Institute for Agriculture and Trade Policy so we include them here.

For reference: CRS Report on Title II ‘Conservation’ of the 2018 Farm Bill.

Solutions Needed from USDA

1. Clarify and reform the application process through Conservation Assessment Ranking Tool (CART), better supporting existing conservation measures while increasing transparency

2. Ensure that CSP remains a whole-farm program and EQIP remains targeted for single conservation projects 

3. Meaningfully invest in CSP and EQIP outreach to farmers of color, and increase CSP and EQIP set-asides for farmers of color

4. Prioritize the climate mitigation benefits of CSP 

National Sustainable Agriculture Coalition Title 2 Recommendations

More can be done to prioritize farmers of color in assigning conservation grants. In 2020, only 245 CSP contracts and 2,158 EQIP contracts were awarded to farmers of color nationally, which comes out to 3.7% of CSP contracts and 6.4% of EQIP contracts.1 

“According to the National Agriculture Statistics Service, in 2017 there were over 240,000 farmers of color in the United States…it is clear that when only 1% of farmers of color are enrolled in the largest conservation programs in the country, more needs to be done to support farmers of color, who are in many cases the most susceptible to climate risks.”

Michael Happ (2021), Program Associate for Climate and Rural Communities, Institute for Agriculture and Trade Policy

We also urge the USDA to enhance CSP payment rates for conservation practices. CSP payment rates for conservation practices adopted as part of a contract should not be capped at 10 percent of the Environmental Quality Incentives Program (EQIP) rate. Differences in practice payment rates should be based on actual projected differences in costs, benefits, and forgone income, rather than on an arbitrary formula that results in unreasonably low payments under CSP. The large discrepancy between EQIP and CSP payments reveals a significant programmatic bias on the part of the leadership of the previous Administration. This should be fixed immediately in the CSP Manual and in the annual payment schedules rather than waiting for the publication of the revised Interim Final Rule.

Finally, it is important to encourage CSP to maintain a whole farm approach so it can continue to “reduce greenhouse gas emissions, sequester carbon, and adapt to emerging and extreme climate-related changes.”2

Solutions Needed from Congress

1. Include an additional $30 billion for CSP and EQIP in budget reconciliation.

2. Authorize and appropriate more money for conservation technical assistance at NRCS.

3. Prohibit EQIP dollars from going to new or expanding CAFOs.

National Sustainable Agriculture Coalition Title 2 Recommendations

In addition to the recommendations from NSAC, AFA proposes that Congress consider these further actions:

  1. Remove the requirement that 50% of EQIP funding go to livestock 3, 4
  2. Make CAFOs ineligible for EQIP funding.
  3. The 2018 farm bill added grazing and commercial uses as valid activities on CRP land. This compromizes the original purpose of re-wilding CRP acreage. AFA proposes reverting the list of valid activities on CRP land to those prior to the 2018 farm bill. More details from the Center for Biological Diversity 5
  4. Increase grazing rates on public land to match market grazing rates on nearby private land.
  5. Add conservation practices that involve increasing farm mobility to producing fiber-rich foods that have a low environmental impact as an official NRCS conservation practice, so it could qualify for federal conservation grants. An example is that a dairy farm can transition to an agro-food forest. This can be achieved with a pilot program like the FARMS Amendment.
  1. Institute for Agriculture and Trade Policy, U.S. Farmers’ Access to Conservation Programs https://www.iatp.org/documents/closed-out-how-us-farmers-are-denied-access-conservation-programs
  2. National Sustainable Agriculture Coalition, U.S. Farmers’ Access to Conservation Programs https://sustainableagriculture.net/blog/closed-out-how-u-s-farmers-are-denied-access-to-conservation-programs/
  3. Federal Register, “Environmental Quality Incentives Program” https://www.federalregister.gov/documents/2019/12/17/2019-26872/environmental-quality-incentives-program
  4. National Sustainable Agriculture Coalition, “Impact of 2018 Farm Bill Provisions on Soil Health” https://sustainableagriculture.net/wp-content/uploads/2019/09/FINAL-DIGITAL-Impact-of-2018-Farm-Bill-Provisions-on-Soil-Health.pdf#page=5
  5. Center for Biological Diversity, Costs of Grazing https://www.biologicaldiversity.org/programs/public_lands/grazing/pdfs/CostsAndConsequences_01-2015.pdf