The U.S. Department of Agriculture is seeking public comments on recent changes to the Conservation Stewardship Program (CSP). The program, the most significant leap in conservation policy in a decade, was designed to reward top-notch conservation already on the ground, as well as incentivize the integration of new and innovative conservation systems that protect and enhance the quality of our soil, water and air.

However, without crucial changes, the program will fail to yield those intended results. The Natural Resources Conservation Service (NRCS) must base producers’ ranking and payments solely on environmental benefits and outcomes. They consistently overemphasize the importance of additional or new conservation activities while failing to adequately support conservation practices and systems farmers and ranchers are currently employing, which misses the mark by supporting late adopters of improved conservation systems over those who have historically placed conservation at the core of their operations.

NRCS must also ensure payment limitations are real. By statute, CSP contracts are limited to $40,000 per fiscal year and $200,000 from fiscal year 2014 through 2018.  

But the rule doubles the statutory limit for joint operations. Worse, the rule fails to require that beneficiaries be active farmers, and allows farms to have multiple contracts despite the statutory stipulation that the entire farm must be enrolled in the CSP contract. These loopholes allow certain operations to rack up contracts far in excess of the statutory limit and gives them a competitive advantage over small and mid-sized farmers.