Attn: Conservation Security Program
Attn: Conservation Security Program
The interim final rule for CSP is so restrictive that it risks undermining the purpose of the program. The Final Rule should make the CSP into the nationwide, accessible, and effective program intended by Congress to help farmers maximize their conservation performance.
• Remove restrictions limiting enrollment to only a few watersheds and certain “categories” of farmers and ranchers.
• Expand eligible resource concerns to all types of conservation objectives.
• Eliminate the new “per acre” cap on contract payments. It favors large farms over small farms and those with high land rents over those with lower rental rates even if those farms may be practicing less conservation.
• Expand enhancement payments to include the full range of options in the law, including crop rotations, rotational grazing, buffers, energy conservation, research, etc.
• Increase the cost-share rate for new practices.
• Remove requirements for a prior history of meeting high environmental standards, and instead require that high standards be met in a reasonable time after participating in the CSP.
Thank you for taking these comments into consideration.
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