The response was unprecedented in the history of conservation programs. The Natural Resources Conservation Service received more than 60,000 specific comments on the proposed rule for the Conservation Security Program during its 60-day comment period.

CSP is the latest in an arsenal of conservation tools designed to support and encourage voluntary conservation practices by private landowners across the nation. CSP will identify and reward those farmers and ranchers who are meeting the highest standards of conservation and environmental management on their operations

The unprecedented number of public comments we've received on CSP is indicative of both the interest in this innovative program, and the heart-felt commitment to natural resource conservation on America's working lands by so many groups and individuals. From my perspective as chief of the NRCS, I find it gratifying to receive such thoughtful input — input that is helping us craft a program capable of living up to CSP's enormous potential and the intent of congressional authors.

The comments will be extremely helpful in our daunting task of implementing CSP. We have reviewed and considered every comment and the final rule will reflect some of this creative input. Thanks to this overwhelming feedback we are now closer to the first sign-up for CSP.

However, one area in which we received many comments and yet found no fairer or more scientific way to proceed in implementing CSP is the issue of using a staged, watershed approach.

After reviewing the comments we still believe that a watershed approach offers the best option — economically, practically and administratively. Here's why:

  • Watersheds are nature's boundaries. They are a commonsense way to group together producers working on environmental issues and to measure environmental success — something state or county lines couldn't be expected to do. Plus, everyone lives in a watershed, and within the next eight years, every farmer and rancher will have an opportunity to participate in the program — so no qualifying producer will be left out.

  • More funding means more watersheds — or all watersheds. The watershed approach allows NRCS all the flexibility needed to expand the program as Congress makes more funds available. The watershed approach provides the necessary opening or narrowing of the gate as funding rises or falls.

  • The bottom line on the bottom line: Those following CSP closely will notice that our estimate of CSP contracts for 2004 has increased tenfold since December. Thanks to the administration's dedication to the program, and its resourceful approach to contracting, funding for some 3,000 contracts will now be possible this year. Even so, with 1.8 million potentially eligible applicants — and 3,000-plus contracts available, the need to focus the CSP effort is the commonsense conclusion of simple arithmetic. Furthermore, the law requires that NRCS not incur more than 15 percent technical assistance costs associated with CSP. And whether help comes from an employee or a private technical service provider, that same 15 percent applies. Given this scenario, a nationwide program is inconceivable. A watershed rotation offers a fair, scientific alternative.

  • Do it right, do it in stages: Additionally, focusing on high-priority watersheds will allow NRCS to reduce the administrative burden on applicants, and to reduce the technical assistance costs of processing a large number of applications that cannot be funded.

    The watershed approach will allow landowners to assess the resources on their farms and ranches now and prepare early for participation in the program as their watersheds rotate into the program. To do so, producers can select from a portfolio of USDA conservation programs to make the necessary natural resource improvements on their operations.

    The staged implementation will allow agency personnel to refine, streamline, and perfect application procedures, as well as self-assessment and self-screening processes. It will also allow existing agency staff and private technical service providers to more thoroughly assist landowners who apply during the CSP sign-up, and provide technical assistance to those landowners who will be readying their farms and ranches for subsequent signups.

  • The opening act of a multi-stage program: While much of the concern has been focused on the first year, it's important to remember that this is just the first year of a long-term program. Over seven years the administration is committing $13.4 billion in funding toward CSP — $2 billion more than the latest Congressional Budget Office 10-year score. With this level of funding, we expect to enroll more than 90,000 contracts into CSP in seven years. This will undoubtedly supply the program with the foundation it needs to “reward the best and motivate the rest” toward our collective goal of achieving exemplary stewardship.


Bruce I. Knight is chief of USDA's Natural Resources Conservation Service. He wrote this article for Farm Press Publications.