TALKING POINTS FOR PUBLIC COMMENTS ON MAJOR ISSUES
NSAC recommends that your comments include some or all of the following recommended changes to the Interim Final Rule, plus any additional comments you may have on EQIP. These recommended changes will ensure that EQIP better serves sustainable farmers and ranchers.
1. Organic Conversion: The 2008 Farm Bill included a new provision for conservation financial and technical assistance to farmers and ranchers who are making the transition to organic production systems. Farmers and ranchers may receive up to $80,000 over a 4-year period in organic conversion payments.
- Recommend that the final EQIP rule clarify that EQIP Organic Conversion Assistance is available in all counties in all fifty states every year.
- Recommend that the final EQIP rule requires NRCS State Conservationists to rank and process applications for organic conversion assistance in a separate funding pool.
- Recommend that the final EQIP rule makes clear that the limit of $80,000 over a 4-year period applies only to organic conversion payments and not to all EQIP payments made to organic farmers and ranchers. Organic farmers and ranchers should stand on a equal footing with conventional producers in the funding amounts they can receive from EQIP for their agricultural operations.
2. Restrictions on EQIP Funding for New or Expanding CAFOs: The proliferation of large-scale concentrated animal feeding operations (CAFOs) has resulted in the concentration of huge amounts of animal waste with degradation of watersheds and air quality in locations around the nation.
- Urge NRCS to amend the EQIP rule to prohibit the use of EQIP funding for animal waste storage, treatment or transportation for new or expanding CAFOs.
- Recommend that the EQIP rule not provide for waivers to increase assistance to CAFOs above the payment limit of $300,000, in order to ensure that public funds are not used to provide large subsidies to CAFOs whose cumulative impacts degrade the environment.
3. Comprehensive Conservation Planning: The 2008 Farm Bill provides for EQIP assistance for Comprehensive Nutrient Management Plans for CAFOs and other conservation planning activities. But the EQIP Interim Final Rule limits assistance for comprehensive conservation planning to Comprehensive Nutrient Management Planning.
- Recommend that the EQIP rule be clarified, in accordance with the 2008 Farm Bill, to make EQIP assistance available to all farmers and ranchers for comprehensive whole farm conservation planning.
4. EQIP National Priorities: USDA allocates funding to the states based on national priorities, provides additional incentives to states that implement EQIP national priorities, and gives special attention to national priorities in determining which EQIP applications will be funded. The 2008 Farm Bill directs USDA to encourage the development of habitat for native and managed pollinators and the use of conservation practices that benefit native and managed pollinators in all the conservation programs. In addition, the 2008 Farm Bill added energy conservation and organic systems as new purposes for EQIP and retained assistance for grazing management as an EQIP purpose. These purposes are of particular importance to sustainable farmers and ranchers but are not included in the National Priorities in the Interim Final Rule.
- Recommend that the EQIP Interim Final Rule be amended to include pollinator habitat and pollinator protection, organic systems, grazing management and energy conservation in the list of EQIP National Priorities.
