The Organic Trade Association Supports A Strong Conservation Security Program:
Comments submitted regarding 7 CFR Part 1470 and
the February 18, 2003 CCC-NRCS Advanced Notice of Proposed Rulemaking
Submitted by Tom Hutcheson,
Associate Policy Director
March 20, 2003
The Organic Trade Association (OTA) appreciates the opportunity to comment on the most significant conservation program in recent history. With careful implementation, the Conservation Security Program (CSP) can become the foundation for supporting environmentally sound farming.
OTA is pleased to endorse the detailed comments of the Sustainable Agriculture Coalition, submitted by Ferd Hoefner. Those comments are very well thought-out, deserve close study, and could serve as a guide to CSP implementation.
In addition, OTA notes that the final rule for the National Organic Program (7 CFR 205) requires organic farmers to “maintain or improve” soil or water quality in various sections of the rule, including the definition of pasture (205.100); general production requirements (205.200); soil fertility (205.203(a), (c), and (d)); and crop rotations (205.205). OTA believes that NRCS will appreciate the correspondence between good organic production practices and good conservations practices.
OTA especially supports the Sustainable Agriculture Coalition’s comments in answer to ANPR Question 1.
ANPR question #1: The law specifies that conservation security plans address one or more “significant” resource concerns. Resource concerns may be as general as soil erosion or water quality or as specific as soil erosion by water or ground water quality. Many concerns have no practical direct measurement techniques or tools. What criteria should be used to determine what is a resource concern and whether a resource concern is significant?
OTA emphasizes the Sustainable Agriculture Coalition’s comments regarding comprehensive and whole farm planning. Organic farmers are required to submit detailed plans regarding their operations. In no case should a Tier III payment be made for a plan which is less rigorous than an organic farm plan.
OTA strongly approves of the Sustainable Agriculture Coalition’s comments that “soil building, carbon sequestration, enhancement of biodiversity, and major reductions in the use of synthetic chemical inputs are examples of these potential national resource concerns.”
OTA has an additional comment on ANPR question 3.
ANPR question #3: The law requires NRCS to describe the particular practices to be implemented, maintained, or improved as part of the program. What criteria should be used to determine which practices and activities are eligible for payment under the program? Should specific practices or activities receive priority for payment under the program? To what extent should sets of practices and activities be accorded priority for payment under the program?
Organic producers should receive priority for payment under the program. Not only are organic producers required to “maintain or improve” natural resources, they must submit a farm plan demonstrating those measures. Because the work of NRCS and its Technical Service Providers will be eased by the existence of these verified plans and practices, OTA urges NRCS and CCC to give priority in outreach, technical assistance, and payments to organic operations.
The extent of this preference should depend on the benefit to the environment, which must be assessed on a case-by-case basis.
OTA urges NRCS and CCC to allow organic farmers to use their existing farm plans under 7 CFR 205 as part of their CSP farm plan, and to propose a mechanism whereby organic farmers may submit their organic farm plan together with any necessary additional documentation as their CSP farm plan, in order to reduce the paperwork burden on organic farmers.
OTA notes and supports the third point in the Sustainable Agriculture Coalition’s comments in the section of their comments titled “Ten Additional Key Points and Recommendations”, cited in full below.
“3. Coordination with organic farm plans under the National Organic Program.
“In response to question number 13, we recommended the creation of organic cropping systems and organic livestock systems conservation practice standards as part of the national handbook. In addition, we continue to urge NRCS and the Agricultural Marketing Service to move forward with advanced planning to provide good customer service and a high level of coordination between National Organic Program and CSP farm plans. Ideally, producers with approved organic certification plans under the National Organic Program should have the option to simultaneously certify under both the CSP and NOP if they meet the standards of both. In addition to being farmer-friendly, this process would also improve both programs – helping to improve conservation standards under organic plans and bringing the enormous environmental benefits of organic systems to the CSP and potentially other NRCS conservation programs.”