CSP Comment submitted by American Farmland Trust

March 2, 2004 David McKay Conservation Planning Team Leader Conservation Operations Division Natural Resources Conservation Service P.O. Box 2890 Washington, DC 20013-2890 COMMENT ON THE CONSERVATION SECURITY PROGRAM PROPOSED RULE Dear Mr. McKay: Please find below American Farmland Trust’s (AFT) comments on the proposed rules for the Conservation Security Program (CSP) published in the Federal Register by the Natural Resources Conservation Service (NRCS). NRCS faced a difficult task in developing a rule for an entitlement program that was capped in Fiscal Year 2004. While the proposed rule provides a way to deal with the spending limits that CSP faced in FY 2004, it fails to provide guidelines that will allow for the long-term success of the program once the spending cap is removed. AFT believes that the program, however constrained by funding, must be national in scope, financially attractive to producers, and predictable if it is to meet Congress’ objective. The final rule must encourage farmers and ranchers to participate in CSP, and ensure that those who do so have a good experience. Accordingly, AFT recommends that the many limitations imposed by NRCS in the “preferred approach” – the watershed limitation, the payment reductions, the enrollment categories, and additional eligibility criteria – be dropped from the final rule. Instead, NRCS should promulgate a rule that allows and encourages all eligible producers to ...