2024 Program Recommendations for USDA-NRCS

To:  Working Lands Subcommittee of the VT State Technical Committee

From:  White River Natural Resources Conservation District

This year, the White River NRCD staff have assisted on 36 applications, plans, and contracts in the Northeast Zone and South Zone VT-NRCS field offices, across the AFT RCPP, DEC RCPP, CSP, and the Orange/Windsor Local Funding Pool.  The following examples collected by White River NRCD staff highlight specific issues and areas for suggested improvement within the distribution of EQIP and CSP funds, aiming to streamline processes, improve consistency, and enhance the overall effectiveness of the programs.  Further community recommendations can be found in the 2025 White River/Ottauquechee Local Working Group Report.

General Application Issues

Issue: Multiple Application Forms

• Example: Previously, applicants could submit one form (1200) that could be shifted around into the appropriate fund pool. Now, separate application forms are required for each fund pool, increasing the paperwork and complexity for applicants.

Issue: Inconsistent Definitions for Historically Underserved

• Example: Each USDA agency has varying definitions for historically underserved groups.  This creates confusion for already overburdened individuals, redundant paperwork, and inconsistent records.
  • Women: Considered disadvantaged by FSA, not by other USDA agencies.
  • Beginning Farmer: Defined as 10 years filing Schedule F by some, while RMA defines it as 5 years.
  • Veterans: Defined as having left active duty within the last 10 years by NRCS, but 5 years by RMA.

Issue: Inability to Update Payment Rates

• Example: NRCS cannot update payment rates once a contract is signed. This means contracts signed in 2020 still use those rates in 2023, which are insufficient. Farmers have to cancel and reapply to get updated rates.

Issue: Timeliness of Contracts and Payments to Farmers

• Nationwide and statewide delays and glitches in the NRCS’ contracting system have led to all contracts being delayed until likely June or beyond. This timing is not congruent with the reality of farming schedules in Vermont.  

Conservation Stewardship Program (CSP) Issues

Issue: Inability to Combine CSP Contracts in Multiple Pools

• Example: CSP contracts could not be placed in both the IRA and organic pools, leading to funding issues.

Issue: Priority Given to More Complicated Farms

• Example: Farms with more land uses get higher priority in CSP calculations. This results in grazing or regenerative farms not receiving priority despite their needs.

Issue: Requirement for Enhancements on All Land Uses

• Example: CSP-IRA requires enhancements on all land uses. Many “climate-smart” practices are not applicable to farmsteads or associated agricultural land, which can eliminate potential applicants. Inability to plan climate-smart farmstead practices eliminates applicants, even though potential climate impact from most farmstead practices is minor.  The message received by our field staff was there did not need to be big enhancements, just simple enhancements would be acceptable, but that turned out to not be the case.

Issue: Broad Energy Use Assessment

• Example: The CSP assessment for energy use is too broad.  It only asks if there has been an agricultural energy audit and whether any practices were implemented, without a detailed scale. This leads to inaccurate evaluations of energy efficiency.

Issue: Inconsistent Assessments by Planners

• Example: CSP assessments depend heavily on the planner’s interpretation, leading to inconsistent evaluations. Small farms might be thoroughly assessed, while large farms may not be fully evaluated, or every field not visited, creating disparities.

Environmental Quality Incentives Program (EQIP) Issues

Issue: Limited Eligibility by Land Use

• Example: The EQIP-IRA grazing pool only includes pasture, excluding many grazing farms that have grazed cropland. Similarly, the agroforestry pool does not include alley cropping because it is classified as cropland. 

Tool Issues (CD/CART)

Issue: Lack of Integration Between CART and CD

• Example: Changes in data entry fields (land uses, modifiers, etc.) need to be made separately in each tool, creating redundancy and potential errors. CART should be started only after all work in CD is complete.

Issue: Generic Descriptions of Practices in CART

• Example: CART treats all scenarios within a practice the same, providing only a generic description. This makes it hard to differentiate between scenarios, like portable, interior, and HT fence. Planners often rely on a side list or other attributes like scheduling in the CD Practice Schedule.

Issue: Late Agreement Building

• Example: Agreements cannot be built until the very end of the contract creation process, making it impossible to run financial feasibility checks with participants early on. If participants decide to scale down, the pre-approval process must be undone and redone so the proposal can be modified.

Issue:  Unclear contract language

• Example:  The 1155 narrative is generic, providing only the scenario name to inform participants of their commitments, which is often insufficient. As a result, the contract documents fail to clearly outline the specific requirements for the participants.

Issue: Redundant Practice Schedules

• Example: CD does not allow duplicating a Practice Schedule, forcing the creation of new ones from scratch for each application. This is time-consuming and error-prone for complicated proposals.

Issue: Conflicts in Case Files

• Example: PAs are instructed to create new CD Case Files for applicants, and then create a Practice Schedule named for the Program that is applied to. This assumes that no planning has yet been done. They sometimes cannot find existing case files if they are under different names or service centers. In these cases, the PA's replicate the Case Files which creates conflicts rather than cleaning up the data. 

Issue: Multiple CD Case Files for a Client

• Example: Multiple CD Case Files and Practice Schedules for one client can lead to planning work being done in a Practice Schedule other than the one tied to the application. If the proposal is approved for funding, an Agreement cannot be created without undoing the pre-approval to link the Plan to the application.

Local Funding Pool Ranking Issues

Issue:  Local Funding Pools Ranked First

• Example:  Local Funding Pool applications were ranked first, before the general EQIP pool was ranked.  We were instructed to submit applications across multiple pools, including the Local Funding Pool and the Statewide Community Scale Ag Pool in EQIP.  The larger applications that would have ranked high in EQIP soaked up all the funding in our Local Funding Pool.  Out of 13 Local Funding Pool applications, as of now only the 3 largest received pre-approval.

Issue:  Act Now took planning and funding away from pools

• Example:  We had been told to rank CEMAs and Community Scale Ag applications in a statewide pool, but then only recently were told there was no more money available in that pool due to an Act Now pool that had taken place earlier in the year. We had not received any notice of Act Now pools being run.  Act Now seems to take planning technical assistance away from local priorities and standard planning and contracting, creating an experience of “line-cutting”.

Supplemental Report: 6/7/2024

In response to question posed by USDA-NRCS to the STC Working Lands Subcommittee on May 16, 2024: 

Information provided by NRCS:

Q: What high priority practices should get higher cost share for FY2025?

White River NRCD Comments:

We appreciate the opportunity to provide comments to the FY2025 high priority practice list. We would like to suggest an alternative way to develop a high priority list would be to first decide what types of projects should be prioritized for funding as a whole, look at what Resources Concerns those projects address, list the Practices required to complete the projects, then pick the Priority RCs and Practices from those lists. We also believe this question should have more time to be circulated, understood, and discussed among all Local Working Groups.

Here are some comments on the practices included on this High Priority Practice List:

Residue and Tillage Management (CPC 329 & 345):

Few participants get No-Till or Reduced-Till payments from NRCS. The payment rates are low ($20/ac), there was an earlier (unenforceable but understood) interpretation that a farm that was already doing no-till would not be eligible, and many of the large farms have since gone to full-width shallow tillage to plant or terminate cover crops, so there isn't that much interest in continuing this practice. Not many large farms are running the large and expensive no-till grain drills needed to establish rye. Broadcasting the seed and then a light harrowing is faster and requires less hand labor and equipment.  These practices may not be appropriate to continue to include on this list since they are taking up two valuable positions on the high priority list and do not have a high impact on the farmers’ bottom line.

Fence (CPC 382):

Fence is often listed as Secondary to Prescribed Grazing, meaning that it doesn't get any points in the CART Assessment, so it does not mean much to give it a high priority in ranking, unless Fence is being used to exclude livestock from surface waters as part of a grazing system, in which case it could be a Primary Practice and might jump up the ranking list. It may be better to list Prescribed Grazing as the priority if the goal is to support grazing farms.

Grazing operations generally ask for: fence, water systems (troughs & tanks, pipeline, spring development, wells, pumps), brush management, laneways and trails, seeding, and grazing payments. Consider adding these practices if the goal is to support grazing farms.

Heavy Use Area Protection (CPC 561):

Heavy Use Area is usually a farmstead/waste management Practice for CAFOs, but it can also be used under permanent waterers. Unless the interpretation has changed recently, the farmstead ones require collecting the runoff, so are not useful for smaller farms on non-dairies. If the goal is to continue to heavily favor dairy waste storage, Waste Transfer and Waste Storage Facility Practices are sufficient to fill this need and CPC 561 could be removed from this priority list. 

Tree & Shrub Establishment (CPS 612):

Now that VT has a number of Agroforestry Practices available, there will be less interest in planning CPS 612. Silvopasture, hedgerow, or alley cropping should be scheduled instead to capture the participants’ actual interests.

Recommend including Conservation Crop Rotation (CPS 328) in the high priority list and maybe create some additional scenarios for a year of soil-building crop.  Additionally, increasing adoption of Grassed Waterways on CAFO dairies would benefit waterways as opposed to putting gravel in wet areas.