Policy Update: AFT Submits Interim Rule Comments on RCPP
Earlier this week, AFT’s policy shop submitted comments on the Interim Rule for the Regional Conservation Partnership Program (RCPP), the last of five conservation program rulemaking processes following the 2018 Farm Bill. We commented on three primary areas (project administration, outcomes measurement and reporting, and conservation easements), and mostly focused on requesting additional clarification on the new regulations. Read the condensed summary below:
- Commended NRCS on: simplifying the application process; prioritizing proposals that provide outreach to disadvantaged, limited resource, and beginning farmers and ranchers; creating the role of state-level RCPP coordinator; and for upgrading to the online Conservation Application Ranking Tool (CART) system
- Encouraged NRCS to: simplify the portions of the application relating to budget templates, payment schedules, and interim conservation practice standards; evaluate project renewals based on project demand and partnership strength.
- Suggested that NRCS: specifically include “soil health improvements” as a “natural resource improvement”; adopt internal practices to further engage with, and track, women who participate in RCPP; and not require lead partners to make an arbitrary minimum financial contribution to project costs.
Outcomes Measurement and Reporting:
- Requested that NRCS: improve data sharing on EQIP and CSP practices within RCPP project areas.
- Requested additional guidance regarding: requirements for outcomes reporting, including providing standards for metrics and data collection, clarification about acceptable models.
- Encouraged NRCS to: allow partners to use region-specific models for outcomes reporting; and work with stakeholders to develop best practices regarding outcomes measurement and reporting and provide training to project leaders.
Agricultural Conservation Easements:
- Commended NRCS for allowing mostly forested farms to be eligible for conservation easements through RCPP.
- Requested: more clarification regarding new template deeds that will be used for U.S.-held easements, and the minimum deed terms; and that NRCS define farmland and ranchland protection as a qualifying “natural resource improvement.”
- Recommended that: the cost-share requirements for entity-held easements mirror ACEP-ALE cost-share requirements; and that entities be allowed to use their own easement deed terms and conditions.
- Encourages NRCS to: allow Buy-Protect-Sell transactions for U.S.-held easements; and to use the Adjusted Gross Income waiver liberally.