The following email message is from Brad Crabtree, a North Dakota sheep and cattle farmer who was program coordinator of the Consensus Council, which facilitated development of a unique initiative during 1997-1998 in response to years of repeated and devastating flood losses in the Dakotas, Minnesota, and the Canadian province of Manitoba.

Faced with billions of dollars in damage, the U.S. Federal Emergency Management Agency (FEMA) and Manitoba launched the International Flood Mitigation Initiative (IFMI) to develop basin-wide strategies to deal with future floods.  IFMI formed a working group of government, agriculture, and conservation interests to identify ways to foster flood mitigation on private lands. Following the conclusion of their efforts in 1999, the group presented the “Farmland Stewardship Initiative” to Congress and FEMA.

The “Farmland Stewardship Initiative” was subsequently blended with a similar initiative that began in Florida, which led to introduction of the American Farmland Stewardship Act by Rep. Adam Putnam of Florida in July 2001.

This email was written in response to a request from a U.S. Senate staff member.  Brad’s response appears below:

Date: Fri, 01 Mar 2002 13:51:25 -0600
From: Brad Crabtree <crabtree@drtel.net>
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Subject: Observations on FSP and CSP

Thanks for asking for my comments on the Farmland Steward Program (FSP) relative to the Conservation Security Program (CSP).  I now work pro bono on this and am no longer well-versed on the nuances of existing language for both programs, so my comments are of a more general and philosophical nature.  Specific questions regarding legislative language are best answered by Craig Evans [email craig@privatelands.org], who has been working on this issue throughout the Farm Bill debate.

No Inherent Incompatibility

There is no fundamental incompatibility between CSP and FSP.  CSP is a funding program with a partially reformed mechanism for implementation of conservation on the ground.  By contrast, FSP is not a funding program, but would instead draw on the universe of existing public and private programs to assemble and fund service contracts with producers.  FSP's implementation mechanism is the heart of the program and its value, providing full one-stop shopping -- integration of multiple programs, objectives and criteria, conservation plans, paperwork and payments -- is only available in Tier III of CSP.

So, FSP can be used in Tier III of CSP to implement CSP funds, or a producer could still elect to participate in the CSP program as proposed.  FSP can apply otherwise across the board with hundreds of existing federal, state and private conservation programs.  

My recommendation is support both.  We need the extra CSP dollars for conservation, and producers ought to have the choice as to which mechanism they want to use.  In other words, take the money and let the market of voluntary producer preferences decide which implementation mechanism is superior over time.

If it becomes necessary politically to make a choice between the two in conference, here's why I recommend that you support the Farmland Stewardship Program:  

Complexity

CSP is complex at a time when nearly everyone I talk to with firsthand experience of conservation on the ground is saying that we need greater simplicity in our farm programs.  Complexity harms conservation by making programs less optimally effective and more costly than they need to be.  And it gives yet another advantage to larger producers over smaller ones who have the resources and know-how to navigate that complexity .

I have read the CSP bill several times where it describes the three tiers.  It is mind-numbing.  To its credit, Tier III opens the door to greater flexibility and compensation, but only after setting very high the bar of commitment and resources on the part of the producer.

FSP Offers the Best Hope for One-Stop Shopping

There are literally hundreds and hundreds of public and private programs available to producers.  This was demonstrated by a North Dakota State University Extension study of programs available to Devils Lake area farmers in North Dakota.  No one producer can keep track of even a fraction of these programs, let alone do the paperwork for managing more than a handful at best.  The beauty of FSP is that it creates a mechanism for assembling these multiple programs into a single ecologically comprehensive and administratively manageable package.

Whereas FSP institutionalizes one-stop shopping, CSP makes it available in a limited and circumscribed way.  There is language elsewhere in the Senate bill promoting one-stop shopping (Sec 205), but only as a proposed study. 

One-stop shopping was in the previous farm bill as part of the Conservation Farm Option, but it was authorized and never funded.  Senior USDA people in DC told me that there was little interest in the Department, even if Congress had appropriated money.  Also, I saw first-hand the turf battle that our Red River Basin proposal set up between FSA and NRCS, which led then-Secretary Glickman to abandon FEMA Director James Lee Witt as he was en-route to meet with Sen. Edwards to secure inclusion of Farmland Stewardship in the North Carolina disaster relief package.

I am not confident that USDA will respond to Congress's intent in Sec. 205 because of the threat to turf of individual agencies within USDA.  FSP mitigates this by providing for program assembly at the local level, so federal agencies do not come into conflict with each other.  Tier III in CSP is faint-hearted reform compared to FSP.

Erroneous Approach to Incentives

Implicit in CSP is the idea that in order to receive the benefits of greater compensation, flexibility, adaptability and simplicity, you must make a substantial commitment to conservation practices.  Why is that? You and I know well the depth of skepticism and mistrust on the part of many producers toward the government even as they are hopelessly dependent on the government.  This mistrust only deepens in the realm of conservation.  Why require producers to go whole hog on new management practices (i.e. Tier III) before they see the benefits of a new approach?  

If a skeptical producer is only willing to take a baby step, why not use that as an opportunity to make that experience as attractive as possible for him/her.  Then, he/she might elect to do more in subsequent years.  I had the impression when I read the CSP that the folks who drafted it failed to appreciate how living, breathing farmers and ranchers respond to incentives. 

More Options

While the Senator's staff never had authorizing language drafted for the version of Farmland Stewardship developed in our region, they indicated to me several times that they preferred FSP to CSP because it encompassed a broader, more holistic approach to rural development and revitalization.  Due to its broader criteria and access to a more diverse pool of funding programs, FSP takes a more comprehensive approach to conservation than CSP and can include flood mitigation, creation of rural recreation and tourism amenities, and many other things of value and importance to rural North Dakota. 

Payment for Services Rendered

This Farm Bill is significant for the public debate that has focused on commodity payments. Both CSP and FSP open the door to a politically sustainable approach to farm programs over the long term -- paying producers for explicit services of benefit to the public at large rather than to produce or not produce particular commodities.  For reasons cited above, FSP is a better implementation tool than CSP in that regard because it enables a wider range of stewardship services to be included and compensated and, therefore, supports a broader conception of future farm policy.

Involvement of Private Groups

When you and I first talked about Farmland Stewardship several years ago, you pointed out that the state of North Dakota needs to show more leadership and investment in conservation.  I could not agree more.  FSP addresses North Dakota's leadership vacuum by opening the door to significant participation by nonprofit groups in the funding and implementation of conservation practices--with money, new ideas and expertise.

Emphasis on Flexibility for Results

FSP, more so than CSP, places the emphasis where it needs to be -- on results, and it provides the flexibility necessary to achieve them.  Too often, American environmental/conservation policy is the product of battles between ag and industry groups who seek loopholes, on the one hand, and environmental organizations that fear those loopholes, on the other.  Flexibility and commonsense are out, micromanagement is in, and the majority of farmers/ranchers, local conservationists and other citizens who just want workable solutions are the losers.  FSP is the program for the folks in the middle who want to do the right thing.

Will mistakes be made due to greater flexibility?  Perhaps, although the waiver of provisions in the earlier FSP language that caused so much concern have been changed in consultation with a wide range of ag, environmental and other groups.  Still, the rewards of greater flexibility in implementation (not necessarily in standards) are greater than the risks and are in evidence overseas.  

Those countries that have accomplished the most environmentally -- Denmark, the Netherlands, New Zealand to name a few -- have done so by taking some risks with flexibility and shifting their focus away from prescriptive measures to bold outcomes, while keeping regulatory standards and enforcement on the books for future use if needed.  The Dutch have been especially successful with this in the realm of agriculture and conservation.  This shift has unleashed creativity, goodwill, cooperation, increased economic productivity and better environmental outcomes.

FSP embodies this new generation of public policy that other countries have pioneered; CSP only takes us half-way there.  Many producers and conservationists alike are very frustrated by the shortcomings of many federal programs and policies and the rigid and unproductive attitudes of some of those who tend to dominate the debate.  Most producers will support sound environmental stewardship with the benefit of effective policy tools.  I believe that FSP is precisely the kind of tool that will allow us to encourage stewardship while also preserving flexibility and common sense.

I hope these comments are of use to you.  A matrix comparison of FSP and CSP can be found on the web at www.privatelands.org/CSP_compare.htm  You might find it helpful.

Brad

It is worth noting that:

The CSP provides funding for conservation on working lands -- funding that otherwise would not be available through any other program that can be combined into an FSP.  

On the other hand, the FSP makes the CSP a more locally-based, locally-driven program and, thus, fixes  problems that some groups have objected to in the CSP and which Brad describes above.

Conclusion:  We need BOTH programs, since they both complement and support each other.

For further information on the Farmland Stewardship Program, please contact Craig Evans, President, Florida Stewardship Foundation, 561 NW 53rd Street, Suite 240, Boca Raton, FL 33487, Cell phone 561-289-9690, email craig@privatelands.org.

Or visit the links below--