Source:NATIONAL SUSTAINABLE AGRICULTURE COALITION, 12/18/13

Last week, USDA’s Natural Resources Conservation Service (NRCS) provided its state NRCS offices with national guidance on when and how to administer 13 conservation initiatives for fiscal year (FY) 2014.
The national guidance covers a number of initiatives that NSAC tracks closely, including the National Organic Initiative (NOI), National Seasonal High Tunnel Initiative (NSHTI), and the Mississippi River Healthy Watersheds Initiative (MRBI).  It also covers the National On-Farm Energy Initiative (NOFEI) and the Working Lands for Wildlife (WLFW) “certainty” initiative, which exempts producers from regulation under the Endangered Species Act in exchange for the implementation of a conservation plan.

In addition to the four initiatives listed above, the guidance governs the implementation of the:
•      Bay Delta Initiative (BDI)
•      Gulf of Mexico Initiative (GoMI)
•      National Air Quality Initiative (NAQI)
•      Illinois River Subbasin and Eucha – Spavinaw Lake Watershed Initiative (IRWI)
•      Ogallala Aquifer Initiative (OAI)
•      Long Leaf Pine Initiative (LLPI)
•      Everglades Initiative (EI)
•      Driftless Area Initiative (DAI)

Earlier this fall, NRCS issued a separate guidance with the list of dates by which producers must apply in order to be considered for funding in FY 2014.  Similar to last year, the cut-off date choices for states are October 19, November 15, December 20, January 17, February 21, March 21, April 18, and May 16.
NRCS national headquarters is encouraging state offices to establish multiple cut-off dates and to accept applications through May 16 as necessary, with that last cut-off date applying especially to high tunnel and organic initiatives.  If your state does not decide to accept high tunnel and organic applications through May 16 we want to hear from you.

States are required to announce dates at least 30 days in advance.  However, if there is a compelling reason that a tight turnaround is required, NRCS can waive the 30-day requirement.

Check your state’s NRCS website to see if they have announced ranking dates for FY 2014.  If they have not done so, now is the time to contact your state office to inquire about the dates.

Each of these initiatives is funded through the Environmental Quality Incentives Program (EQIP), Agricultural Management Assistance (AMA) program, Conservation Stewardship Program (CSP), Wetlands Reserve Enhancement Program (WREP) and/or Wildlife Habitat Incentive Program (WHIP).

Important Changes to the EQIP Organic Initiative
Once again, the EQIP Organic Initiative is available to certified organic producers, transitioning-to-organic producers, and producers who are exempt from certification under National Organic Program (NOP) rules:
•      Certified organic producers must provide NRCS with a copy of their NOP Organic Certificate or proof of good standing from their certifying agent.  They must also maintain their certification throughout the life of the EQIP contract.
•      Both transition-to-organic and exempt producers must self certify that they will develop an Organic System Plan (OSP); however, transitioning producers no longer have to provide contact information for their certifying agent.  In previous years, this requirement was problematic for transitioning producers because most producers do not establish a relationship with a certifier until they are ready to be certified.

Unlike last year, NRCS is not requiring that some minimum number of conservation practices be offered through the Organic Initiative.  Instead, farmers will have access to all EQIP conservation practices.  This includes Conservation Activity Plan 138, which assists transitioning-to-organic farmers with the development of a conservation plan.  For FY 2014, farmers will be able to use the Organic Initiative to address all EQIP resource concerns, including energy conservation and air quality resource concerns, which were excluded in FY 2013.

Applications for the Organic Initiative will be ranked based on national and state-level criteria included in the bulletin, as well as local criteria, which is to be set by the states.  National ranking criteria will account for 25 percent of available ranking points, while state criteria will account for 40 percent of the points.  Local ranking criteria will account for 25 percent of available ranking points.  A cost efficiency score will determine the remaining 10 percent.

Like last year, there are no ranking threshold cut-off points for the Organic Initiative in FY 2014.

Seasonal High Tunnel Initiative
Two major changes differentiate this year’s High Tunnel Initiative from that of last year.  First, there is no longer a limit on the size of the high tunnel, though NRCS likely would be critical of unreasonably large proposals.  Contracts that get close to or exceed the $300,000 payment limitation, for example, will likely be rejected.  The previous size limitation of 2,178 sq. feet made it difficult for many producers in colder climates to take advantage of the Initiative.  The removal of the one-size-fits-all size limit is a significant advance.

Second, NRCS no longer requires state NRCS offices to offer the High Tunnel Initiative, though states are required to offer the conservation practice standard, Seasonal High Tunnel System for Crops (798).  In other words, high tunnels must be offered to farmers in all states, but states have the option of whether or not to make it a special initiative with its own separate pool of funds.

We expect that rather than offer the stand-alone initiative, some states will chose instead to offer the practice as part of regular EQIP.  We strongly encourage readers to monitor the status of the High Tunnel Initiative in their states.  If your state chooses not to offer the Initiative, we want to hear from you.  Under that scenario, it will be important to examine how applicants that propose to implement the high tunnel practice (798) stack up against other EQIP applicants.  We suspect that USDA may be monitoring this as well, and may go back to mandatory initiative status in the future if it appears farmers are having difficulty securing high tunnel contracts.

Mississippi River Basin Initiative
The FY 2014 guidance for the MRBI is much the same as the FY 2013 guidance.  MRBI is administered through EQIP, WHIP, WREP, and CSP.  The most striking difference between last year and this year is that NRCS is no longer accepting MRBI applications through the Wetlands Reserve Enhancement Program due to a lapse in authority when the 2008 Farm Bill extension expired earlier this fall.  With that expiration, NRCS lost its authority to accept farmers and ranchers into the Wetlands Reserve Program, and therefore into WREP.  NRCS continues to service prior year contracts.

For the MRBI, there is a list of core practices and a list of supporting practices relating to avoidance, control, and trapping of nutrient and sediment pollution.  States have the option to offer other supporting practices at their discretion.  The guidance also allows states to offer several conservation activity plans.
NRCS will soon issue a follow up guidance relating to water quality monitoring through MRBI.  According to the bulletin, “edge-of-field water quality monitoring activities will be available for inclusion in fiscal year 2014 contracts.”  In recent years, edge-of-field monitoring has expanded as a practice in various watersheds across the country.

Unlike the Organic Initiative and the Seasonal High Tunnel Initiative, states develop the state-level ranking criteria and project sponsors develop the local-level ranking criteria.  NRCS headquarters is responsible only for developing the national level ranking questions.  National and state-level ranking criteria will each account for 25 percent of available ranking points, while local criteria will account for 40 percent of the points.  A cost efficiency score will determine the remaining 10 percent.

On-Farm Energy Initiative
The FY 2014 guidance for the EQIP On-Farm Energy Initiative is largely the same as last year’s guidance, with one primary exception.  Due to the high demand for the Initiative, the national guidance allows states with a large backlog of completed Agricultural Energy Management Plan (AgEMP) Conservation Activity Plans to rank those applications separately from applications for new AgEMP Conservation Activity Plans.  These plans are similar to other on-farm energy audits.

Working Lands for Wildlife
In September 2012, NRCS announced the Working Lands for Wildlife initiative, a partnership between USDA and the Department of the Interior to conserve threatened and endangered species and provide producers with “regulatory certainty” for up to 30 years.

The national guidance provides a list of core practices that participating states must offer for each of the seven covered species.  The U.S. Fish and Wildlife Service requires that additional conservation measures be taken for each species when implementing core and supporting conservation practices through the initiative.

The national guidance establishes three initial screening criteria for “high priority” applications, “medium priority” applications, and “low priority” applications.  Additionally, NRCS headquarters developed national and state ranking questions, while the states are required to coordinate with State Technical Committees to develop local ranking questions.  In some cases, the ranking questions and scores are specific to the wildlife species.  Like the Organic Initiative and Seasonal High Tunnel Initiative, national and local ranking criteria each count for 25 percent of the ranking score, while state ranking criteria count for 40 percent.
As the FY 2014 sign up for NRCS conservation initiatives moves forward, organizations should reach out to farmers and ranchers who may be interested and encourage them to contact their local NRCS field office.  We will monitor the progress of the FY 2014 sign up, and will report final numbers late next year.