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The Farm Bill’s conservation title includes a suite of programs that pay farmers for implementing conservation projects on their land. These programs are beneficial for numerous reasons: they encourage practices that sequester carbon, clean up the water, create wildlife habitat and make farms more resilient to extreme weather. One of these programs is the Environmental Quality Incentives Program (EQIP), which supports farmers putting environmental best practices in place for the first time. The Natural Resources Conservation Service (NRCS) recently released new program rules for EQIP, and IATP submitted comments on this Interim Final Rule urging the agency to increase the program’s focus on climate change and hold factory farms accountable for their pollution.

Over the past two decades, more than 380,000 farmers benefitted from the program and implemented conservation practices on over 115 million acres. These numbers are especially important because EQIP supports first-time conservation practices. In many cases, these EQIP contracts were the start of longer-term conservation planning on farms. From a climate perspective, conservation practices are a key element in making agriculture a carbon sink. EQIP supports planting cover crops, transitioning to more diverse crop rotations, installing infrastructure for rotational grazing and much more. All of these activities sequester carbon while also building soil health. The healthier the soil, the better a farm can withstand droughts, floods and extreme weather events.

The 2018 Farm Bill added soil health planning, resilience to weather variability and drought resilience to EQIP statutory language. However, the Interim Final Rule’s list of priorities failed to include these. In IATP’s comment, we encouraged NRCS to make sure soil health and climate are included as specific EQIP priorities. Farmers are struggling from climate impacts across the country, including extreme flooding in the Midwest in 2019, hurricanes in the Southeast in 2018 and intense drought throughout the country in 2012. Conservation programs should consciously invest in mitigating climate change and helping farmers adapt.

Unfortunately, much EQIP funding goes to confined animal feeding operations (CAFOs). CAFOs harm the environment, rural communities, independent family farmers and public health and should not qualify for conservation funding. Yet, CAFOs are eligible for EQIP dollars to build and expand animal waste storage. In fact, EQIP has a 50% set-aside for livestock operations, much of which goes to support CAFOs at the expense of small to mid-sized sustainable operations.

CAFOs pack thousands of animals into a small space, producing enormous amounts of manure that is liquefied and stored in lagoons. These lagoons are closely linked to water contamination, are a top emitter of methane and severely harm quality of life for nearby communities, which are often minority and low-income. These operations should not be eligible for any public funding, but since they are under the most recent Farm Bill, they should at least meet strong requirements to minimize environmental damage.

Congress originally prohibited the participation of CAFOs in EQIP but then changed the law to allow their participation in the 2002 Farm Bill. At that time, Congress also said that CAFO operators needed to develop and implement a USDA-approved comprehensive nutrient management plan. Although these plans do not offset the overall harm that CAFOs cause, they do add a modicum of environmental protection.

The 2018 Farm Bill weakened this standard. It said that although CAFOs still require a comprehensive nutrient management plan, that plan no longer needed to reach the USDA standard requirements but rather just show progress toward that standard. This weakening in and of itself was deeply disappointing, but the EQIP Interim Final Rule diminishes it even further by removing the requirement to implement a comprehensive nutrient management plan at all. It states that CAFOs must simply write a comprehensive nutrient management plan, and the plan doesn’t even need to be written until the very end of the EQIP contract period. This lets CAFOs off the hook for their pollution and runs contrary to the entire ethos of EQIP as a conservation program.

In IATP’s comment, we encouraged NRCS to return to their previous rule – that CAFO operators must both develop a comprehensive nutrient management plan and demonstrate progressive improvement throughout the EQIP contract. Returning to that previous rule isn’t enough, but it’s the least NRCS should do. In the long term, IATP will continue to advocate that CAFOs should not receive public support of any kind.

Conservation programs are critical tools to help farmers deal with climate impacts and direct public money to practices that can help mitigate climate change. It’s essential that these programs work fairly by rewarding small to mid-sized producers who are implementing truly sustainable practices.

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