Organic Consumers Association


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Tell Congress to Fund a National Program to Help U.S. Farmers Convert to Organic

Posted June 6, 2005

From: National Campaign for Sustainable Agriculture


Some states (Minnesota, Massachusetts, and Montana) already offer EQIP incentive payments to support producers transitioning to organic production. These payments are available during the 3-year transition period. Comment BY THIS SUNDAY to have Organic Transition included as a National Priority in all states.

In addition, there are two other priorities of importance to organic producers including Grazing and Pasture land, and Native Pollinator Habitats.

Please feel free to use these template comments below (thanks to Organic Farming Research Foundation and Sustainable Agriculture Coalition), and feel free to add your own language as to why these are important to you.



Re: Comments on FR Doc: 05-05556, National Priorities for the Environmental Quality Incentives Program

To Whom It May Concern:

1. Establish an EQIP National Priority for Organic Transition Incentive Payments, for land that is in transition to organic production, and assistance for organic farmers and ranchers.

Under existing law and guidelines, EQIP incentive payments may be provided for up to three years to encourage producers to implement innovative management practices. We would encourage this priority for farmers who have long, costly transition challenges such as dairy farmers converting to organic dairy production.

Some states, including Massachusetts, Montana, and Minnesota have used incentive payments to support producers transitioning to organic production. These transition incentives payment programs assist farmers who choose to convert acreage to organic production. To qualify, farmers must file organic system plans at their local NRCS offices, and be inspected by a USDA-accredited certifying agent.

Organic production meets many of the goals of the EQIP program by offering growers a means to optimize environmental benefits. Practices that are key components of organic production such as cover cropping and crop rotations, serve to reduce non-points source pollution from synthetic pesticides, herbicides, and fertilizers while increasing biodiversity.

Yet the three years transition period from conventional to certified organic systems can be difficult. Growers often struggle to manage their land in a new way that can be more labor intensive yet they cannot sell their product at the organic price premiums. Research and extension are often not available to growers seeking information on organic production.

Availability of EQIP funds to support growers transition to organic production practices is a cost effective way to create positive returns for the environment and our economy.

2. Establish an EQIP National Priority for Grazing and Pasture Land Managed under Sustainable, Intensively Managed Livestock and Poultry Production Systems.

The 2002 Farm Bill specifically directs the agency to encourage the use of grazing systems, such as year-round, rotational or managed grazing systems, that enhance productive livestock and poultry operations. Promotion of these sustainable production systems achieves another major purpose of EQIP
- to assist producers to make beneficial and cost-effective changes to their productions systems with regard to nutrient management, grazing management and other practices. Giving priority to sustainable livestock and poultry production systems also addresses the statutory requirement that the Secretary accord a higher priority to providing assistance and payments that encourage use of cost-effective conservation practices.

We recommend an EQIP national priority for incentives for intensively managed production systems that address multiple resource concerns, e.g. water quality, wildlife habitat, and soil erosion control, simultaneously through well-designed, well-managed systems. The goal is to provide financial incentives and technical assistance to farmers and ranchers to establish managed rotational grazing and other sustainable pasture and grass-based livestock production systems.

We further recommended that this EQIP national priority be used to encourage owners of land that is coming out of Conservation Reserve Program (CRP) contracts to establish grass-based production systems rather than return the land to intensive cropping which could result in soil and wind erosion problems, wildlife habitat degradation, increased sediment runoff, and other significant resource problems. Between September 30, 2007, and 2010, CRP contracts for more than 28.7 million acres are scheduled to expire. Establishing an EQIP national priority in FY2006 for sustainably managed grazing and pasture land will lay the groundwork for a major EQIP role in meeting the conservation needs of landowners and agricultural producers who want to retain a significant portion of the conservation values obtained from having land enrolled in the CRP but who either are unwilling or unable to re-enroll the land in the CRP.

We also encourage USDA to combine this EQIP national priority with additional incentives for beginning farmers and ranchers, particularly a special transition period prior to the end of the CRP contract during which the beginner could use EQIP funds to start making conservation and land improvements or even make limited economic use of the property, consistent with an approved conservation plan. Such a transition period could help beginning farmers and ranchers establish managed intensive, rotational grazing operations.

3. Establish an EQIP National Priority to Increase Native Pollinator
Habitat & Promote Management Practices, Including Pesticide Use Management,
to Protect Native Pollinators.

We recommend that NRCS add to the list of EQIP National Priorities a priority for the increase of native pollinator habitat and on-farm practices to protect native pollinators.

A key purpose of this recommendation is to preserve and increase the production in the U.S. of agricultural crops that depend on pollinators for their propagation or for increases in production yield and quality. An EQIP national priority focused on native pollinators can also further numerous conservation goals including an increase in native plant habitat and an overall increase in wildlife habitat. The priority will also promote improved management of pesticide use, which can result in increased protection of wildlife in addition to native pollinators and improvements in water quality.

An EQIP national priority for native pollinators can be implemented initially through existing NRCS conservation practice standards. We also recommend that NRCS develop new standards and criteria for protection and conservation of pollinators, similar to current pest management practices for creating habitat for beneficials. This should include managing lands to reduce native pollinator habitat loss, reducing pollinator mortality due to improper pesticide use, and specific attention to practices designed to restore native pollinator populations and habitat.

We assume that in implementing this priority NRCS State Conservationists will consult with their State Technical Committees and with experts in their region and states to tailor existing conservation practice standards and design interim standards to increase native pollinator habitat and prmote on-farm practices to protect native pollinators.

Thank you for the opportunity to comment on this important national program.