Rules Should Reflect The Law
Mark Lange
What are the concerns about the rules?
The USDA rule goes well beyond the 2008 farm law provisions. For example, the farm law does not contain the USDA-imposed requirement that all members of a farming entity make a regular, identifiable, documentable, separate and distinct contribution of active personal labor or active personal management. Despite comments from the NCC and most commodity and general farm organizations, as well as a letter cosigned by 69 representatives and 21 senators urging the Secretary to publish a final rule that more closely reflected Congressional intention, USDA rejected virtually every recommendation and is moving forward with reviewing 2010 farm plans based on the Final Rule.
In addition, the NCC filed comments with USDA expressing concerns with actions regarding the Conservation Stewardship Program (CSP). Producers are being encouraged by USDA officials to enter into CSP contracts that do not conform to the underlying statute. The 2008 farm law clearly establishes a five-year payment limit of $200,000 per "person or legal entity" for "all contracts" entered into during any "five-year period." Without basis, USDA has instituted an overly-restrictive limit of $40,000 per year on CSP participants and a five-year limit of $200,000 per contract, regardless of the number of participants associated with the contract.
source : cottonfarming
Mark Lange
What are the concerns about the rules?
The USDA rule goes well beyond the 2008 farm law provisions. For example, the farm law does not contain the USDA-imposed requirement that all members of a farming entity make a regular, identifiable, documentable, separate and distinct contribution of active personal labor or active personal management. Despite comments from the NCC and most commodity and general farm organizations, as well as a letter cosigned by 69 representatives and 21 senators urging the Secretary to publish a final rule that more closely reflected Congressional intention, USDA rejected virtually every recommendation and is moving forward with reviewing 2010 farm plans based on the Final Rule.
In addition, the NCC filed comments with USDA expressing concerns with actions regarding the Conservation Stewardship Program (CSP). Producers are being encouraged by USDA officials to enter into CSP contracts that do not conform to the underlying statute. The 2008 farm law clearly establishes a five-year payment limit of $200,000 per "person or legal entity" for "all contracts" entered into during any "five-year period." Without basis, USDA has instituted an overly-restrictive limit of $40,000 per year on CSP participants and a five-year limit of $200,000 per contract, regardless of the number of participants associated with the contract.
source : cottonfarming
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