I'm no expert on the subject, particularly since my knowledge of the matching process between NRCS data and FSA data is so out of date. But the study seems professional and hits all the bases, although it obviously is pushing for changes in conservation compliance.
A couple quotes I found interesting:
- the report says linking crop insurance with conservation compliance was dropped in the 96 farm bill to encourage participation in crop insurance. It argues that goal has been achieved so the requirement should be reinstated.
- the report's interesting on the process of easing up on the initial 1986equirements. I was sort of peripherally aware of some of the changes, but mostly of the fact NRCS did not at all like having to change from a service/educational agency to a regulatory one.
there has been less focus on the FSA officials who have had the lead administrative responsibility for the law from the outset. FSA officials are responsible for making final determinations on whether producers qualify for the most important exemptions and variances, including the good faith exemption, graduated penalties and eligibility for relief because of economic or personal hardship. NRCS’s more limited role is to provide the technical information and guidance for the decisions made by FSA. According to some observers, FSA officials, who have extensive experience with enforcement of commodity program rules, have been largely unwilling to deny farm program benefits to farmers who do not actively implement their conservation plans. It is FSA that bears the greatest burden of responsibility for the law’s ineffectiveness and the apparent acrimony between FSA and NRCS officials. [page 18]
ongoing rancor between USDA’s Farm Service Agency, which has the lead responsibility for enforcement, and the Natural Resources Conservation Service, which provides technical assistance to farmers and conducts spot checks of compliance, has contributed to enforcement failures. [page 22]I wonder whether part of the resistance to the idea of combining SCS and ASCS in the early 1990's was the fear that, if you put everyone in one agency, the enforcement of conservation compliance would have been more effective.