The 2002 farm bill authorized the use of a third party system to help better serve growers and landowners participating in federal conservation programs. The rule went into effect March 1, and the Natural Resources Conservation Service (NRCS) has been soliciting comments from interested parties with suggestions for program improvements.
The USA Rice Federation and U.S.Rice Producers Association believe expansion and improvement of the third party technical service provider system is vital to the long-term viability of conservation programs.
However, reporting mixed experiences in past dealings with local NRCS offices, rice producers say they need the flexibility to work with their local NRCS office if they feel comfortable with the service that is provided, and if the NRCS staff is available. If either availability or technical expertise is limited by using the NRCS staff, then producers should be able to use a certified third party provider, they say.
Each of the groups submitting comments seem to agree that the certification process for third party providers should be uniform, rigorous and task specific, while still flexible enough for a third party provider to qualify for one of more specific types of work.
“If NRCS is to use third party providers then the bar should be set high so that only people that are truly qualified in an area receive certification,” the rice groups say. “Once certified, a third party's recommendations should receive the same weight as assistance provided by local NRCS county officials. For third party assistance to work well, and in fact ease the workload and bottlenecks at the local NRCS offices, the work prepared by the third party provider should not require review and approval by the county conservationist in order to advance in the process.
“The whole point of a third party provider system is to ease the workload of the county offices while providing quality technical assistance,” they say. “If the county office must also approve every project plan that is prepared by the private sector, the why have the private sector involved in the first place?”
The Society of American Foresters agrees current NRCS staffing levels are not sufficient to meet the increased demands resulting from the new programs and additions to existing programs in the 2002 Farm Bill.
Instead of overloading government staff, the two rice groups say local NRCS staff should act as a watchdog, or layer of local scrutiny for third party work, and should report poor performance to a review panel. “They should not be burdened with reviewing every plan.”
Taking a different stance, the National Campaign for Sustainable Agriculture says NRCS should review and approve all conservation plans prepared under the technical service provider program.
“The review is necessary to insure that conservation plans adequately address both the needs of the producers for sound planning advice and the goals of the conservation programs,” the Washington, D.C. based group says.
Saying it finds “significant problems” with the rules governing technical service providers, the National Campaign for Sustainable Agriculture asks that fertilizer and chemical dealers, irrigation equipment salespeople, and other agricultural input companies not be approved as third party technical service providers.
“This may not only compromise the integrity of the conservation assistance, but will distort the farm bill conservation programs by gearing them toward practices and products that provide profits to service-providing businesses that also supply agricultural inputs,” the group says. “Certified technical service providers should not have a financial interest or stake in the sale of materials, equipment, infrastructure, or inputs necessary for implementing a conservation plan.”
The USA Rice Federation and the U.S. Rice Producers Association agrees that the presence of “alternative agendas” could potentially be problematic. “If USDA sees that a group is misusing their status as a technical service provider then procedures should be in place to remove their certification.”
Adds the Society of American Foresters, “Ensuring strict adherence to performance quality standards should be actively pursued, and be a part of the overall quality assurance and quality control programs already in place. This will allow the Agency to protect the public from individuals who are incompetent in providing the necessary assistance.”
Third party technical service providers could also supply the input needed to establish payments rates, maintain lists of providers, and refer producers to those providers.
“The third party initiative should not lessen the ability of NRCS to deliver conservation technical services, but should provide an added capability,” says the National Association of Conservation Districts. “The most critical element of all in ensuring the success of the initiative will be adequate funding through the Farm Bill conservation programs. Funding to date for technical assistance falls far short of what NRCS needs to provide assistance through its own cadre of technical professionals. It will be absolutely essential to greatly increase this funding in order for NRCS to implement the initiative to its full potential.”