Proposed Revisions to the National Handbook of Conservation Practices

The National Sustainable Agriculture Coalition (NSAC) supports the proposed revisions to the NRCS conservation practice standards, particularly the efforts to simplify standards and align them with current resource concerns. However, they provide specific recommendations to reinstate certain deleted purposes, include more robust language for organic production systems, and clarify technical details across several specific practices.

Pheasants Forever and Quail Forever, a nonprofit organization dedicated to upland habitat conservation, support the proposed revisions to the National Handbook of Conservation Practices. They provide specific recommendations to strengthen wildlife timing criteria, suggest additional practice combinations for prescribed burning, and advocate for language that prioritizes native forage and clarifies vegetation management goals.

The Virginia Association for Biological Farming (VABF), a non-governmental organization, supports the proposed revisions to the NRCS Conservation Practice Standards. They advocate for specific language additions to ensure the standards are compatible with USDA National Organic Program (NOP) requirements and recommend expanding the purposes and criteria for several practices to better address soil health, water quality, and organic production needs.

The Association of Fish and Wildlife Agencies supports the proposed revisions to the National Handbook of Conservation Practices, particularly those emphasizing wildlife conservation and native plant species. They recommend specific clarifications to prevent the conversion of non-cropland to cropland and suggest removing requirements to identify specific individuals in prescribed burn plans to reduce administrative burdens.

The Tennessee NRCS Forestry Sub-Committee argues that the proposed revisions to several conservation practices (315, 338, 654, 381, and 490) may create administrative burdens, increase costs for landowners, and reduce the accessibility of forestry-specific benefits. They specifically express concern that narrowing the stated purposes of these practices or changing measurement units could make it harder for forest landowners to qualify for and implement necessary conservation projects.

The Chesapeake Bay Foundation, a non-profit organization dedicated to restoring the ecological health of the Chesapeake Bay, supports the proposed revisions to the NRCS National Handbook of Conservation Practices. They provide specific recommendations to strengthen environmental protections, such as shortening storage limits for animal waste, increasing tree canopy requirements for silvopasture, and ensuring native plant preferences are maintained in trail and walkway standards.

The commenter, likely a farmer or rancher, supports keeping indirect benefits like soil erosion reduction and carbon storage in the language for Silvopasture. They argue that removing these benefits could negatively impact scoring and limit eligibility for contracts and programs.

The American Bird Conservancy (ABC) supports the proposed revisions to the National Handbook of Conservation Practices, particularly those that emphasize native plant materials, wildlife habitat benefits, and design flexibility. They provide specific technical recommendations to improve the language, clarify purposes, and ensure that the revisions do not unintentionally eliminate existing conservation uses or create unnecessary administrative burdens.

The Organic Farming Research Foundation (OFRF) supports the proposed revisions to the National Handbook of Conservation Practices but argues that the standards should be better tailored to organic producers. They recommend including specific language in each practice standard to ensure compliance with USDA National Organic Program (NOP) regulations and to provide guidance on implementing conservation practices in organic and transitioning systems.

Pasa Sustainable Agriculture, a nonprofit organization, opposes the proposed removal of water quality, erosion control, and wildlife habitat as standalone purposes of the Silvopasture (381) practice standard, arguing that scientific evidence supports these benefits. They also request that the new "decreases forest health" prohibition include a clear definition and documentation standard to ensure consistent application and clarity for producers.