Detailed Information on the
Conservation Security Program Assessment

Measure: Tons of nitrogen reduced from agricultural operations, nationally.

Explanation:This measure reflects the agency's efforts to reduce the amount of nitrogen reaching the nation's waterways, represented as tons of potential nitrogen loadings reduced. Nutrient runoff from agricultural operations is a nonpoint source of water quality impairment in lakes, streams, and oceans. An increase in available nitrogen has the potential to cause increases in algae in marine systems that decrease the amount of dissolved oxygen needed to sustain aquatic life. This measure directly supports the NRCS Strategic Plan Goal, "Clean and Abundant Water" and USDA's Strategic Plan Goal, "Protect Watershed Health to Ensure Clean and Abundant Water."

Measure: Carbon sequestered on agricultural lands nationally, the cumulative million tons.

Explanation:This measure reflects the agency's efforts to improve soil quality on agricultural land, represented as the cumulative million tons of carbon sequestered. Soil has the ability to store carbon from the atmosphere primarily as soil organic matter. Soil organic matter plays a key role in the physical, chemical, and biological health of soils. This measure directly supports the NRCS Strategic Plan Goals, "High Quality Productive Soils" and "Clean Air." This measure also supports USDA's Strategic Objective 6.2, "Enhance Soil Quality to Maintain Productive Working Cropland."

Measure: Agricultural land with an increase in the Soil Conditioning Index, million acres.

Explanation:This measure links to the long-term soil quality performance measure of carbon sequestration on agricultural lands. The Soil Conditioning Index (SCI) is measured using RUSLE2 to predict the consequences of cropping and tillage systems on soil organic matter. This measure reflects acres on which soil condition (as measured by the SCI) has been improved since entering CSP. Measurement unit is million acres.

Measure: Cropland acres with reduced soil compaction and improved soil structure and infiltration, million of acres.

Explanation:This measure links to the long-term performance measure associated with soil quality on agricultural lands. Soil compaction is reduced by confining all heavy traffic to specific lanes through cropland fields enrolled in CSP. Controlled traffic improves soil quality by improving soil structure, increasing infiltration, and reducing erosion, runoff and sedimentation. The baseline will be established in the next signup; the measurement unit is million acres.

Measure: Cropland that uses management practices to recude nitrogen loading to surface and groundwater, in million acres.

Explanation:This measure links to the long-term water quality measure of reducing nitrogen loadings to waterways. Nitrogen application management controls the amount, source, placement, form, and timing of the application of nitrogen to maximize plant uptake and minimize nutrient losses in the field. The enhancement activities associated with this measure include: application dates of less than 30 days of planting; using controlled release nitrogen; deep profile sampling for residual nitrogen; nitrogen applied in 2 applications or more; and split application based on pre-sidedress nitrogen testing. Measurement unit is million acres.

Measure: Acres with an increase in the Soil Conditioning Index per $1 million.

Explanation:This measure reflects the agency's efforts to improve the efficiency of implementing practices that improve a participant's SCI score. The SCI is measured using RUSLE2 to predict the consequences of cropping and tillage systems on soil organic matter. The measurement unit is acres per million dollars of financial assistance.

Is the program purpose clear?

Explanation: The Conservation Security Program's (CSP) purpose is to promote the "conservation and improvement of the quality of soil, water, air, energy, plant and animal life, and any other conservation purposes, as determined by the Secretary (16 USC 3838 a-c)." The CSP regulation in 7 CFR 1469.1 (c) provides that participants receive financial and technical assistance for the conservation of soil, water, and other resources. CSP accomplishes this purpose by rewarding those farmers and ranchers who reach the pinnacle of good land stewardship on working agricultural lands, and encouraging others to do the same. As articulated in the Conservation Programs Manual, Part 518, CSP's program identifies the objectives for the CSP: enhancing soil quality, improving water quality and conservation, promoting healthy wildlife habitat, sequestering carbon, improving on-farm energy use, and generating energy alternatives.

Evidence: Title II; Subtitle A, Section 2001 of the Farm Security and Rural Investment Act of 2002, Public Law; 16 USC 3838 a-c; 7 CFR 1469; Conservation Programs Manual, Part 518

Does the program address a specific and existing problem, interest, or need?

Explanation: CSP addresses the need to conserve, maintain and improve the quality of our Nation's soil, water, air, energy, plant and animal life. It encourages conservation on privately owned lands, the largest percent of the Nation's land base, by providing payments to producers who have achieved a sustainable baseline and wish to further conservation benefits on their farm or ranch. Despite significant improvements in soil erosion control and other water quality efforts, agriculture continues to be a major contributor to non-point source pollution. Other public conservation program strategies for achieving natural resource protection on private lands are not adequate to reach the level of environmental quality that Americans want today. Regulatory approaches necessarily focus on meeting minimum standards for specific resources. Cost share programs focus on installing practices to standards and maintaining them for a specific period. The resource goals of the Nation today?? the demand for clean water, clean air, and healthy wildlife populations -can be met only if a majority of managers of private land practice a high degree of comprehensive conservation management over the long term. The CSP also creates incentives for other producers to meet those same standards of conservation performance on their operations. The CSP encourages farmers and ranchers to enhance the ongoing production of clean water, clean air, and healthy soil on their farms and ranches which are valuable commodities to all Americans.

Evidence: Land Use NRCS National Resources Inventory, 2003 Annual NRI, February 2007; NRCS Conservation Brief, Water Quality (February 2006, Number 0603); NRCS Conservation Brief, Soil Quality (February 2006, Number 06010); NRCS Strategic Plan, p. 24, Figure 1, Erosion on Cropland and CRP land, Billions of Tons Per Year, Schnepf and Cox, "Environmental Benefits of Conservation on Cropland: The Status of Our Knowledge," 2006 (http://store.swcs.org/index.cfm?fuseaction=C_Products.viewProduct&catID=574&productID=9630); The Heinz Institute, " The State of Nation's Ecosystems." 2005 Updates (http://www.heinzctr.org/ecosystems/report.html)

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: While CSP is designed to be the only Federal conservation program that recognizes and rewards farmers and ranchers for on-going conservation stewardship, the program overlaps with other farm support and conservation programs. Participants in CSP are automatically paid a per-acre stewardship payment that is based on the rental rate for their land, regardless of whether the participant performs additional conservation activities. CSP also pays a "base" enhancement payment for the enhancement activities that producers have already implemented, often through other federal conservation programs such as the Environmental Quality Incentives Program (EQIP). Payment for existing practices is required by the 2002 Farm Bill, which states that existing land management practices are eligible, ensuring overlap with other programs. Indeed, an April 2006 Government Accountability Office (GAO) report identified cases where CSP made duplicative payments for similar or the same conservation activities, such as performing crop rotations or practices that reduce soil erosion. GAO identified cases from 2004 where producers received a CSP enhancement payment and an EQIP payment for conservation actions GAO determined were the same. Importantly, GAO concluded that NRCS did not have a comprehensive process, such as an automated system, to either preclude duplicate payments or identify them after the agency has awarded a contract. The program has taken steps to ensure that the CSP is not operating redundantly. Following CSP's original PART assessment and in response to GAO's report on CSP payments, NRCS has undertaken a comprehensive process to screen CSP and other conservation databases to ensure that duplicate payments are not issued among CSP and other conservation programs. For example, conservation practices such as terraces and waterways that are required to meet conservation compliance requirements on highly erodible land are not eligible for payment. New practices that were applied with cost-share assistance through other cost-share programs may not receive CSP new practice payments. CSP participants are ineligible to receive payments for enhancement activities that are also earning financial assistance payments through other programs. This comprehensive process has included an addendum to the CSP Self-Assessment Workbook and an update to CSP's contract database.

Evidence: P.L. 107-171, Sec. 2001; Government Accountability Office - Conservation Security Program: Despite Cost Controls, Improved USDA Management Is Needed to Ensure Proper Payments and Reduce Duplications with Other Programs; GAO-06-312, April 2006. 1.3A - Natural Resources Conservation Service (NRCS) Conservation Programs Manual (CPM), Part 518.80b 1.3B - National Bulletin 300-6-14; CSP PART Milestone Report-MITS; CSP Self-Assessment Workbook's Duplicative Payments Addendum

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The CSP regulation economic analysis estimated that CSP generates negative net societal benefits because the relatively large reward payments and governmental administrative costs outweigh the environmental improvements. The benefit-cost analysis for the interim final rule stated that "due to a lack of data, no attempt was made to estimate the benefits generated by the implementation of enhancement activities. The model results therefore show a negative net benefit for ...program alternatives, because enhancement activities, which are a large portion of the contracts' cost, are assigned zero benefits." Enhancement activities make up 72% of the funds obligated to CSP contracts and are based on the concept of management intensity, meaning the practices or measures taken result in environmental benefits exceeding quality criteria, or go beyond the minimum requirements of a conservation practice standard. Even though payment for enhancement activities is based on environmental benefits, it is unclear whether these benefits are being realized. It is assumed, but never determined, that better practices yield higher benefits. Therefore, it is difficult to tell whether the payments for enhancement activities -- which are supposed to be rewarding increased environmental benefits-- are actually producing those benefits. A program design that required evidence of improved environmental outcomes as a condition of payment would yield more definite results. A February 2007 assessment conducted by the Soil and Water Conservation Society and Environmental Defense identified several design flaws and concluded that CSP "must change to realize its potential" in providing environmental benefit on the nation's working landscapes. The report states "As currently funded and implemented, CSP is largely missing that opportunity." The report further states that the program should "reward more than the status quo": "Enhancement payments, for example, could be reserved only for new effort above and beyond the benchmark (preexisting) level of effort rewarded through stewardship payments. Stewardship payments, then, would reward "good actors" for their current level of stewardship while enhancement payments would reward participants for doing more. Alternatively, contract in periods in CSP could be shortened to five years and producers be required to do more in order to renew their contracts (and receive higher payments) for another five years. Or, producers could be required to plan for and commit to new conservation practices and activities as part of their CSP contract with their CSP payment growing as those new practices and activities come on-line." Beyond providing direct environmental benefits on participants' farm operations, CSP is intended to serve as a motivational tool. The CSP is expected to help to generate environmental improvements on farms and ranches who are not yet enrolled in the program. Unfortunately, it is very difficult to estimate the indirect environmental impact that CSP is generating on these potential future participants' operations. A reliable national system for measuring these results has not been developed. However, there is some evidence that the program has motivated producers outside of the program. In 2007, the Minnesota Project studied CSP implementation in five Midwestern States. Three-fourths of the farmers interviewed stated that they incorporated new conservation practices or activities in addition to their existing conservation practices identified in their initial CSP benchmark resource assessment. The study found that farmers were motivated to add new conservation practices to ensure their acceptance into the program and to transition to higher tiers.

Evidence: 1.4A - 7 CFR Part 1469, CSP Proposed Rule, January 2, 2004; Amendment to the Interim Final Rule, Benefit Cost Assessment, March 18, 2005; The Minnesota Project, "Conservation Security Program Drives Resource Management: An Assessment of CSP Implementation in Five Midwestern States," April 2007; Conservation Security Program Assessment, Soil & Water Conservation Society and Environmental Defense, February 2007(http://www.swcs.org/documents/CSP_assessment.pdf)

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: the PART guidance requires that programs demonstrate that activities that would have occurred without the program are not subsidized (or receive only warranted levels of subsidies). With regard to this requirement, CSP has not provided evidence that all of the conservation activities that it subsidizes would not have occurred without the program. To a large extent, one of the central purposes of the program is to reimburse producers for the costs of conservation activities they have already undertaken, as well as to subsidize the long-term operations and maintenance costs of these conservation practices. In fact, part of the CSP's statutory purpose is to pay for activities which have already occurred. The 2002 Farm Bill (P.L. 107-171) specifies that existing management practices - which predate the program - are eligible for payment. Because of this, the program must receive a "NO" for this question. The PART guidance requires that programs provide evidence that they are designed to ensure that their resources are being used effectively the meet the program's purposes and that they are targeted so that resources and benefits reach the intended beneficiaries. On these points, CSP can demonstrate that it has procedures to meet these criteria, including offering the program in selected watersheds, creating enrollment categories, and establishing higher minimum requirements. CSP watersheds are selected based on a process that examines natural resources, environmental quality, and agricultural activity. By focusing on watersheds, where agriculture is a major contributor to nonpoint source pollution in waterways, NRCS hopes to reduce sediment and nutrient loadings where there is the highest percentage of target beneficiaries. CSP also created enrollment categories for farmers to achieve in order to be eligible for payment (see evidence). The enrollment categories enable NRCS to select individuals based on the resource condition and the practices in place. This process prioritizes applications to ensure that those producers with the highest conservation commitment are funded first. In addition, CSP has also raised the minimum tier standards, enabling the agency to target participants with more management intensity within each of the Tier levels. For example, NRCS' Tier II required the participant to address the nationally significant resource concerns of soil and water quality on the entire farm or ranch, and address a third resource concern applicable to their watershed. The statute requires only one resource concern be met on the entire farm or ranch.

Evidence: Farm Bill 2002, CSP Fact Sheet; Farm Bill 2002, CSP Key Points, Watershed Selection; NB300.6.44, State Watershed Selection Process for CSP; "Conservation Security Program Variable Rate Fact Sheet," January 22, 2007; the 2002 Farm bill, P.L. 107-171, section 2001.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: NRCS has established two long-term performance measures that reflect the program purpose and natural resource outcomes. These two measures reflect NRCS' ongoing efforts to improve soil quality on agricultural land, reduce the amount of nitrogen reaching the nation's surface water and groundwater, and make a positive contribution to the nation's efforts on global climate change by sequestering carbon on the agricultural landscape. The first measure, "Carbon sequestered on agricultural lands, cumulative million tons," directly supports two of NRCS' Goals, "High Quality, Productive Soils" and "Clean Air." It also supports USDA Strategic Objective 6.2, "Enhance Soil Quality to Maintain Productive Working Cropland." Soil has the ability to store carbon from the atmosphere primarily as soil organic matter; which plays a key role in the physical, chemical, and biological health of soils. This measure is viewed by NRCS as an outcome measure for soil quality and serves as a proxy for the desired outcome of reduced carbon in the atmosphere since NRCS does not measure air quality. The second measure, "Tons of potential nitrogen delivery reduced from agricultural operations," directly supports NRCS' Goal, "Clean and Abundant Water," and USDA's Strategic Objective 6.1, "Protect Watershed Health to Ensure Clean and Abundant Water." This is an output measure that serves as a proxy for CSP's authorized purpose of improving water quality. NRCS does not measure in-stream water quality, which is the desired outcome. Water quality varies continuously, based on many non-agricultural factors outside of CSP's control (such as the weather). CSP can impact water quality by reducing the level of nutrients, such as nitrogen, leaving agricultural operations and entering waterways. NRCS will use the Soil and Water Eligibility Tool (SWET) to determine program eligibility and predict environmental benefits by assessing applicants' conservation system information, benchmark condition inventory, and records. This data is collected through an applicant self-assessment process in which field verification will be expanded in the future years. Data collected through SWET will be used as inputs for the Agricultural Policy/Environmental eXtender (APEX) model to generate a water quality baseline data, as well as provide performance information for soil quality and water quality. The APEX model was developed for use in whole farm/small watershed management and has been extensively tested, endorsed and utilized by the science community beginning with the creation of its predecessor, the EPIX model in 1980. The model was constructed to evaluate various land management strategies and their impacts on sustainability, erosion, economics, water supply and quality, soil quality, plant competition, weather, and pests. The results will be verified through a random sample of 60 fields. APEX can also be used in evaluating the effects of global climate change and carbon management. Performance estimates obtained from the APEX model will include standard errors, and will be expressed as confidence intervals. Additional information to support these long-term measures is provided in the evidence document, The APEX model, and in the PART performance measures. Note: NRCS policy requires that self-assessment verification be used to authenticate any questionable information provided by participants. NRCS is conducting on-site verification of questionable information; the percentage will be reported to OMB semi-annually. NRCS reports that the 3,350 (17% of total) contracts modified to transition tiers were field verified. Self-assessment verification will be conducted on-site for 100% of approved contracts. Additionally, NRCS will conduct a 10% national random sample quality assurance review that will include field verification. Improved controls will further ensure that data used in SWET and the APEX model are as accurate and reliable as possible.

Evidence: Productive Lands Healthy Environment, NRCS Strategic Plan (2005-2010); USDA Strategic Plan FY 2005-2010; FY 2009 Explanatory Notes; PART Performance Measures Section; Texas A&M University, "The APEX Model," 2005.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: Although NRCS has established targets, the targets do not meet the criteria required in PART guidance for this question. The PART requires specific, quantified targets for measures evaluated in 2.1. The baseline and long-term targets for reduced nitrogen delivery from agricultural operations to waterways are currently under development. Therefore, the program must receive a NO for this question. Targets, baselines, and data on past performance are provided in the PART Performance Measures section.

Evidence: Productive Lands Healthy Environment, NRCS Strategic Plan (2005-2010) (see section 2.1); USDA Strategic Plan FY 2005-2010 (see section 2.1); See PART Performance Measures Section

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: PART guidance for this question has three elements: (1) the program must have a limited number of discrete, quantifiable, and annual performance measures; (2) the annual measures must measure progress towards the stated long-term goals in question 2.2; (3) annual measures must focus on outcomes, or if they are outputs the program must adequately justify why it is unable to define satisfactory outcome measures. The two annual measures that support the long-term CSP goal of improving soil quality, as measured by carbon sequestration, are: "Agricultural land with an increase in the Soil Conditioning Index , million acres," and "Cropland acres with reduced soil compaction and improved soil structure and infiltration, million acres." The annual measure that supports the long-term CSP goal of protecting and improving water quality, as measured by tons of potential nitrogen delivery reductions to surface water and groundwater is: "Cropland with a reduction in nitrogen loading to surface and groundwater, million acres". Though the agreed upon measures are all outputs, they act as pseudo measures to capture the environmental benefits taking place on the field. There is no measure that can easily capture improved environmental outcomes, making it necessary to create output performance measures that focus on key components that lead to improving environmental quality. The annual performance measures were developed using a logic model process that translates the CSP program objectives identified in authorizing legislation to the annual performance measures, outputs, and activities needed to achieve the desired long-term outcomes. Note: NRCS policy requires that self-assessment verification be used to authenticate any questionable information provided by participants. NRCS is conducting on-site verification of questionable information but has no database to document the extent. NRCS can report that the 3,350 (17% of total) contracts modified to transition tiers were field verified. Self-assessment verification will be conducted on-site for 100% of approved contracts. Additionally, NRCS will conduct a 10% random sample (selected by national headquarters) quality assurance review that will include field verification. Improved controls will further ensure that data used in SWET and the APEX model are as accurate and reliable as possible.

Evidence: Productive Lands Healthy Environment, NRCS Strategic Plan (2005-2010) (see section 2.1); USDA Strategic Plan FY 2005-2010 (see section 2.1); FY 2009 Explanatory Notes (see section 2.1); NRCS General Manual 340, Part 400 Strategic Planning and Accountability; CSP Logic Model.

Does the program have baselines and ambitious targets for its annual measures?

Explanation: While NRCS has established baselines and annual targets for three of the four annual performance measures, they are not ambitious in accordance with PART guidance. For example, goals for the performance measure "Cropland acres with reduced soil compaction and improved soil structure and infiltration, million of acres" are still "to be determined." Through streamlined program delivery and use of improved technologies and budget and performance integration tools, CSP has achieved efficiency gains as detailed in question 4.3 response, even though CSP has not met its target each year for the annual efficiency measure. All measures and targets are based on the NRCS strategic plan, and are reflected in the Agency business plan and employee performance plans.

Evidence: Productive Lands Healthy Environment, NRCS Strategic Plan (2005-2010)(see section 2.1); USDA Strategic Plan FY 2005-2010 (see section 2.1); FY 2009 Explanatory Notes (see section 2.1)

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: PART guidance for this question requires that all partners - in this case producers with land enrolled in CSP - measure and report on their performance as it relates to accomplishing the program's goals. Indeed, PART guidance states "if a program does not link partners' activities to the program's goals through a performance requirement or some other means, then a "no" would be appropriate." As cited in question 1.1, the program's goals include conservation and improvement of the quality of soil, water, air, energy, plant and animal life, and any other conservation purposes, as determined by the Secretary (16 USC 3838 a-c)." Producers are not required to report, or even to monitor, whether the quality of the soil, water, air, energy, plant or animal life has improved as a result of the practices installed. Therefore, the program must receive a NO for this question. For CSP, contract participants are the principal partners that achieve CSP long-term goals. Contracts are geared towards enforcing activities (the conservation practices, which are outputs rather than outcomes) agreed upon in the conservation stewardship plan. Participants must agree to "establish conservation practices and activities specified in this conservation stewardship plan ..as scheduled and to operate and maintain new or existing practices specified in the conservation stewardship plan for the lifespan identified in this contract." However, establishing conservation practices is not the desired outcome of CSP. CSP's desired outcomes, as specified above, relate to environmental benefits. Contracts do enforce the agreed-upon practices. Each contract articulates the relevant CSP goals and outlines the participants' responsibilities to achieve those goals in the contract appendix. NRCS State Conservationists ensure that contract participants meet established objectives. Penalties, including contract termination and recovery of costs, may be assessed for failure to comply with contract terms and conditions. CSP participant compliance is monitored by annual contract reviews and State quality assurance efforts. CSP participants' accomplishments are monitored using management reports generated from ProTracts implementation data. NRCS also works with State Technical Committees, Federal, Tribal, State and local agencies, and other interests with conservation expertise, who provide advice on CSP implementation, such as, establishing land rental rates, recommending eligible enhancement activities, and setting payment rates. This collaborative process helps ensure that partners are committed to achieving CSP goals and that program delivery does not duplicate partner efforts. To ensure accountability of its partners, NRCS hosted a nationwide grants and agreements training for NRCS employees and partners in FY 2004, and released grants and agreements policy guidance following the training (see evidence).

Evidence: CSP Contract Appendix; Conservation Programs Manual 440, Part 501, Subpart B, State Technical Committees; State Technical Committee; Minutes;http://directives.sc.egov.usda.gov/index.aspx?l=3 (GM 120 Part 600, Federal Grants and Cooperative Agreements; GM 120 Part 610, Contribution Agreements)

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Though CSP has had multiple external evaluations and NRCS has an internal process in place to evaluate the program's effectiveness and identify areas for program improvement, the evaluation of CSP's effectiveness in meeting PART guidance requirements for scope and quality have not been met. The evaluations that have taken place have served to improve internal controls and create a more efficient program delivery process, but have not assessed whether the program has met its goals of improving the environment. Several entities also have conducted independent evaluations on CSP since CSP underwent its initial PART assessment in FY 2005. In April 2006, the General Accounting Office (GAO) completed a review in which the primary concerns were related to instances where CSP made duplicative payments for similar or the same conservation activities in other programs. In response to GAO's findings, NRCS developed a comprehensive process to prevent approval of an application where a conservation practice is already scheduled for payment in another contract. This comprehensive process included: revised program policy; an addendum to the CSP Self-Assessment Workbook, whereby the applicant identifies conservation activities on their land that are being applied through other conservation programs; and an internal control within the ProTracts contracting software that conducts a comparison between CSP applications and existing contracts (WHIP, AMA, EQIP) to reveal potential areas of overlapping practices. GAO's other concern was related to the lack of consistency among states' wildlife criteria. In response to this concern, NRCS: requested that states submit their wildlife habitat criteria for all CSP watersheds to a National Biology Team, who reviewed for consistency, amended the national guidance on wildlife habitat assessment criteria, and pilot-tested several IT improvements to further quality assurance and consistency among states, including the wildlife habitat tool which enables NRCS staff consistently evaluate environmental benefits derived from CSP enhancement activities on cropland, grazing lands, and other land suited to wildlife. In September 2007, GAO issued a follow-up report to the April 2006 report. The 2007 report determined that NRCS had made payments on CSP contracts in excess of annual payment limits as required by statute (16 USC 3838c). NRCS was not authorized to make such payments, and GAO determined these constituted improper payments. GAO concluded the improper Tier I payments were resolved, but that the Tier II and Tier III contract improper payments were still to be rectified. It is unclear whether NRCS has followed this recommendation. Aside from a review by the General Accounting Office, CSP also underwent several external reviews by nongovernmental organizations, such as the Center for Rural Affairs, Soil and Water Conservation Society and Environmental Defense, and The Minnesota Project. However, many of these reports focused on whether producers were satisfied with the program, and how program delivery could be improved for producers rather than on whether desired environmental outcomes were being achieved. In response to these reports, NRCS has streamlined and improved program implementation in the field. Examples of streamlining improvements include: developing the Soil and Water Eligibility Tool, the Grazing Lands Eligibility Tool, and the Wildlife Habitat Eligibility Tool; enhancing selection criteria to identify applications with the highest levels of stewardship, and reducing the number of enhancements to simplify program implementation. Internally, in February 2006, NRCS' Operations Management and Oversight Division conducted a review on CSP entitled, "Review of Internal Controls and Application Processes for CSP." Following this review, NRCS developed a Management Action Plan. All action items outlined in the MAP, have been completed.

Evidence: US General Accounting Office, "Conservation Security Program: Despite Cost Controls, Improved USDA Management Is Needed to Ensure Proper Payments and Reduce Duplication with Other Programs," May 30, 2006; The Minnesota Project, "Conservation Security Program Drives Resource Management: An Assessment of CSP Implementation in Five Midwestern States," April 2007; Center for Rural Affairs, "The Conservation Security Program: An Assessment of Farmers' Experience with Program Implementation," September 2006; NRCS Oversight and Evaluation, "Review of Internal Controls and Application Processes for the Conservation Security Program American Customer Satisfaction Survey, NRCS CSP Participants Customer Satisfaction Study, Final Report, October 2005; NRCS' Operations Management and Oversight Division conducted a review on CSP entitled, "Review of Internal Controls and Application Processes for CSP;" NRCS's Response to OIG Audit 10501-05-FM, "NRCS Application Controls-Program Contracts System (ProTracts)," February 2008; Government Accountability Office, Letter to the Honorable Robert F. Bennett, September 27, 2007.

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Budget requests for CSP are tied to annual and long-term goals and accomplishments. Furthermore, the annual budget submission to Congress includes annual performance measures and targets to indicate the estimated level of performance at the requested budget level. The estimates of resources needed for key activities are based on the agency's Cost of Programs model. Resource needs and agency accomplishments are clearly articulated in the budget in the Summary of Budget and Performance section. The annual budget submission includes annual performance measures and targets to indicate the number of acres CSP is estimated to enroll at the requested budget authority level. The request includes a table with the full cost of programs by the USDA Strategic Objectives that CSP contributes toward. Since FY 2005, NRCS has instituted a number of measures to strengthen budget and performance integration, including: linking CSP's performance measures and targets directly to NRCS's Strategic Plan; increasing the transparency of CSP's allocation process by establishing CSP priorities and publishing its program priorities and selected watersheds on NRCS's website; and conducting an Activity Based Costing effort to better identify efficiencies across states, enabling the agency to make allocation adjustments and streamline program implementation, where needed.

Evidence: Fiscal Year 2009 Explanatory Notes (see section 2.1), Activity Based Costing fact sheet

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: NRCS has revised its strategic plan in FY 2005 and strengthened the connection between program performance and agency long term and annual goals. All CSP activities, performance measures, and targets link directly to goals and objectives outlined in NRCS's Strategic Plan (2005-2010) and to Goal 6 in USDA's Strategic Plan (2005-2010). The CSP logic model shows the association between the USDA and NRCS long-term goals and CSP's long-term, annual, and efficiency measures. These long-term measures and their associated annual performance measures have been instrumental in aligning CSP with NRCS's Strategic Plan. The response to question 2.6 identifies a number of improvements incorporated in the CSP delivery process. These improvements better enable the agency to meet its strategic goals.

Evidence: MITS Performance Measures; Productive Lands, Healthy Environment, NRCS Strategic Plan 2005-2010 (see Section 2.1);CSP Logic Model

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The PART sets a clear standard for a "Yes" answer to this question. PART guidance requires that the agency regularly collect high quality performance data related to program goals, and use that information to adjust program priorities, allocate resources, or take other appropriate management actions. As described in question 2.5, producers are not required to report, or even to monitor, whether the quality of the soil, water, air, energy, plant or animal life has improved as a result of the practices installed. Therefore, the program must receive a NO for this question. However, NRCS regularly collects and analyzes data on outputs, such as the types of practices installed and the number of acres where these practices are located, including data from partners, from ProTracts and program eligibility tools to improve program performance. NRCS mines information on enhancement activity extents from ProTracts. Tons of carbon sequestered is calculated using a formula based on ProTracts data on soil conditioning indices levels and their extents - but this formula is not verified by any actual field measurements or samples from producers. Performance output information measured in acres is queried directly from ProTracts data. For the water quality measure, NRCS uses the output data from the Water Quality Eligibility Tool as inputs for the Agricultural Policy/Environmental eXtender (APEX) model to generate water quality performance information. NRCS also uses ProTracts management reports to monitor participants' contract activities and improve participants' implementation rates. In addition to ProTracts, NRCS uses the Accountability Information Management System (AIMS) to track and evaluate field office, state office, and partner progress; track financial obligations and outlays; adjust program priorities; and allocate and reallocate program resources. For CSP, AIMS components include: Foundation Financial Information System (FFIS); Total Cost Accounting System (TCAS) that stores employees' time and attendance; and the activity based cost (ABC) system that tracks technical assistance expended by program task. Each system has business rules, definitions, and internal controls that enforce CSP policies or business requirements and diagnose potential entry errors ?? allowing managers at appropriate levels to evaluate and monitor program performance. Reports on time, outlays, obligations, and performance are provided to employees and managers on the agency intranet via Conservation Information System (CIS) and Business Intelligence Dashboard reports. These reports, coupled with ProTracts reports, are periodically provided to agency leadership to facilitate allocation, performance, and staff adjustments. State Conservationists are required to attest to the quality of NRCS and partnership performance information.

Evidence: Conservation Information Systems (CIS) report sample, ProTracts Report sample, Activity Based Costing Fact Sheet, (see Section 2); FFIS sample report

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: NRCS's policy manual (in Conservation Programs Manual Part 518.10) identifies the NRCS line officers responsible for achieving key program results. Performance standards for managers define quantifiable performance standards related to CSP activity. Some program partners have contributed to the achievement of program goals for activities related to education, information, and outreach. In those instances the terms of those agreements have defined performance standards and expected outcomes that contribute to the achievement of CSP performance and efficiency measures.

Evidence: CPM Part 518 3.2A - NRCS Manager Performance Standards 2.5C - Kansas Agreement Plan of Work 2.5D - Iowa Agreement Supplemental Information 2.5E - Ohio Agreement Plan of Work

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: GAO found in September 2007 that NRCS made payments pursuant to CSP contracts that exceeded annual payment limits imposed by statute. This finding indicates the program does not have adequate procedures for reporting actual expenditures and comparing them against the intended use, as required by guidance. In terms of obligating funds, CSP program funds are obligated consistently with the overall program plan. In the year of contract development, funds have been obligated as expeditiously as possible. In subsequent years, obligations are completed/payments are made as soon as practicable after October 1. A limited amount of unobligated funds, less than 1 percent, remained at the end of the fiscal year 2004 - 2007. NRCS uses ProTracts, a web-based software program, to manage CSP applications and contracts. ProTracts offers procedures for reporting actual expenditures, and provides functions for: managing program allocations to counties, areas, and States; scheduling contract obligations though the term of a contract; certifying completed conservation practices and activities and approving them for payment; and preventing over-obligation of funds. NRCS has internal controls in place to assure funds are spent on the intended purpose. Among those controls are: rigorous applicant, land, and conservation standards eligibility criteria; applicant interviews to evaluate and verify the information accuracy provided by the applicant; enrollment categories to determine which contracts will be funded, (enrollment categories are defined by criteria related to resource concerns, levels of historic conservation treatment, and producer willingness to achieve additional environmental performance); contract compliance monitored by self-assessment verifications and annual contract reviews; and - practice and activity certification and payment approval where a conservationist certifies practice/activity units performed and a second-level reviewing official authorizes payment. Improper Payment Information Act reviews verify that NRCS is making a limited number of erroneous payments. In 2006, IPIA testing found no improper CSP payments. The 2007 IPIA found an improper payment rate of .47. To ensure funds spent for their intended purpose and obligated in a timely manner are accurately reported, NRCS has linked ProTracts with the Foundation Financial System (FFIS). These two real-time databases enable NRCS to provide detailed reports on payment scheduling to track the status of obligations. The combination of FFIS, ProTracts, and CIS also enable the Agency to flag anomalies, giving NRCS the ability to easily correct data errors and improve program implementation. As the year progresses, funds may be re-distributed to achieve CSP performance objectives.

Evidence: Unobligated Balance Table, 2007 IPIA Corrective Action Plan, Sample ProTracts Report; Government Accountability Office, Letter to the Honorable Robert F. Bennett, B-307720, Department of Agriculture--Conservation Security Program, September 27, 2007.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: NRCS has one annual efficiency measure related to program outcomes, "Increase in Soil Conditioning Index per $1 million." NRCS has a variety of procedures and systems to achieve efficiencies and cost-effectiveness improvements in program execution. NRCS has adopted one efficiency measure to monitor CSP efficiencies and cost effectiveness in program outcomes. ProTracts eliminated several paperwork steps and streamlined the program contracting processes, ranging from managing application and approving contracts, to certifying conservation activities for payment. A primary objective for CSP implementation has been to develop procedures that allow States to conduct the signup within available technical assistance. In preparing for FY 2006, NRCS set a goal for state and field offices to complete 90% of the CSP applicant interviews in less than 2 hours while also accomplishing the following outcomes: - Applicant, land, and conservation standards eligibility determined, - Tier placement completed, - Enrollment category placement completed, - Benchmark enhancements identified, and - Payment level estimated. NRCS also implemented Producer Self-Assessment as a part of CSP to reduce the amount of time field staff spend determining applicant eligibility. With producer self-assessment, CSP applicants go through much of the application analysis themselves and arrive at preliminary eligibility conclusions independent of NRCS. The producer self-assessment process allows NRCS conservationists to focus their energy on other meaningful conservation activities. NRCS conducted interviews with over 29,600 potential applicants who completed self-assessment workbooks during the 2004 - 2006 sign-ups. Using Activity Based Cost analysis information on the time required for NRCS to complete the resource inventory collection and analysis task of conservation planning, which the applicant accomplishes for themselves by completing the workbook, NRCS estimated that the self-assessment workbook process saved 77 staff years. NRCS also developed the Customer Service Toolkit that reduced planning time by 30 percent.

Evidence: Amendment to the Interim Final Rule, 7 CFR Part 1469, March 25, 2005 2.1A - MITS Performance Measures 3.4B - National Bulletin 300-6-10; Report 1.5, "National Summary by Program, Product, and Task," ABC.

Does the program collaborate and coordinate effectively with related programs?

Explanation: NRCS implemented CSP in a way that allows it to work with and complement other conservation programs. Cost-share programs such as the EQIP and WHIP are intended to help compensate producers for implementing conservation practices to achieve sustainable levels. As such, a producer can use the cost-share programs to elevate their conservation treatment level to become eligible for CSP. The CSP is available to reward producers for the highest levels of environmental stewardship and the outputs of conservation systems that exceed sustainable levels; cleaner water, enhanced soil quality, higher levels of stored soil carbon. The CSP also offers an enhancement component intended to increase conservation performance above minimum requirements as a result of additional effort by the participant. Enhancement payments are available to a participant for activities that improve the comprehensiveness and intensity with which participants treat natural resources. As a result of earlier audits and in response to the GAO audit on CSP payments, NRCS created an internal control within ProTracts that conducts a comparison between CSP applications and existing contracts (WHIP, AMA, EQIP) to reveal potential areas of overlapping practices. This improvement, coupled with the CSP Self-Assessment Workbook's Duplicative Payments Addendum, eliminate the chance for duplicative payments among CSP and other conservation programs. NRCS also uses the CSP Self-Assessment Workbook to better coordinate CSP delivery with other cost-share programs. The workbook provides advice to producers who are ineligible for CSP on how to achieve their conservation goals by using other federal programs, such as EQIP. The CSP also collaborates with technical assistance programs. For example, NRCS used its Conservation Operations technical assistance funding account to support planning activities in watersheds. These watershed assessments then provided initial estimates of where CSP investments would best address the concerns of landowners and stakeholders.

Evidence: CSP Self-Assessment Workbook 3.5B - NRCS Rapid Watershed Assessment Guidance 3.5C - Federal Register Notice, May 4, 2004 3.5D - CPM Part 512 3.5E - NRCS Program Contract Appendixes 3.5F -Conservation Programs Manual 440, Part 501, Subpart B, State Technical Committees; State Technical Committee Minutes;518 3.5G, National Bulletin 300-5-10; CSP Self Assessment Workbook's Duplicative Payments Addendum (see 1.3)

Does the program use strong financial management practices?

Explanation: PART guidance requires evidence for several aspects of strong financial management, including that the program is free from material internal control weaknesses as reported by auditors; the program's financial management system meets statutory requirements; the financial information is accurate and timely; financial statements receive a clean audit opinion and no material internal control weaknesses; and the program has no other non-compliances with laws and regulations related to financial management. NRCS as an agency has never been audited separately from the USDA. NRCS is undergoing its first stand-alone audit this year. That audit is not yet complete, so there is a significant lack of evidence with regard to this question. However, GAO found in September 2007 that NRCS made payments pursuant to CSP contracts that exceeded annual payment limits imposed by statute (16 USC 3838c). GAO concluded the department was not authorized to make payments that exceeded the statutory payment limit, and that these were improper payments. This is a clear non-compliance with a statutory limitation, and indicates significant weaknesses in the program's financial management control system. Due to the lack of a completed agency-specific audit and GAO's findings on improper payments, the program must receive a NO for this question. NRCS does have internal controls in place, though they did not prevent the payments detailed in the GAO letter. NRCS has been required for over 20 years to establish and assess internal controls in their programs and financial management activities pursuant to the Federal Manager's Financial Integrity Act of 1982. The Improper Payments Information Act (IPIA) of 2002 requires the Agency to annually review all programs and activities the Agency administers to identify those that may be susceptible to significant improper payments. To comply with these requirements, USDA issued a departmental regulation, Management Accountability and Control, and a related departmental manual, USDA Management Control Manual. Controls discussed in the manual include separation of duties, reconciliation of records from two sources, reconciliation of records and physical inventories, limiting access, providing supervision, documentation of process and procedures, written delegations of authority, analyzing and reporting on risk, and periodic reviews of performance. NRCS has followed the internal control guidance in this regulation and manual. The Agency has established agency-specific guidance on internal controls, found principally in its General Manual (GM) and Conservation Programs Manual (CPM). The GM outlines the process through which the Agency complies with government-wide requirements for internal management control. The CPM provides specific policy, guidance, and operating procedures for implementing CSP. The manual sets procedures for key program controls such as the documentation required from an applicant to process a payment application. To ensure obligated funds are disbursed in a timely manner, policy requires NRCS to complete annual contract reviews. The manual also discusses specific responsibilities for program implementation as it relates to internal controls. For example, within each state, the State Conservationist is responsible for ensuring compliance with internal controls, including separation of duties related to contract approval and payment certification. CSP uses ProTracts to manage funds. ProTracts contains extensive fund management controls. In 2005, the Office of the Inspector General (OIG) conducted an audit on the ProTracts system (10501-05-FM). The audit produced eight findings and thirteen recommendations. NRCS has implemented all of OIG's recommendations (see 2.6 evidence).

Evidence: Government Accountability Office, Letter to the Honorable Robert F. Bennett, September 27, 2007; NRCS FFIS Manual, National Finance Center procedures, Title IX, Chapter 6 (http://cod.nfc.usda.gov/publications/CodSystem/ffisnrcs.pdf); 2007 IPIA Corrective Action Plan (see 3.3); NRCS's Response to OIG Audit 10501-05-FM, "NRCS Application Controls-Program Contracts System (ProTracts)," February 2008 (see 2.6)

Has the program taken meaningful steps to address its management deficiencies?

Explanation: For this question, PART guidance requires that the program has a system for identifying and correcting program management deficiencies and uses the system to make necessary changes within agreed upon timeframes. NRCS does have these systems in place as described below and has used them to refine policies. In addition, NRCS has taken steps to improve its financial management issues, including conducting reviews of undelivered orders, reviewing obligations, and working closely with auditors to complete the 2008 audit. NRCS has implemented a system of continuous feedback to correct program management deficiencies, which included: - Annual post sign-up interagency debriefings, and - Weekly internet conferences with state program leaders and field conservationists. These efforts have resulted in the identification of program management deficiencies. In response to those deficiencies, program directives were issued to clarify or improve policy. In FY 2006, a complete revision of CPM Part 518, was released. NRCS created internal controls and improved management applications in ProTracts to address management deficiencies. For example, to prevent duplicate payments between CSP and other programs, an internal control within ProTracts conducts a comparison between CSP applications and existing contracts (WHIP, AMA, EQIP) to reveal potential areas of overlapping practices. A ProTracts contract management module was released in April 2007. That module updated contract management functions to provide improved reports and data summaries for contract implementation and obligation management. CSP technical tools have been developed and refined to address program needs. The Soil and Water Eligibility Tool, the Grazing Lands Eligibility Tool, and the Wildlife Habitat Eligibility Tool will provide a consistent method for determining program eligibility nationwide. The tools move NRCS abilities closer using resource-specific indices to measure expected levels of environmental outcomes and make payments for conservation systems. NRCS also took action to address deficiencies identified in audits and reviews as described in question 2.6.

Evidence: 2005 Debriefing Comments 3.1E - National Bulletins 300-6-10 through 300-6-20 3.7A - Water Quality Tool 3.7B - Notice of Proposed Rulemaking, 7 CFR Part 1469, February 18, 2003 1.4A - CSP Proposed Rule, 7 CFR Part 1469, January 2, 2004 3.7C - CSP Interim Final Rule, 7 CFR Part 1469, June 21, 2004 3.4A - Amendment to the CSP Interim Final Rule, 7 CFR Part 1469, March 25, 2005 3.7D - NRCS General Manual 340 1.3A - CPM Part 518 3.7E - Wisconsin State Quality Assurance Plan ; see 2.6; US General Accounting Office, "Conservation Security Program: Despite Cost Controls, Improved USDA Management Is Needed to Ensure Proper Payments and Reduce Duplication with Other Programs," NRCS Oversight and Evaluation, "Review of Internal Controls and Application Processes for the Conservation Security Program"- NRCS's Response to OIG Audit 10501-05-FM, "NRCS Application Controls-Program Contracts System (ProTracts), February 2008 (see.2.6)

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: For this question, PART guidance states, "The program must be on track to meet all the long-term performance goals - including ambitious targets and timeframes - evaluated in questions 2.1 and 2.2. A program would not receive a "Yes" answer by simply meeting any one of its long-term targets, or by having performance measures but no ambitious targets and timeframes." CSP does have performance targets, but one of the targets has no ambitious targets or timeframes, as discussed in section 2.2. More importantly, the model on which CSP results are based has not been verified by actual data on CSP lands. However, NRCS is planning to verify this model using actual data from CSP lands. This evaluation should be completed in time for the first performance evaluation of the new Conservation Stewardship Program (the successor to the Conservation Security Program, passed in the 2008 Farm Bill). NRCS plans to use CEAP data to perform the evaluation for all locations with varying topography and soils. Based on discussions with NRCS, at least seven of the current CSP watersheds overlap with the CEAP (Conservation Effects Assessment Project), so NRCS should be able to use data associated with CEAP as a starting point for evaluations of the Conservation Security Program and its successor, the Conservation Stewardship Program. CEAP focuses on developing approaches, methodologies, and databases to produce scientifically credible estimates of environmental benefits of conservation. NRCS plans to use data collected by CEAP in the seven CSP watersheds (including Upper Washita Watershed, OK; Grant-Little Maquoketa Watershed, WI and IA; St. Joseph River Watershed, MI, IN, & OH; Upper Auglaize River Watershed, OH & IN; Choptank River Watershed, MD & DE; South Skunk Watershed, IA; and Little River Watershed, GA) to verify the environmental benefits provided by CSP. These evaluations will be done in a manner that is as statistically representative of the program as possible, and will form the basis for more wide-ranging evaluations including various types of soils and topography covered by CSP contracts.

Evidence: See Performance Measures of this database; "Conservation Security Program Scope, 2004 - 2008," NRCS, Resources Inventory and Assessment Division, September 2006; and Conservation Effects Assessment Project, http://www.nrcs.usda.gov/TECHNICAL/NRI/ceap/, updated April 2008.

Does the program (including program partners) achieve its annual performance goals?

Explanation: CSP does have annual performance goals and data, but one of the targets has no ambitious targets or timeframes, as discussed in section 2.2. More importantly, the model on which CSP results are based has not been verified by actual data on CSP lands. However, NRCS is planning to verify this model using actual data from CSP lands. This evaluation should be completed in time for the first performance evaluation of the new Conservation Stewardship Program (the successor to the Conservation Security Program, passed in the 2008 Farm Bill). NRCS plans to use CEAP data to perform the evaluation for all locations with varying topography and soils. Based on discussions with NRCS, at least seven of the current CSP watersheds overlap with the CEAP (Conservation Effects Assessment Project), so NRCS should be able to use data associated with CEAP as a starting point for evaluations of the Conservation Security Program and its successor, the Conservation Stewardship Program. CEAP focuses on developing approaches, methodologies, and databases to produce scientifically credible estimates of environmental benefits of conservation. NRCS plans to use data collected by CEAP in the seven CSP watersheds (including Upper Washita Watershed, OK; Grant-Little Maquoketa Watershed, WI and IA; St. Joseph River Watershed, MI, IN, & OH; Upper Auglaize River Watershed, OH & IN; Choptank River Watershed, MD & DE; South Skunk Watershed, IA; and Little River Watershed, GA) to verify the environmental benefits provided by CSP. These evaluations will be done in a manner that is as statistically representative of the program as possible, and will form the basis for more wide-ranging evaluations including various types of soils and topography covered by CSP contracts.

Evidence: See Performance Measures of this database; "Conservation Security Program Scope, 2004 - 2008," NRCS, Resources Inventory and Assessment Division, September 2006; and Conservation Effects Assessment Project, http://www.nrcs.usda.gov/TECHNICAL/NRI/ceap/, updated April 2008.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: PART guidance requires that the program must demonstrate improved efficiency or cost effectiveness over the prior year, including meeting its efficiency target in question 3.4. NRCS has one efficiency measure,"Acres with an increase in the Soil Conditioning Index per $1 million." Although for two of the past three years, NRCS has not met its target for this goal, NRCS did meet its target for 2007 and showed increased efficiency over past years by creating more acres with an increase in the soil index per $1 million. However, these are model results only which have not been verified by field tests.

Evidence: See Performance Measures.

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: PART guidelines for this question require that "the user should consider relevant evaluations and/or data that are collected in a systematic fashion that allow comparison of programs with similar purposes and goals." The program has submitted neither relevant evaluations nor systematically collected data regarding whether CSP compares favorably to other programs with similar purposes and goals (such as other NRCS conservation programs). Although the program has submitted evidence that CSP treats acres at an average cost of $18 per acre, versus EQIP that has an average cost per acre of $45 (three year average) (see evidence), there is no connection between this calculation and the extent of the environmental outcomes resulting from each of these programs. Moreover, there does not appear to be any systematic collection or evaluation of how well CSP improves environmental outcomes as opposed to other conservation programs (like EQIP). PART guidance also requires that "comparisons must include an assessment of the most significant aspects of the program's performance." The most significant aspects of CSP must include its purposes as detailed in question 1.1: promoting the "conservation and improvement of the quality of soil, water, air, energy, plant and animal life, and any other conservation purposes, as determined by the Secretary (16 USC 3838 a-c)." No evidence has been submitted regarding how CSP compares to other conservation programs in accomplishing these goals. Accordingly, the program must receive a "No" for this question.

Evidence: CSP/CRP Carbon Sequestration Comparison; CRP enrollment statistics: http://www.fsa.usda.gov/Internet/FSA_File/06rpt.pdf; EQIP/CSP Cost Comparison (see 1.4);

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: As stated in the answer to 2.6, CSP has been the subject of external reviews by nongovernmental organizations such as the Center for Rural Affairs, Soil and Water Conservation Society (SWCS) and Environmental Defense (ED), and The Minnesota Project. However, many of these reports focused on whether producers were satisfied with the program and how program delivery could be improved for producers, rather than on whether desired environmental outcomes were being achieved. To the extent that environmental outcomes were discussed, the CSP program assessment by SWCS and ED concluded, "CSP was designed to ...improve environmental qualityand natural resource condition in agricultural landscapes. Our assessment suggests that CSP is falling short of realizing [this]." See Conservation Security Program Assessment, at 1. However, another purpose of CSP is to reward those farmers and ranchers who demonstrate good land stewardship on working agricultural lands, and encourage other producers to do the same. There is evidence in a limited number of states (5) to support that CSP is accomplishing this goal. A 2007 Minnesota Project report studying CSP implementation in five Midwestern States found that farmers were motivated to add new conservation practices to ensure their acceptance into the program and to transition to higher tiers. To validate the effects that CSP and other programs have on the landscape, NRCS has also initiated the Conservation Effects Assessment Project (CEAP) to provide credible estimates of environmental benefits from conservation practices and management activities. Unfortunately, there are no final results available yet from this project.

Evidence: Soil and Water Conservation Society and Environmental Defense, "Conservation Security Program Assessment," February 2007. The Minnesota Project, "Conservation Security Program Drives Resource Management: An Assessment of CSP Implementation in Five Midwestern States," April 2007; Center for Rural Affairs, "The Conservation Security Program: An Assessment of Farmers' Experience with Program Implementation," September 2006; NRCS Oversight and Evaluation, "Review of Internal Controls and Application Processes for the Conservation Security Program ; American Customer Satisfaction Survey, NRCS CSP (see 2.6)