Analysis—2023 RCPP Funding Announcement
The fiscal year 2023 Regional Conservation Partnership Program (RCPP) Notice of Funding Opportunity (NFO) was released by NRCS on May 19, 2023. Up to $500 million is available and the deadline for proposal submissions is August 18, 2023.
This is a milestone RCPP announcement as it contains the first $250 million tranche of Inflation Reduction Act (IRA) funding. This may also be the final NFO under the 2018 Farm Bill, depending on the timing of enactment of the next Farm Bill.
In the run-up to the release of the NFO, NRCS held listening sessions with RCPP stakeholders to get feedback and suggestions on the challenges partners have faced with the current iteration of the program. These stakeholders and especially potential applicants will be poring over the NFO to find any changes NRCS made compared to preceding years. Below is my analysis of the NFO, highlighting changes over previous funding announcements:
The award cap for this NFO is $25 million (it had been $10 million for many years). USDA’s Partnerships for Climate-smart Commodities (PCSC) initiative likely paved the way for larger project sizes in RCPP, with some PCSC awards nearing $100 million over five years.
The NFO lumps RCPP FY 23 Farm Bill and IRA funding into a single pot. Projects that address IRA priorities (i.e., greenhouse gas mitigating activities) may be funded using IRA dollars, while projects addressing other priorities may be funded using Farm Bill dollars. Unlike other NRCS Farm Bill programs like EQIP, CSP and ACEP, there is not a hard requirement that RCPP funding is awarded to GHG mitigating projects, only that the agency must give priority to such proposals.
For the first time, NRCS has issued a single NFO that includes opportunities for NRCS-led projects (RCPP Classic) and for partner-led projects (either Alternative Funding Arrangements or Grants). The NFO does not make clear whether AFAs or grant agreements will be used for partner-led projects. The distinction between AFAs and grants is important—AFAs are managed by NRCS programs staff using the RCPP Portal and are not administered under 2 CFR 200, the regulation that governs many Federal awards. Any grant agreements funded under this NFO would be managed in ezFedGrants by the FPAC Business Center’s Grants and Agreements Division using 2 CFR 200.
It is unclear from the NFO whether partners should propose whether they would like to have their project managed as an AFA or a grant. Perhaps that issue will be addressed during the forthcoming applicant webinars.
The NFO continues the de-emphasis of partner contributions that subtly began with the FY 22 RCPP Nutrient Management Grants offering. The magnitude and quality of partner contributions only count for 15 out of 100 points in the FY 23 proposal evaluation criteria (vs. 25 points last year). This is good news for partners and, following again the path blazed by PCSC, opens the door for the submission and awarding of proposals that include smaller amounts of partner contributions.
The NFO de-emphasizes the agency’s desire for projects to include innovative approaches to partnerships, targeting of producers, and conservation implementation. Innovation has been a hallmark of the program since its inception in 2014, and in FY 22 for example, it accounted for 20 out of 100 points in the proposal evaluation criteria. In FY 23, innovation has been removed entirely from the proposal evaluation criteria and the program goals.
The de-emphases of partner contributions and innovation means the proposal evaluation criteria looks like this—Impact counts for 50 points, Partner Contributions 15 points and Partnerships and Management 35 points.
For the first time under the 2018 Farm Bill, the agency has set aside up to $50M for Tribal AFA projects. If the funding is not used on Tribal AFAs, it can be folded back into the general RCPP pot.
NRCS made some substantive changes to the Financial Assistance (FA) and Technical Assistance (TA) funding that comprise RCPP projects.
It removes from proposal/project budgets the TA funding that was previously reserved by NRCS for project management—that funding is being allocated separately to NRCS States. So instead of the old 70/30 FA/TA split, that split is now 75% FA, 25% TA.
It eliminates the distinction between Enhancement TA (or TA-E, activities like producer outreach, project management, outcomes reporting) and Implementation TA (or TA-I, activities like conservation planning, practice design, and practice implementation verification). Partners may now request up to 25% of the overall funding request without the old limits of 7% for TA-E activities and 18% for TA-I activities.
The elimination of the TA-E/TA-I distinction will most benefit applicants with projects dominated by entity-held easements. There are few implementation TA activities that NRCS will reimburse for easement activities so easement partners can now request more funding for project management and producer outreach activities than they previously could (in fact, many existing entity-held easement projects made requests to shift project TA to FA since there wasn’t much use for TA funding).
In several places, the NFO includes an increased emphasis on coordination with NRCS STC and staff. Page 17, for example, includes a list of reasons applicants should coordinate with STCs and State RCPP staff in the development of proposals.
There are some tweaks to RCPP easements in the FY 23 NFO.
NRCS will pay up to 75% of the value of an entity-held easement that is both with a Historically Underserved landowner and includes a government right of enforcement. Previously, 50% had been the highest level of NRCS compensation for entity-held easements.
Awardees interested in U.S.-held easements may use easement deeds used for the Wetland Reserve Easement (WRE) or Healthy Forest Reserve Program (HFRP), with “appropriate adjustments made for RCPP funding, project purposes and land eligibility.” Similarly, awardees interested in entity-held easements may use an easement template approved under ACEP-ALE with appropriate adjustments. In these ways, RCPP easements are now effectively be “all things to all people.” Applicants interested in RCPP for the flexible land use and deed terms based on restrictiveness level can pursue those innovations, while applicants interested in more traditional NRCS easement offerings can now pursue those through RCPP.
While not in the NFO itself, the agency has made some small changes to the RCPP Portal, where applicants develop and submit proposals. Most notably, these changes streamline the process for recording partner contributions.
Finally, page 13 of the NFO includes a short but important statement—“For AFA projects, funding assistance is provided to partners in advance or on a reimbursement basis as appropriate.” Prior to FY 23, advances have not been made available to AFA awardees. This newly announced availability of advance payments can help AFA partners, particularly smaller organizations without the resources to carry out a project strictly on a reimbursable basis.
For a program like RCPP, which is governed by a fairly generically-written regulation, the annual funding announcement is an important policy document that lays out how projects funded under it will be managed in the years ahead. NRCS has made several substantive and other smaller changes to RCPP through the FY 23 NFO ahead of what it promises are even bigger changes to come as part of a program improvement effort. This internal agency effort is occurring in parallel to negotiations for the next Farm Bill. Either way, whether changes are forced by the next Farm Bill or implemented by the agency if the Farm Bill is extended for a lengthy period, the FY 24 NFO is likely to look quite different from the one released today.
