FY 2024 RCPP Renewals Opportunity
The 2018 Farm Bill authorized USDA, for the first time, to noncompetitively renew existing Regional Conservation Partnership Program (RCPP) projects. NRCS has publicly stated that Renewals are intended to reward the most successful RCPP projects with additional funding.
On July 19, 2023, NRCS announced the availability of FY 2024 RCPP Renewals. Because Renewals is not available to partners other than a subset of existing RCPP awardees, Renewals opportunities are not publicly announced through a NRCS news release, for example. Rather, they are announced internally through NRCS’s eDirectives system using a national bulletin directed to NRCS State offices, which in turn are directed to notify eligible awardees of the Renewals opportunity.
RCPP stakeholders, however, may find the FY 2024 Renewals opportunity to be of great interest. The national bulletin announcing FY 24 Renewals to NRCS State offices includes policy and guidance that hints at future RCPP program approaches and timing beyond Renewals. The analysis below unpacks the FY 24 Renewals opportunity, putting it in the context of prior Renewals offerings and exploring what it means for future RCPP funding announcements.
Renewals History and Challenges
NRCS made available up to $50 million for RCPP Renewals in fiscal years 2020, 2021, 2022, and 2023. This amount provided a substantive amount for partners seeking renewals while retaining a large majority of each year’s $300 million RCPP authorization (in reality, $250-260 million once sequestration and above-state charges such as IT development were taken off the top) for competitive funding announcements.
In 2020, the first year the agency offered Renewals, NRCS allowed any partner with a project expiring in fiscal year 2021 OR with a project that had effectively expended all its financial assistance funding to request a renewal. Over 90 partners submitted a renewal request but with funding limited to $50 million, only 18 were approved. Subsequently, in fiscal years 2021, 2022 and 2023, NRCS limited renewal requests to partners with projects that were scheduled to expire in the succeeding fiscal year.
The Farm Bill making Renewals noncompetitive introduced an immediate challenge for the agency. Limiting funding for Renewals meant that not every awardee seeking additional funding would get it, but the agency somehow needed to make what seemed like a competitive situation noncompetitive. It did so by introducing Renewals evaluation criteria, scoring Renewals proposals against that criteria, setting a threshold above which proposals would be funded, and then moving down the list from the top-ranked proposal on down until the available funding ran out. Some of you who remember the old Conservation Security Program may read this and experience a shudder of remembrance.
Another challenge of Renewals for the agency and awardees alike is that partners with projects governed by 2014 Farm Bill rules and policies are applying for renewals that are governed by 2018 Farm Bill rules and policies. The 2018 Farm Bill made RCPP a standalone program with unique land management contracts and easements. To ensure that partners think through how to adapt 2014 projects for the 2018 program, awardees interested in Renewals must submit a proposal in the NRCS Programs Portal. This proposal is only slightly streamlined from the competitive announcement proposal.
Fiscal year 2024 Renewal Opportunity
RCPP’s Inflation Reduction Act (IRA) windfall appears to have impacted the FY 2024 Renewals opportunity in several ways:
NRCS once again has offered renewals to projects scheduled to expire in FY 2024 (largely FY 2018 projects awarded under the 2014 Farm Bill) AND any 2018 Farm Bill projects that have effectively expended all their financial assistance funding. This makes the 2024 Renewals opportunity the first time that 2018 Farm Bill projects are eligible for renewal. The list of eligible 2018 Farm Bill projects attached to the national bulletin (based on NRCS analysis of project fund accounts) includes both Classic and AFA projects.
The Renewals opportunity makes up to $100 million available, double what previous opportunities have offered. The funding is split--$50 million in Farm Bill funding and $50 million in IRA funding. This is FY 2024 funding that the agency can at this point be comfortable will become available October 1, 2023. It is increasingly unlikely that a new Farm Bill will pass before then—a new Farm Bill could alter the schedule of IRA funding or even eliminate the Renewals component of RCPP.
The Renewals guidance states that the $50 million in available IRA funding is available to proposals that score at least a B on the included “Addresses Climate Priorities Index.”
A—Goals, objectives, and outcomes (including social and economic) identify a direct link to climate-smart agriculture by assisting eligible producers in adaption to climate change, reducing or mitigating climate change factors or building capacity for resilience in agronomic, ecological, and social and economic systems. Language throughout proposal sufficient to reasonably substantiate climate smart outcomes.
B—Goals, objectives, and outcomes (including social and economic) suggest a link to climate-smart agriculture as described above; OR proposal lacks sufficient language to reasonably substantiate climate-smart claims.
C—Despite lack of direct link to climate-smart agriculture in the proposal, positive climate impacts are likely based on stated goals, objectives, and outcome narratives.
D—Proposal does not appear to include outcomes associated with climate-smart agriculture.
The big news here is that the table makes eligible for an “A” proposals that address climate mitigation, climate adaptation, OR resilience in ag systems. This is interesting since the IRA statute directs USDA (and therefore NRCS) to prioritize proposals that implement climate mitigation activities. Neither climate adaptation nor resilience activities appear in the RCPP IRA statutory language. Opening up the index’s highest score to adaptation and resilience activities will make available the IRA funding to a much broader pool of projects than if the agency hewed strictly to the statute’s climate mitigation language. It will also make many more easement projects eligible for IRA funding as only certain soils in certain geographies may have qualified for the climate mitigation prioritization.
It remains to be seen whether the FY 2023 RCPP proposals will be evaluated against this index. We may never know. The index was not included in the FY 2023 funding announcement even though half of the funding available through the announcement comes from the IRA.
Important for partners interested in Renewals is that eligible awardees no longer are limited to requesting the same or less funding than they were awarded for their first project. Renewals applicants can request up to $25 million for FY 2024, consistent with the FY 2023 funding opportunity. Renewals applicants are also no longer required to submit proposals with the same or greater contribution ratio as their first project. This is also consistent with the FY 2023 funding opportunity, which de-emphasized partner contributions in several ways.
Finally, the Renewals bulletin notes that NRCS intends to make provisional renewal offers to successful applicants no later than October 6, 2023. Since NRCS in past years pushed to make Renewals award offers prior to publication of the next competitive funding announcement, the tea leaves indicate that the agency is setting itself up to release the FY 2024 Classic and AFA announcement as soon as early October (though of course it could be later, as I’ll analyze in a future blog post).
