Tuesday, June 23rd was the day that comments on the Interim Final Rule on "Conservation Compliance" were due. CIPA submitted additional comments (available here) to supplement the group letter that was sent earlier this month (available here).

In this new comment, we ask for 3 basic accommodations: (1) that FSA and RMA and NRCS reconcile their lists quickly and provide certainty as to who is in and who is out; (2) that the rule be altered to allow producers to restore eligibility if they come into compliance before a relevant SCD; and (3) that producers be allowed to alter or drop coverage if they are notified they are not in compliance after SCD.  We touch on other themes that support these 3 requests, but that is the essence.