Soil and Wetlands Conservation: Soil Conservation Service Making Good
Progress but Cultural Issues Need Attention (Letter Report, 09/27/94,
GAO/RCED-94-241).

In 1985, Congress created the conservation compliance program to reduce
soil erosion and the swampbuster program to prevent the conversion of
wetlands to new cropland. The Agriculture Department's Soil Conservation
Service (SCS) manages these programs through more than 3,000 field
offices at the state and county levels. Although SCS has made
considerable progress in placing millions of acres under these
environmental programs, Office of Inspector General evaluations have
urged SCS to improve (1) the quality of farmers' conservation plans and
its decisions identifying wetlands, (2) its related enforcement
activities, and (3) the quality and quantity of information needed to
manage and evaluate the programs. Since 1991, SCS has begun a series of
reforms to address these three areas. This report discusses whether
these reforms will help the agency to better manage these environmental
programs and whether additional improvements are necessary to ensure
effective management.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-94-241
     TITLE:  Soil and Wetlands Conservation: Soil Conservation Service 
             Making Good Progress but Cultural Issues Need
             Attention
      DATE:  09/27/94
   SUBJECT:  Agricultural programs
             Soil conservation
             Land management
             Management information systems
             Regulatory agencies
             Agricultural policies
             Law enforcement
             Farm income stabilization programs
             Farm credit
             Environmental policies
IDENTIFIER:  USDA Conservation Reserve Program
             USDA Swampbuster Program
             
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Cover
================================================================ COVER


Report to the Chairman, Subcommittee on Specialty Crops and Natural
Resources, Committee on Agriculture, House of Representatives

September 1994

SOIL AND WETLANDS CONSERVATION -
SOIL CONSERVATION SERVICE MAKING
GOOD PROGRESS BUT CULTURAL ISSUES
NEED ATTENTION

GAO/RCED-94-241

Soil and Wetlands Conservation


Abbreviations
=============================================================== ABBREV

  ASCS - Agricultural Stabilization and Conservation Service
  GAO - General Accounting Office
  OIG - Office of Inspector General
  SCS - Soil Conservation Service
  USDA - U.S.  Department of Agriculture

Letter
=============================================================== LETTER


B-257452

September 27, 1994

The Honorable Charlie Rose
Chairman, Subcommittee on Specialty
 Crops and Natural Resources
Committee on Agriculture
House of Representatives

Dear Mr.  Chairman: 

Among the environmental programs for agriculture that the Congress
established in 1985 were the conservation compliance program to
reduce soil erosion and the swampbuster program to prevent the
conversion of wetlands to new cropland.  The Soil Conservation
Service (SCS) in the U.S.  Department of Agriculture (USDA) is
principally responsible for implementing these programs through its
more than 3,000 field offices at state and county levels.  While SCS
has made considerable progress in placing millions of acres under
these environmental programs, several evaluations by USDA's Office of
Inspector General (OIG) and others have found three key program areas
needing management improvements.  (See bibliography.) These
evaluations found that SCS needed to improve (1) the quality of
farmers' conservation plans and its decisions identifying wetlands,
(2) its related enforcement activities, and (3) the quality and
quantity of information needed to manage and evaluate the programs. 

Since 1991, SCS has initiated a series of reforms to address these
three areas.  You asked us to determine (1) whether these reforms
will help the agency to better manage its conservation compliance and
swampbuster programs and (2) if additional improvements are necessary
to ensure effective management. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

SCS has undertaken extensive reforms to more effectively manage the
conservation compliance and swampbuster programs.  While these
reforms are noteworthy, several additional steps are needed.  For
example, SCS has substantially revised its guidance to county offices
to provide more explicit technical instructions on how to develop
conservation plans and identify wetlands, but it has not instituted a
follow-up system to ensure that county offices revise any plans found
to be deficient.  SCS has also developed new enforcement procedures
and instituted more headquarters oversight of state and county
offices.  Headquarters staff responsible for overseeing these
offices, however, lack clear authority to require state and county
offices to follow their recommendations.  Finally, although SCS is in
the process of developing an information system to track all
violations, it still has not established performance goals for the
conservation compliance and swampbuster programs (such as goals for
soil savings to determine how well conservation systems are working
to reduce overall erosion). 

One overarching barrier stands in the way of effective implementation
of SCS' reforms and the achievement of the programs' full
potential--the cultural conflict within SCS between its new
regulatory role under the 1985 act and its traditional role of
advising and helping farmers.  Our evaluation and many of the studies
we reviewed found that SCS' internal conflict contributes to the
reluctance of SCS county office staff, with whom most contacts with
farmers take place, to cite farmers for violations with their
conservation plans because such citations could result in farmers
losing their farm program benefits.  For example, several OIG audits
questioned whether county office staff were abusing the use of
variances allowed under the program to avoid citing farmers for
violations.  For the past 60 years, SCS' role has been to work
cooperatively with farmers to provide technical assistance and foster
voluntary conservation.  With the addition of the 1985 programs, SCS
is often in the conflicting position of acting as both adviser to and
regulator of farmers.  The agency's new regulatory role, combined
with its traditional role, requires a cultural change within the
agency if it is to effectively administer its regulatory
responsibilities. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Before 1985, this nation annually lost over 3 billion tons of soil
because of erosion on its 420 million acres of cropland.  In
addition, farmers were draining thousands of acres of wetlands each
year and converting them to new cropland.  To address these problems,
the Congress, in the Food Security Act of 1985, required farmers who
participate in federal farm programs to reduce erosion on highly
erodible cropland and, with certain exceptions, prohibited the
conversion of wetlands.  Violators of these program requirements risk
losing federal farm program benefits.  USDA's Agricultural
Stabilization and Conservation Service (ASCS) decides on violators'
continuing eligibility for most federal farm program benefits after
SCS refers the violators to ASCS. 

Under the conservation compliance program, SCS must determine whether
land is highly erodible and, if so, help farmers develop a
conservation plan that spells out how soil erosion will be reduced. 
Farmers subject to this program had to have an approved plan by 1990
and must fully apply soil conservation practices by January 1995. 
SCS is to annually inspect farmers' cropland to ensure that they are
applying the soil conservation practices called for in their plans. 

Under the swampbuster program, SCS must determine whether land is a
wetland and, if so, whether farmers have converted it to new
cropland.  In January 1994, SCS and three other agencies--the Fish
and Wildlife Service within the Department of the Interior, the U.S. 
Army Corps of Engineers, and the Environmental Protection
Agency--signed an interagency agreement that consolidates
responsibility under SCS for identifying wetlands on agricultural
land covered by federal regulation under section 404 of the Clean
Water Act and the swampbuster program.  SCS will begin identifying
wetlands under this agreement in fiscal year 1995. 

To carry out the goals of the 1985 act, as well as its historical
mission of providing technical assistance to foster voluntary soil
and water conservation, SCS has 3,050 state and county offices.  The
line of authority in SCS extends from the chief of the agency to the
heads of its state offices--the state conservationists--who oversee
SCS' county offices, which are headed by district conservationists. 
Four assistant regional chiefs in SCS headquarters provide technical
assistance to the state and county offices through four national
technical centers. 

According to the Chief of SCS, U.S.  agriculture is now carrying out
the most intensive conservation effort ever undertaken on private
land.  As of March 1994, SCS had identified 149 million acres\1 of
highly erodible cropland and had assisted farmers in developing 1.8
million approved plans to reduce soil erosion.  Conservation
practices, such as contouring, terracing, and leaving crop residue
during harvesting (crop residue management), are increasing as a
result of the conservation compliance program, and as appendix I
indicates, farmers had fully implemented 74 percent of the approved
plans as of March 1994.  In addition, as of this date, SCS had
identified 16 million acres of wetlands--the first step in preventing
farmers from converting these lands to new cropland.  Nearly half of
the areas under both programs are concentrated in the Midwest. 

While SCS has taken noteworthy steps to implement program
requirements, evaluations by USDA's OIG and others found that SCS
could improve its effectiveness in several areas.  First, the
evaluations found that many of the conservation plans SCS approved
were deficient, and some of the identifications of wetlands were
questionable.  For example, the OIG noted that many conservation
plans did not adequately specify the actions farmers had to take to
reduce soil erosion, thus making the plans hard to enforce.  Second,
SCS was reluctant to cite farmers who were not in compliance with
their approved plans.  For example, the OIG found that more farmers
were not in compliance with their plans than SCS had reported and
that some county office staff gave farmers a variance to avoid citing
them.  And third, SCS did not have in place adequate information
systems to manage or evaluate these programs.  For example, although
one objective of the conservation provisions is to reduce soil
erosion, SCS (1) has not set soil savings goals in order to measure
its progress and (2) had not estimated soil savings until May 1994
because of deficiencies in its information systems. 


--------------------
\1 This includes 36.4 million acres enrolled in the Conservation
Reserve Program.  These acres are covered by 375,000 10-year
contracts, which also require approved conservation plans.  SCS'
reports on the number of conservation plans include those plans under
the Conservation Reserve Program. 


   OVERSIGHT OF CONSERVATION PLAN
   REFORMS IS INADEQUATE, WHILE
   WETLANDS IDENTIFICATION REFORMS
   ARE ON THE RIGHT TRACK
------------------------------------------------------------ Letter :3

In response to criticisms of the quality of its conservation plans
and wetlands identification efforts, SCS has developed better
guidance and put into place new oversight procedures.  These are
steps in the right direction.  While the reforms and oversight of
wetlands identification appear adequate, SCS has not made all the
institutional changes needed to ensure that SCS county offices fully
implement the reforms to improve the quality of conservation plans. 


      REFORMS TO IMPROVE QUALITY
      OF CONSERVATION PLANS LACK
      EFFECTIVE OVERSIGHT
---------------------------------------------------------- Letter :3.1

SCS revised its operations and procedures manual in March 1994.  SCS
staff use this manual as guidance for developing conservation plans,
identifying wetlands, and conducting enforcement activities.  The
March 1994 manual is the third edition since 1987, and it contains
more explicit technical instructions than did the previous manuals. 
Previous guidance was considered overly broad, making it difficult
for county offices to tailor the plans to specific problems with
cropland and causing the plans to be technically deficient, according
to both SCS headquarters and county office staff.  In contrast, the
new guidance spells out how county offices should develop a plan that
meets specific needs for the cropland.  For example, the new guidance
explains how to describe the (1) conservation problem to be solved or
reduced; (2) conservation practice(s) farmers must employ, such as
the order in which they should rotate crops and/or the amount of crop
residue they need to leave on the ground to reduce erosion; and (3)
maintenance requirements, such as ensuring that terraced areas are
stable.  With these new instructions, county offices are in a better
position to prepare conservation plans that will guide farmers and
provide SCS with an adequate basis for enforcement. 

In addition to its procedures manual, SCS headquarters sometimes
provides guidance and special instructions to its state and county
offices through bulletins.  However, follow-up action is not always
adequate to ensure that county offices implement these bulletins. 
For example, in a February 1991 bulletin, SCS headquarters required
its county offices to revise deficient conservation plans by June
1993.  SCS headquarters did not require state offices to report to
them on the corrections county offices had made, and it has no plans
to determine whether offices met this deadline.  As of April 1994,
SCS headquarters had no method for determining (1) how many plans
found to be deficient were revised and (2) whether the revised plans
were done correctly. 

In March 1992, SCS realigned its management to provide more oversight
of state offices in response to criticisms by USDA's OIG and others
that it had not effectively carried out its regulatory
responsibilities.  SCS assigned responsibility for overseeing state
operations to the four assistant chiefs in headquarters.  By taking
this action, SCS intended, in part, to ensure that farmers had sound
conservation plans.  To achieve this objective, the assistant chiefs
and their technical center staff have started to review state and
county office operations and advise those staff on corrective
actions.  But SCS--maintaining the traditional autonomy of the state
offices--did not give the assistant chiefs clear authority to require
state offices to act on headquarters' recommendations.  Consequently,
headquarters and technical center officials told us that they do not
know how effectively state offices will implement the
recommendations.  For example, one technical center official in the
Midwest found that conservation plans were still deficient after
state offices had been told to revise all deficient plans.  The
official expressed concern that some county offices may not revise
the plans in time for farmers to meet the 1995 deadline for fully
applying their plans. 


      REFORMS AND OVERSIGHT OF
      WETLANDS IDENTIFICATION
      APPEAR ADEQUATE
---------------------------------------------------------- Letter :3.2

SCS' guidance in the March 1994 edition of the operations and
procedures manual for wetlands identification is far more useful than
the old guidance and was developed in cooperation with the Fish and
Wildlife Service, the Environmental Protection Agency, and the Corps
of Engineers.  SCS' January 1994 interagency agreement with these
agencies provides for agreed-upon locally set standards for
identifying wetlands and for training personnel.  In addition, the
agreement provides for interagency teams to review and certify the
accuracy of SCS' past wetlands identifications and to periodically
review future wetlands identifications conducted by SCS county
offices.  Officials with SCS and the Fish and Wildlife Service
believe that when SCS resumes the wetland identification process, now
scheduled for fiscal year 1995, the revised guidance and the
oversight called for in the interagency agreement should improve the
process. 


   IMPLEMENTATION OF ENFORCEMENT
   REFORMS IS NOT ADEQUATE
------------------------------------------------------------ Letter :4

As with its efforts to improve the quality of its conservation plans
and wetlands identification efforts, SCS has focused its enforcement
reforms on better guidance and new inspection procedures.  However,
for the conservation compliance program, headquarters oversight is
not sufficient to ensure that reforms are implemented.  In addition,
there is no program for regular field inspections to monitor for
violations of wetlands regulations. 


      SCS HAS NOT ENSURED
      IMPLEMENTATION OF
      ENFORCEMENT REFORMS FOR
      CONSERVATION COMPLIANCE
---------------------------------------------------------- Letter :4.1

SCS has developed new enforcement procedures for the conservation
compliance program and instituted more headquarters oversight of
state and county offices.  Headquarters staff responsible for
oversight, however, lack clear authority over SCS' state offices to
ensure that enforcement reforms are implemented. 

Enforcement for the conservation compliance program primarily
consists of two levels of review.  First, SCS county offices must
annually review a statistical sample of conservation plans to test
farmers' compliance with those plans, commonly called a status
review.  Second, SCS state offices must assess the performance of
county offices by reviewing a sample of the status reviews--a process
referred to as the quality review. 

Recognizing that the county office status reviews are the "building
block" of enforcement, SCS has made continuing efforts to provide
clearer guidance in its procedures manual on how county offices are
to inspect highly erodible cropland to determine farmers' compliance
with conservation plans.  SCS found that earlier guidance contained
in its procedures manual was not specific enough for county offices
to use as an effective enforcement tool.  For example, county office
staff would sometimes convert a compliance review into an advisory
session and give the farmer found in violation another opportunity to
comply without penalty.  In May 1991, SCS provided new guidance to
clarify for county offices the difference between providing technical
assistance and conducting compliance reviews of farmers. 

In addition to improving guidance, SCS headquarters has also been
concerned about the underreporting of violations.  While the
percentage of violations reported at the state level for 1991, 1992,
and 1993 was 1.6, 2.6, and 3.6 percent, respectively, other
organizations, including USDA's OIG, reported higher levels of
violations.  (See app.  II.) For example, in 1991, USDA's OIG found
that about 10 percent of the farmers were in violation of their
conservation plans.  In response, the SCS Chief in a May 1992
bulletin encouraged county offices to rotate staff conducting status
reviews so that they are not inspecting farmers in their own
community.  However, this was not a mandatory requirement and,
according to SCS officials, has not changed most county office
practices. 

Another SCS headquarters' enforcement concern was that the annual
state quality reviews left too much authority in the hands of the
state conservationists.  In response, as part of SCS' March 1992
decision to give its four assistant chiefs responsibility for
overseeing state operations, SCS also required the assistant chiefs
to review the state conservationists' annual quality review of
county-level enforcement decisions.  This was intended to ensure that
state offices were effectively overseeing how county offices were
inspecting farmers, enforcing compliance with their plans, and
implementing the enforcement reforms.  SCS' March 1994 revised
operations and procedures manual incorporates the requirement for the
assistant chiefs to review the state conservationists' annual quality
review of county-level enforcement decisions.  However, as mentioned
earlier, when SCS assigned the assistant chiefs this new
responsibility, it did not give them authority to require state
conservationists to implement their recommendations.  In some cases,
this situation has sent a mixed signal to state and county offices as
to the seriousness on the part of SCS headquarters. 


      SCS HAS NOT ESTABLISHED A
      ROUTINE INSPECTION PROGRAM
      FOR WETLANDS
---------------------------------------------------------- Letter :4.2

While SCS requires all county offices to conduct annual status
reviews for compliance with conservation plans, it does not do so for
wetlands.  Several evaluations have criticized SCS' monitoring of
violations of wetlands regulations and concluded that wetlands
conversion (swampbusting) could go undetected.  As of March 1994, SCS
had identified an estimated 50 percent of the wetlands (16 million
acres) that are subject to the swampbuster program.  However, SCS had
not established a routine inspection program aimed at ensuring that
swampbusting is detected, farmers' compliance with the program's
regulations is enforced, and farmers are deterred from swampbusting. 
Until a routine field inspection program for wetlands is established,
SCS cannot be assured that violations have not occurred. 


   SCS HAS NOT COLLECTED
   INFORMATION ON PROGRAMS'
   PERFORMANCE BUT WILL TRACK
   VIOLATIONS
------------------------------------------------------------ Letter :5

Several evaluations found that SCS had not collected the information
necessary to effectively manage the conservation compliance and
swampbuster programs and report on the programs' performance and
results.  According to SCS officials, before these programs were
enacted, the agency administered through its county offices diverse
voluntary programs that were responsive and accountable to local
priorities.  Because of its tradition of autonomous state and county
office operations, SCS headquarters did not systematically evaluate
field offices' performance or the environmental benefits being
achieved.  It was not until May 1993 that SCS began developing a
national system to track program violations. 

For the conservation compliance program, SCS began to collect
information starting in 1993 to estimate soil savings resulting from
the farmers' application of their conservation plans, but SCS has not
established a target for national soil savings.\2 For the swampbuster
program, SCS has determined neither the wetlands affected by the
program's regulations nor set appropriate goals for protecting those
resources.  Therefore, SCS cannot measure the conservation benefits
achieved or assess whether farmers are subjected to appropriate and
equitable conservation standards across the nation. 

Even though the conservation compliance and swampbuster programs
began in 1985, several evaluations in 1992 reported that SCS had no
system to track the extent of program violations reported by SCS
county offices and resulting penalties imposed by USDA's ASCS.  In
response, in May 1993 SCS began developing with ASCS a national data
base to track such information.  An SCS headquarters official told us
that the agency expects this tracking system to be fully operational
in SCS county offices in December 1994.  Information compiled to date
has been developed by a nonprofit environmental research and
publishing organization that reviewed SCS and ASCS data. 


--------------------
\2 SCS collected soil savings information on the farms included in
its 1993 status reviews.  SCS reported these estimated soil savings
in May 1994. 


   CHANGING ROLE OF SCS REQUIRES A
   CHANGE IN ITS CULTURE
------------------------------------------------------------ Letter :6

Collectively, the reforms that SCS has put in place will undoubtedly
contribute to better management of the conservation compliance and
swampbuster programs.  However, our review found one overarching
issue that continues to impede the effective implementation of SCS'
reforms and the achievement of the programs' full potential--the
cultural conflict between SCS' new regulatory responsibilities and
its historical role of fostering farmers' voluntary conservation. 
Without a change in SCS' culture, the reforms will provide SCS with
the tools to manage this program but not the discipline and mindset
to ensure that the national environmental mandates imposed by the
1985 act are uniformly carried out. 

Because of this internal cultural conflict, several evaluations have
found that county office staff have been reluctant to cite farmers
for violations--perhaps the acid test of effective regulation.  For
example, several OIG audits questioned whether county office staff
were abusing the use of variances allowed under the program to avoid
citing farmers for violations of their conservation plans.  From 1991
through 1993, about 15 percent of the status reviews were found in
compliance because of the use of variances.  (See app.  III.) While
the 1985 act allows for variances, the OIG found that these are used
by some county offices to avoid citing violations.  Similarly,
assigning responsibility to the assistant chiefs without giving them
the authority to effectively oversee enforcement at state and county
offices sent a mixed signal about the seriousness on the part of SCS
headquarters to eliminate the underreporting of violations.  Finally,
SCS has never established a routine inspection program for the
swampbuster program to detect violations of SCS' wetlands
regulations, a situation that both undermines enforcement and the
protection of wetlands. 

SCS' role for almost 60 years has been to promote voluntary resource
conservation and to work cooperatively with farmers.  SCS carried out
its mission by persuasion and education and promoted this mission as
one that would bring direct benefits to farmers.  Prior to the 1985
act, SCS advised farmers on how to drain and convert wetlands into
new cropland.  Beginning with the act, however, SCS found itself in
the difficult position of now telling farmers that if they converted
wetlands to new cropland they risked losing their farm program
benefits.  Therefore, SCS county office staff are often working with
farmers in two conflicting capacities--as adviser and regulator. 

This conflict in roles may be exacerbated if SCS assumes more
responsibilities for environmental issues facing agriculture. 
Several legislative proposals could greatly increase SCS'
responsibilities to ensure that environmental requirements are
followed.  First, pending legislation to reorganize USDA would fold
SCS into a new Natural Resources Conservation Service.  This new
agency would serve as the single agency for all agriculture-related
environmental programs in the department, including financing
farmers' conservation efforts.  In this capacity, the agency would be
positioned as the lead agricultural environmental agency in the
federal government. 

Second, proposals to reauthorize the Clean Water Act will address the
problem of runoff from agricultural lands.  No matter how
agricultural runoff is regulated, it is generally expected that SCS
or its successor agency will have overall responsibility for ensuring
that farmers comply with the provisions of the act. 


   CONCLUSIONS
------------------------------------------------------------ Letter :7

Nine years after the Congress enacted the conservation compliance and
swampbuster programs, SCS has approved a significant number of
conservation plans affecting millions of acres and recently agreed to
a credible system for identifying wetlands.  SCS has also undertaken
extensive reforms to address concerns identified by critical
evaluations.  While these reforms are laudatory, SCS could make
additional improvements to the conservation compliance and
swampbuster programs so that they operate more effectively and better
prepare the agency for its likely role as the lead federal
environmental agency for agricultural cropland. 

SCS' enforcement actions--perhaps the acid test of effective
regulation--have been problematic.  Enforcement is the area in which
the county offices' traditional role of providing technical
assistance conflicts with their new responsibility for enforcing
program compliance.  This is believed to have led to an
underreporting of violations to avoid citing farmers for violations. 
The enforcement reforms for the conservation compliance program lack
adequate oversight to ensure that they will be implemented, and there
is no routine enforcement process for the swampbuster program. 

While SCS has made some strides in improving information necessary to
effectively manage these programs, it still has not set national
performance goals for soil and wetlands conservation, making it
difficult to measure the success of these programs. 

Finally, the reforms to date do not fully deal with the underlying
dilemma of how to integrate SCS' regulatory responsibilities into its
traditional institutional culture--a culture that for over 60 years
focused on providing technical assistance on conservation to farmers
who requested it.  This cultural conflict may become even more
significant if SCS' environmental responsibilities increase under
proposals for USDA's reorganization and changes to the Clean Water
Act. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :8

To improve SCS' management of the conservation compliance and
swampbuster programs and to provide adequate oversight of the
agency's state and county offices, we recommend that the Secretary of
Agriculture direct the Chief of SCS to take the following actions: 

  Establish an annual status review process for the swampbuster
     program to assess farmers' compliance with the wetlands
     regulations. 

  Give state offices responsibility for conducting annual status
     reviews for the conservation compliance and swampbuster programs
     to avoid the conflict that county office staff encounter between
     advisory and regulatory roles.  There are a variety of
     alternatives to do this.  One possible alternative to avoid this
     conflict could be for state offices to rotate county office
     staff conducting the status reviews so that no SCS personnel
     inspect farmers in their own community. 

  Give the assistant chiefs clear oversight authority of SCS state
     and county offices to ensure that conservation plans and
     wetlands identifications follow the revised guidance and that
     these offices fully and uniformly enforce these programs. 

In order for SCS to develop the information needed to manage these
programs and for USDA, the Congress, and others to better understand
their performance, we recommend that the Secretary of Agriculture
direct the Chief of SCS to

  set performance goals for soil and wetlands conservation, annually
     assess progress towards these goals, and submit the results to
     the Congress in USDA's annual budget submission. 

Because SCS' changing regulatory responsibilities require cultural
changes, we recommend that the Secretary of Agriculture direct the
Chief of SCS to

  develop and implement a strategy to resolve the cultural conflict
     between SCS' traditional role of fostering voluntary
     conservation by farmers and its new regulatory role.  This
     strategy could include training of staff to help them adapt to
     their regulatory responsibilities and requiring SCS headquarters
     to increase oversight of and the accountability of state and
     county offices. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :9

In responding to a draft of this report, USDA said that SCS will
correct the limitations in the conservation compliance and
swampbuster programs, in part aided by the recommendations we make in
this report (see app.  IV for the text of USDA's response and our
detailed comments).  Specifically, USDA agreed with three of our
recommendations and cited several corrective actions under way or
planned for fiscal year 1995.  These actions include instituting an
annual status review process for the swampbuster program,
reorganizing to give the SCS assistant chiefs clear oversight
authority, and developing performance goals and assessing progress
for both programs. 

USDA agrees with us about the cultural conflict SCS employees have
experienced with SCS' regulatory role under these programs.  However,
while recognizing the need for improvement, USDA said that SCS will
defer taking action in response to our remaining recommendations--(1)
to make SCS state offices, rather than county offices, conduct annual
status reviews for both programs and (2) to develop and implement a
strategy to resolve the cultural conflict between the agency's newer
regulatory role and traditional role of fostering voluntary
conservation by farmers.  According to USDA, SCS' role has evolved
since the 1985 farm bill without clear guidance from the Congress. 
Therefore, USDA believes that SCS alone is not in a position to take
corrective action on these two recommendations.  According to USDA,
the appropriate time for discussion and resolution of this issue will
be during the upcoming farm bill debate. 

We agree that the Congress may consider SCS' role anew as it debates
the merits of farm program legislation in 1995.  However, we do not
believe that USDA needs to delay action on reassigning organizational
responsibility for conducting status reviews and developing a
strategy for implementing its assigned regulatory responsibilities
pending congressional action.  In our view, in both the 1985 and 1990
farm legislation the Congress has set forth its expectation that SCS
will assume regulatory responsibilities under the conservation
compliance and swampbuster programs.  In particular, by expanding in
1990 the number of farm program benefits subject to loss if farmers
do not comply with these programs, the Congress signaled that these
regulatory responsibilities were to be fully implemented.  Decisions
concerning organizational structures and implementation strategies
are essentially an administrative function that properly rests with
SCS.  Addressing the cultural barriers within its organization that
impede the effective assumption of its assigned regulatory role is
simply part of SCS' administrative and management responsibilities. 


   SCOPE AND METHODOLOGY
----------------------------------------------------------- Letter :10

To determine SCS' response to criticisms of its management of the
conservation compliance and swampbuster programs, we reviewed
relevant literature and agency documents and records at USDA
headquarters in Washington, D.C., and judgmentally selected USDA
offices in Kansas, Minnesota, Nebraska, North Dakota, and Texas.  We
interviewed SCS and ASCS program officials in headquarters and in
field offices.  We also obtained documents from and spoke with Fish
and Wildlife Service program officials at headquarters and in
Minnesota and North Dakota, as well as USDA's OIG auditors in
Washington, D.C., and Kansas City, Missouri. 

To obtain views on USDA's administration of the programs, we spoke
with representatives from state natural resources and agriculture
agencies in Kansas, Minnesota, North Dakota, and Texas; farmers'
organizations; and environmental and conservation groups. 

We conducted our review from January 1993 through May 1994 in
accordance with generally accepted government auditing standards. 
Written comments from USDA on the results of our work appear in
appendix IV. 


--------------------------------------------------------- Letter :10.1

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 5 days after the date of this letter.  At that time, we will
send copies to the appropriate congressional committees; interested
Members of Congress; the Secretary of Agriculture; the Chief, Soil
Conservation Service; the Inspector General; the Director, Office of
Management and Budget; and other interested parties. 

Please contact me at (202) 512-5138 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
V. 

Sincerely yours,

John W.  Harman
Director, Food and Agriculture Issues


STATUS OF CONSERVATION COMPLIANCE
AND SWAMPBUSTER PROGRAMS, AS OF
MARCH 31, 1994
=========================================================== Appendix I

                               (Acres in thousands)


                                          Percent of
                            Acres with       planned
              Acres with   plans fully   acres fully         Acres
                 plans\a     applied\a       applied    identified         Total
----------  ------------  ------------  ------------  ------------  ------------
================================================================================
Total,           143,885       103,419          71.9        16,429       160,314
 U.S.


Midwest region
--------------------------------------------------------------------------------
Ill.               4,956         3,029          61.1           590         5,546
Ind.               2,343           631          26.9           158         2,501
Iowa              11,562         4,611          39.9           275        11,837
Kans.             12,806        11,496          89.8           149        12,955
Mich.                720           571          79.3           828         1,548
Minn.              2,269         1,348          59.4         1,792         4,061
Mo.                6,520         5,069          77.7           433         6,953
Neb.               9,938         8,432          84.8           315        10,253
N.Dak.             7,708         7,158          92.9         1,737         9,445
Ohio               1,915         1,556          81.3            64         1,979
S.Dak.             4,064         3,256          80.1         1,318         5,382
Wis.               3,583         2,212          61.7         1,001         4,584
================================================================================
Subtotal          68,384        49,369          72.2         8,660        77,044


Northeast region
--------------------------------------------------------------------------------
Conn.                 24            11          45.8            16            40
Del.                  12             5          41.7             8            20
Me.                  125            74          59.2            24           149
Md.                  329           226          68.7            15           344
Mass.                 19            14          73.7             4            23
N.H.                   6             4          66.7             3             9
N.J.                  31            25          80.6            11            42
N.Y.               1,178           731          62.1           484         1,662
Penn.              2,619         1,302          49.7            37         2,656
R.I.                   1             1         100.0           <.5             1
Vt.                  109            79          72.5            28           137
Va.                1,225           687          56.1           242         1,467
W.Va.                102            84          82.4             6           108
================================================================================
Subtotal           5,780         3,243          56.1           878         6,658


South region
--------------------------------------------------------------------------------
Ala.               3,008         1,002          33.3            13         3,021
Ark.                 348           305          87.6           307           655
Fla.                 242           198          81.8           491           733
Ga.                  698           595          85.2         1,959         2,657
Ky.                3,957         2,389          60.4           201         4,158
La.                  238           219          92.0           881         1,119
Miss.              1,795         1,633          91.0           712         2,507
N.C.               1,551           991          63.9           185         1,736
Okla.              5,140         4,457          86.7           161         5,301
Puerto                14             8          57.1             2            16
 Rico
S.C.                 414           349          84.3             5           419
Tenn.              2,599         2,028          78.0           105         2,704
Tex.              12,839         9,351          72.8           511        13,350
================================================================================
Subtotal          32,843        23,525          71.6         5,533        38,376


West region
--------------------------------------------------------------------------------
Alaska                59            43          72.9             3            62
Ariz.                 23            18          78.3           <.5            23
Cal.                 892           636          71.3           114         1,006
Colo.              8,929         6,451          72.2           111         9,040
Hawaii                78            61          78.2           <.5            78
Ida.               3,533         2,156          61.0           157         3,690
Mont.             14,302        11,354          79.4           508        14,810
Nev.                 211           156          73.9            95           306
N.Mex.             2,017         1,544          76.5             5         2,022
Ore.               1,630         1,401          86.0           191         1,821
Utah                 487           368          75.6            71           558
Wash.              3,578         2,091          58.4            82         3,660
Wyo.               1,139         1,003          88.1            21         1,160
================================================================================
Subtotal          36,878        27,282          74.0         1,358        38,236
--------------------------------------------------------------------------------
\a The Soil Conservation Service's (SCS) progress reports for
conservation plans merge together plans prepared to meet the
conservation compliance program requirements and the Agricultural
Stabilization Conservation Service's (ASCS) Conservation Reserve
Program requirements.  SCS cannot provide separate estimates for the
conservation compliance program alone.  As of March 31, 1994, there
were 375,000 10-year contracts under the Conservation Reserve Program
affecting 36.4 million acres; each contract requires a conservation
plan. 

Source:  Strategic Planning Division, SCS. 


CONSERVATION COMPLIANCE VIOLATIONS
REPORTED BY SCS STATE OFFICES,
1991 THROUGH 1993
========================================================== Appendix II

                     (Number and percent)


                                1993        1992        1991
------------------------  ----------  ----------  ----------
============================================================
Total, U.S.                    1,735       2,494       1,153
                                3.6%        2.6%        1.6%

Midwest region
------------------------------------------------------------
Ill.                             102         158          56
                                3.9%        2.5%        1.3%
Ind.                              29         261          67
                                2.7%        4.5%        2.5%
Iowa                             102         211          37
                                4.3%        2.8%        0.6%
Kans.                            129         283          26
                                5.8%        4.5%        0.8%
Mich.                             17          54          59
                                1.9%        6.1%        5.6%
Minn.                             10          18          16
                                1.0%        1.1%        0.9%
Mo.                              106         190          99
                                5.1%        3.9%        2.6%
Neb.                              40          74          41
                                2.0%        1.1%        1.0%
N.Dak.                            61          25           8
                                4.5%        0.9%        0.4%
Ohio                              21          78          59
                                1.9%        3.6%        3.0%
S.Dak.                             7           4           6
                                0.5%        0.3%        0.4%
Wis.                              47         115          77
                                2.8%        2.5%        2.1%
============================================================
Subtotal                         671       1,471         551
                                3.4%        2.9%        1.5%

Northeast region
------------------------------------------------------------
Conn.                              1           2           0
                                2.2%        4.1%
Del.                               0           0           1
                                                       11.1%
Me.                                0           0           0
Md.                               13          24          24
                                2.6%        5.9%        7.5%
Mass.                              1           0           0
                                3.1%
N.H.                               0           4           1
                                           20.0%        7.1%
N.J.                               5          15          17
                                5.1%       12.3%       15.0%
N.Y.                              39          57          19
                                4.2%        3.9%        1.6%
Penn.                             53         183         186
                                3.7%        6.8%        9.2%
R.I.                               0           0           0
Vt.                                1           0           0
                                3.0%
Va.                               50          49          47
                                3.5%        2.2%        2.4%
W.Va.                              2           0           2
                                1.4%                    1.0%
============================================================
Subtotal                         165         334         296
                                3.4%        4.4%        4.8%

South region
------------------------------------------------------------
Ala.                              96         104          41
                                5.3%        5.8%        3.0%
Ark.                               4          17           4
                                0.5%        3.7%        1.1%
Fla.                               3           0           2
                                1.9%                    1.3%
Ga.                               14           8          16
                                1.5%        0.8%        1.9%
Ky.                               38          65          72
                                1.9%        1.0%        1.3%
La.                                3           3           3
                                1.0%        1.5%        1.7%
Miss.                             29          38           3
                                2.2%        3.2%        0.3%
N.C.                             304         144          42
                               11.6%        3.7%        1.3%
Okla.                             88          30          14
                                5.4%        1.0%        0.7%
Puerto Rico                        0           0           0
S.C.                              19          12           4
                                5.9%        2.1%        0.8%
Tenn.                            160         144          33
                                9.2%        3.2%        0.9%
Tex.                              13          31          15
                                0.6%        0.6%        0.5%
============================================================
Subtotal                         771         596         249
                                4.8%        2.1%        1.1%

West region
------------------------------------------------------------
Alaska                             0           0           0
Ariz.                              0           0           0
Cal.                              11           7           0
                                2.7%        2.0%
Colo.                             12          18          10
                                0.7%        0.6%        0.5%
Hawaii                             0           0           0
Ida.                              15          18          35
                                1.4%        1.5%        3.5%
Mont.                             35           3           1
                                1.6%        0.1%        0.2%
Nev.                               0           0           0
N.Mex.                             0           0           1
                                                        0.3%
Ore.                              15          13           9
                                2.9%        4.5%        2.5%
Utah                               4           1           0
                                4.2%        0.5%
Wash.                             35          32           1
                                3.4%        3.0%        0.1%
Wyo.                               1           1           0
                                0.5%        0.3%
============================================================
Subtotal                         128          93          57
                                1.6%        0.8%        0.9%
------------------------------------------------------------
Notes:  Percentage calculated based on total number of
status-reviewed tracts requiring a plan.  The total number of tracts
reviewed for compliance were 48,418 (1993), 93,233 (1992), and 70,988
(1991).  Additional farm tracts were status-reviewed but were
excluded from reported compliance determinations because SCS county
offices decided that these tracts were not subject to conservation
compliance.  These tracts were excluded for various reasons, for
example, they did not contain any highly erodible fields.  The
numbers of excluded tracts were 5,484 (1993), 4,593 (1992), and 214
(1991).

Our review of swampbuster data, discussions with SCS officials, and a
USDA Department of Agriculture, Office of Inspector General (OIG),
audit all indicate the data available on swampbuster violations are
unreliable. 

Sources:  For 1991 and 1992, SCS data compiled by the Center for
Resource Economics, a nonprofit environmental research and publishing
organization (1993); for 1993, Strategic Planning Division, SCS. 


STATUS REVIEWS IN COMPLIANCE DUE
TO CONDITIONS AND VARIANCES
GRANTED BY SCS COUNTY OFFICES, BY
STATE, 1991 THROUGH 1993
========================================================= Appendix III

                     (Number and percent)

State                           1993        1992        1991
------------------------  ----------  ----------  ----------
============================================================
Total, U.S.                    6,625      13,174      11,555
                               14.2%       14.1%       16.3%

Midwest region
------------------------------------------------------------
Ill.                             336       1,025         799
                               13.4%       18.3%       18.2%
Ind.                              21         148       2,134
                                2.0%        3.0%       81.8%
Iowa                             694       1,074         717
                               30.3%       14.5%       11.2%
Kans.                             73       5,862           0
                                3.5%       95.4%        0.0%
Mich.                            145          37          35
                               16.4%        4.2%        3.3%
Minn.                             75          67          34
                                7.9%        4.1%        1.9%
Mo.                              633       1,208         667
                               31.9%       25.8%       17.6%
Neb.                             331         609       2,082
                               17.2%        8.9%       49.9%
N.Dak.                            68         244         193
                                5.2%        9.3%       10.3%
Ohio                             118         155         169
                               11.0%        7.5%        8.6%
S.Dak.                            85          79          74
                                6.4%        5.2%        5.2%
Wis.                             194         211         296
                               11.9%        4.8%        8.0%
============================================================
Subtotal                       2,773      10,719       7,200
                               14.6%       22.0%       19.8%

Northeast region
------------------------------------------------------------
Conn.                              7           0           2
                               15.6%        0.0%        5.7%
Del.                               6           1           2
                               24.0%        7.1%       22.2%
Me.                                0           0           0
                                0.0%        0.0%        0.0%
Md.                               98          49          24
                               20.0%       12.5%        7.5%
Mass.                              3           0           6
                                9.7%        0.0%       13.6%
N.H.                               0           1           3
                                0.0%        5.0%       21.4%
N.J.                              22          15           7
                               20.2%       12.7%        6.2%
N.Y.                             105          79         124
                               11.9%        5.9%       10.4%
Pa.                              468         627         480
                               34.0%       24.0%       23.7%
R.I.                               0           1           1
                                0.0%       25.0%       33.3%
Vt.                                5           1           1
                               15.6%        1.1%        0.8%
Va.                              267          95         133
                               19.5%        6.2%        6.8%
W.Va.                             13           7           3
                                9.0%        3.1%        1.6%
============================================================
Subtotal                         994         876         786
                               21.3%       13.4%       12.8%

South region
------------------------------------------------------------
Ala.                             263          57         795
                               15.4%        3.2%       57.2%
Ark.                              97          23          30
                               13.1%        5.0%        8.3%
Fla.                              11           0          12
                                7.3%        0.0%        7.8%
Ga.                              117          32          82
                               12.6%        3.4%       10.0%
Ky.                              148         250         460
                                7.5%        4.1%        8.1%
La.                               40          17          20
                               13.0%        8.6%       11.5%
Miss.                            147          86          92
                               11.3%        7.3%        9.0%
N.C.                             463          39         349
                               19.9%        1.0%       10.6%
Okla.                            243          99         351
                               15.9%        3.5%       16.5%
Puerto Rico                        3          15           0
                               14.3%        100%        0.0%
S.C.                              10          36           9
                                3.3%        6.6%        1.8%
Tenn.                            385         354         438
                               24.4%        7.9%       12.4%
Tex.                             144         148         142
                                6.1%        3.2%        4.3%
============================================================
Subtotal                       2,071       1,156       2,780
                               13.6%        4.2%       12.5%

West region
------------------------------------------------------------
Alaska                             2           0           0
                               33.3%        0.0%        0.0%
Ariz.                             14           2          74
                               25.9%       11.8%       28.2%
Cal.                              24          39         101
                                6.1%       12.5%       35.8%
Colo.                            193         238         208
                               11.8%        8.5%        9.7%
Hawaii                             0           1           2
                                0.0%       33.3%       50.0%
Ida.                              76          54          73
                                7.1%        4.7%        7.4%
Mont.                            217          48          89
                               10.2%        1.2%       13.4%
Nev.                               3          13           5
                                8.1%       15.7%       15.2%
N.Mex.                            23          13         171
                                3.7%        2.2%       43.7%
Ore.                             107           0          12
                               21.0%        0.0%        4.3%
Utah                               0           0           1
                                0.0%        0.0%        0.6%
Wash.                            114           0          39
                               11.3%        0.0%        5.5%
Wyo.                              14          15          14
                                7.1%        5.2%        7.1%
============================================================
Subtotal                         787         423         789
                               10.2%        3.9%       12.8%
------------------------------------------------------------
Note:  The total number of tracts reviewed for compliance were 48,418
(1993), 93,233 (1992), and 70,988 (1991).  Additional farm tracts
were status-reviewed but were excluded from reported compliance
determinations because SCS county offices decided that these tracts
were not subject to conservation compliance.  These tracts were
excluded for various reasons, for example, they did not contain any
highly erodible fields.  The numbers of excluded tracts were 5,484
(1993), 4,593 (1992), and 214 (1991). 

Sources:  For 1991 and 1992, SCS data compiled by the Center for
Resource Economics, a nonprofit environmental research and publishing
organization (1993); 1993, Strategic Planning Division, SCS. 




(See figure in printed edition.)Appendix IV
COMMENTS FROM THE U.S.  DEPARTMENT
OF AGRICULTURE
========================================================= Appendix III



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on the September 6, 1994, letter
from the U.S.  Department of Agriculture. 


   GAO'S COMMENTS
------------------------------------------------------- Appendix III:1

1.  As noted in USDA's letter, SCS' 1993 status review reports
indicate major reductions in soil erosion attributable to farmers
fully implementing their conservation plans by the end of 1994. 
These data were not available in time for us to fully evaluate them
during our audit.  However, we have raised several questions with
USDA officials about the validity of the projected 1 billion tons of
soil savings attributed by USDA to the conservation compliance
program.  On the basis of discussions with SCS officials, we
determined that this figure includes estimated soil savings from 36
million acres retired under the Conservation Reserve Program, a
separate program from the conservation compliance program.  Moreover,
data released in July 1994 from SCS' 1992 National Resources
Inventory estimated actual soil savings from the Conservation Reserve
Program to be about 369 million tons.  Therefore, as much as 37
percent of USDA's projected 1 billion tons of soil savings could be
based on the benefits achieved under a separate program and not the
conservation compliance program. 

2.  USDA states that SCS supports the development and utilization of
more effective management controls and associated mechanisms to
correct the conservation compliance and swampbuster program
management problems identified in this report.  However, USDA states
that when SCS has been faced with difficult choices concerning the
investment in management controls versus working cooperatively with
the farmer to get good conservation on the ground, SCS has
consciously chosen the latter course of action.  As stated in our
report, SCS has made noteworthy progress in implementing program
requirements.  However, 9 years have passed since the enactment of
these programs, and by January 1995, farmers' conservation plans are
to be fully implemented.  We agree that getting good conservation
practices on the ground is one of the primary goals of the program
but equally important is the establishment of sound management
controls and systems to ensure that plans are being implemented. 
Moreover, as this report and several other studies have documented,
SCS' management problems have reduced the programs' full potential to
achieve soil and wetlands conservation benefits. 

3.  We are aware of the long-running debate surrounding federal
wetlands policy.  We are also aware of the impact that debate had on
SCS' suspension of most swampbuster program activities in May 1991,
despite congressional action in the Food, Agriculture, Conservation
and Trade Act of 1990 directing USDA to complete and certify wetlands
identifications for the swampbuster program.  In this report, we
focus on the good progress SCS has made since January 1994 to reform
its swampbuster program in several areas as a result of the
President's August 1993 wetlands policy. 

4.  USDA agrees with our recommendation that SCS institute an annual
status review process for the swampbuster program.  USDA plans to
design this process for use in 1995.  However, because the proposed
action will not be implemented before this report is issued, we
continue to make this recommendation and will follow-up on USDA's
implementation. 

5.  Although USDA does not disagree on the need for improvement, USDA
believes SCS should not alter its current status review process
pending the outcome of the course of actions described in USDA's
response to our final recommendation (that SCS resolve its cultural
conflict).  For reasons we discuss in detail below, we believe that
USDA need not delay corrective action on this recommendation pending
congressional action on the 1995 farm legislation (see comment #9). 

6.  We revised our recommendation to more clearly state that we were
suggesting one of several possible alternatives for SCS state offices
to implement our recommendation.  USDA said that no difference in the
percentage of reported violations occurred when one-third of SCS
state offices rotated county office staff to conduct status reviews
outside of their community (compared with county staff inspecting
farmers in their own community).  In May 1992, SCS headquarters
suggested that SCS state offices try this approach, but as we state
in this report, this has not changed most county office practices. 
We believe a more systematic evaluation of this approach is merited,
after it is more carefully implemented in a systematic manner. 

7.  In response to our recommendation, USDA agrees to give SCS
assistant chiefs clear oversight authority over SCS state and county
offices under its reinvention efforts.  However, because USDA's
proposed action will not be implemented until after this report is
issued and we have not been provided the details on the scope of this
organizational change, we continue to make this recommendation and
will follow-up on its implementation. 

8.  USDA agrees that better performance goals need to be established
for these programs and plans to establish and annually assess SCS
performance goals for soil and wetlands conservation.  However,
because this proposed action will be implemented after this report is
issued, we continue to make this recommendation and will follow-up on
its implementation. 

9.  In this report, we broadly apply the term "regulatory" to
describe the conservation compliance and swampbuster programs, and
thus SCS' role as the lead federal agency for these programs. 
Technically, ASCS, not SCS, ultimately determines farm program
eligibility for farmers whom SCS determines are not complying with
the soil and wetlands regulations. 

USDA agrees with us about the cultural conflict SCS employees have
experienced with SCS' regulatory role under these programs.  Although
USDA does not explicitly disagree with our recommendation to develop
a strategy to resolve the cultural conflict within the agency over
carrying out this regulatory role and its traditional role of
fostering voluntary conservation by farmers, USDA wants to delay
taking corrective action.  According to USDA, SCS alone is not in a
position to resolve this cultural conflict without first getting
clear guidance from the Congress.  USDA cites the lack of clear
guidance from the Congress to date on the nature of SCS' regulatory
role under the conservation compliance and swampbuster programs and
the appropriate "degree of movement" for SCS in carrying out a
regulatory role.  Furthermore, USDA does not describe any planned
action to actively solicit such clear guidance from the Congress on
this matter. 

We agree that the Congress may consider SCS' role anew as it debates
the merits of farm program legislation in 1995.  However, we do not
believe that USDA needs to delay action on reassigning organizational
responsibility for conducting status reviews and developing a
strategy for implementing its assigned regulatory responsibilities
pending congressional action.  In our view, in both the 1985 and 1990
farm legislation the Congress has set forth its expectation that SCS
will assume regulatory responsibilities under the conservation
compliance and swampbuster programs.  In particular, by expanding in
1990 the number of farm program benefits subject to loss if farmers
do not comply with these programs, the Congress signaled that these
regulatory responsibilities were to be fully implemented.  Decisions
concerning organizational structures and implementation strategies
are essentially an administrative function that properly rests with
SCS.  Addressing the cultural barriers within its organization that
impede the effective assumption of its assigned regulatory role is
simply part of SCS' administrative and management responsibilities. 


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix V

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION,
WASHINGTON, D.C. 

Luther L.  Atkins, Jr., Assistant Director
Carolyn R.  Kirby, Project Leader
Carol Herrnstadt Shulman

KANSAS CITY REGIONAL OFFICE

William H.  Gansler
Mark T.  Amo
Gary T.  Brown


BIBLIOGRAPHY
=========================================================== Appendix 0

Cook, Kenneth A., et al.  Countdown to Compliance:  Implementation of
the Resource Conservation Requirements of Federal Farm Law.  Center
for Resource Economics, Washington, D.C.:  Mar.  1993. 

Cook, Kenneth A., et al.  Farm Bill 1990 Revisited:  Agenda for the
Environment and Consumers.  Center for Resource Economics,
Washington, D.C.:  Mar.  1992. 

Cook, Kenneth A., et al.  Subsidizing Soil Loss:  USDA's Lax
Enforcement of the Federal Conservation Compliance Policy.  Center
for Resource Economics, Washington, D.C.:  May 1992. 

Esseks, J.  Dixon, et al.  Midwestern Farmers' Perceptions of the
Implementation of Conservation Compliance:  Comparisons Between 1990
and 1992 Surveys in the Same Six States.  Center for Governmental
Studies, Northern Illinois University.  DeKalb, IL:  May 1992. 

Soil and Water Conservation Society.  Implementing the Conservation
Title of the Food Security Act:  A Field-Oriented Assessment by the
Soil and Water Conservation Society, Final Report.  Ankeny, IA: 
1992. 

United States Department of Agriculture, Office of Inspector General
for Audit.  Alternative Conservation Systems.  Audit Report No. 
10900-14-KC, Kansas City, MO:  Mar.  1994. 

United States Department of Agriculture, Office of Inspector General
for Audit.  Conservation Compliance Provisions.  Audit Report No. 
50600-3-KC, Kansas City, MO:  Aug.  1992. 

United States Department of Agriculture, Office of Inspector General
for Audit.  Food Security Act Highly Erodible Land Conservation
Provisions.  Audit Report No.  03099-159-KC, Kansas City, MO:  Aug. 
1991. 

United States Department of Agriculture, Office of Inspector General
for Audit.  Rescheduled Status Reviews.  Audit Report No. 
10099-12-KC, Kansas City, MO:  July 1993. 

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