USDA’s new Regenerative Agriculture Initiative: A step forward or greenwashing?

The guest blog by Michael Happ of the Institute for Agriculture and Trade Policy (IATP) below provides an overview of what USDA’s new Regenerative Agriculture Pilot Program (RPP) is and is not. In the three months since publication, we have learned a bit more about how this is being administered as well as what questions or barriers remain. Find related updates at the end of the blog – Amalie Lipstreu, Agriculture Conservation Director, Midwest Agriculture Conservation Network

In late 2025, the United States Department of Agriculture (USDA), along with the United States Department of Health and Human Services (HHS) announced the launch of a Regenerative Agriculture Pilot Program, also known as the Regenerative Agriculture Initiative (RAI). Through this program, $400 million in existing funds will be set aside for Environmental Quality Incentives Program (EQIP) and $300 million for the Conservation Stewardship Program (CSP). These are not new funds, but rather a set-aside of existing program funds, with no additional funds for staff. This new program requires soil testing for applicants, a whole farm assessment, and the implementation of a primary conservation practice.  

USDA identified 17 existing EQIP practices as “regenerative,” and will set aside funds for farmers utilizing these practices. USDA’s definition of regenerative is “a conservation management approach that addresses natural resource concerns through soil health, water management, and biodiversity to improve the productivity and prosperity of agriculture, communities, and ecosystems.” These practices include cover cropping, prescribed grazing, nutrient management, forest stand improvement, mulching, no till, reduced till, irrigation water management, conservation crop rotation, pest management conservation system, soil and source testing for nutrient management, soil health testing, forage harvest management, conservation planning, contour farming, drainage water management, and strip cropping.  

The involvement of HHS and the focus on regenerative agriculture is a result of the “Make America Healthy Again” (MAHA) movement and its influence on the administration’s agenda. While the RAI does support conservation, this is not a transformative, holistic, or agroecological approach to conserving farmland in the United States.  

What are some unintended consequences of this new program? 

In analyzing this program, it appears that, while people are qualified for funding from the RAI for implementing one “primary” practice, other EQIP practices they implement that are not on the regenerative list are also eligible for the funding. For example, a farmer might plant cover crops to be considered regenerative, but if they’re also building a manure lagoon or other structural practice that is not as conservation-forward, that practice is still eligible for funding. Farmers can apply for multiple EQIP contracts, and the RAI requires a whole-farm assessment that allows for multiple practices across the farm. This program mechanism heightens the risk of practices widely considered non-regenerative eating up a disproportionate share of program funding.  

The risk of large farms vacuuming up a majority of funds is heightened by recent policy changes. Namely, Congress’s recent decision to eliminate payment limits for EQIP and CSP may make fair allocation of RAI dollars harder.  

Additionally, the RAI does not use new money to achieve its goals — it is essentially a set-aside of existing funds that already go toward EQIP and CSP. It is unclear whether this set-aside will dedicate that much more money to these practices than already is allocated. For example, in fiscal year 2022 (FY2022) — one of the more recent years we have complete data for — a total of $254,737,372 was obligated for EQIP practices on the RAI list. It is not hard to see existing obligations for these practices plus additional EQIP practices by the same farmers bringing us to the stated goal of $400 million. USDA’s Natural Resources Conservation Service (NRCS), which will administer the program, needs to demonstrate that the RAI will meaningfully increase the implementation of regenerative practices rather than package existing policy in a way that merely sounds like progress.  

What’s the staffing component? 

Staffing and conservation implementation are deeply linked. The lower the staff capacity, the lower the ability to implement practices targeted toward small-scale producers, as well as more comprehensive, whole-farm conservation through CSP. Research shows that, with fewer conservation staff at the county level, fewer, larger contracts go out the door, rather than more, smaller contracts.  

The RAI cannot work as intended without full staffing at NRCS. This program does not create a new pot of funds and does not include the additional technical assistance needed, meaning local staff support will be strained, making it harder for interested farmers to successfully navigate the application process. Additionally, the soil testing requirement will add burdens on the existing level of staff. Soil testing on its own is not a bad idea, but creating a new requirement for NRCS staff without providing resources to hire on additional staff capacity means that USDA is essentially creating a new unfunded mandate.  

In 2022, when passing the Inflation Reduction Act (IRA), Congress not only allocated over $8 billion for EQIP and over $3 billion for CSP but also allocated $1 billion for conservation technical assistance. In the case of the IRA, Congress had the foresight to know that with additional resources and expectations on staff, NRCS might simply need more staff. Between 2022 and 2024, NRCS added nearly 1,300 new staff across the country in an effort to add capacity and better implement the IRA, reaching a staff of over 11,600 by September 2024. Since 2024, as a result of arbitrary cuts by the Department of Government Efficiency (DOGE), the number of staff at NRCS has plummeted to the lowest level in recent history, projected to drop to 8,000 in 2026. 

List of Regenerative Agriculture Initiative EQIP Practices 

How is this different from IRA funding for “climate-smart” agriculture? 

As IATP’s research has shown, the funding from the Inflation Reduction Act (IRA) was making a measurable difference in addressing the number of farmer applicants closed out of EQIP and CSP. The IRA infused billions more dollars into these programs. In just one year, between 2023 and 2024, the percentage of applicants successfully awarded contracts increased by 18 percentage points for EQIP and 23 percentage points for CSP. Historically, between two thirds and three quarters of farmers who applied to EQIP and CSP were rejected from the programs. Last year, in many states, most of the demand for these programs was being met.   

The Republican budget reconciliation bill from 2025 took the money from the IRA and put it into the baseline of the Farm Bill to extend the lifetime of these funds and increase the cumulative total amount of money going toward conservation programs. This transfer of funds comes with the caveat that funds can be used for any conservation practice, not just those labeled “climate-smart.” Additionally, the amount of dollars flowing to EQIP and CSP is smaller in the short term, but larger in the long term.  

The IRA, similar to the RAI, came with a list of “climate-smart” practices. However, IRA dollars could only go to those practices labeled “climate-smart” or facilitating climate-smart practices. In the case of RAI, while a farmer is required to implement at least one practice on this list and have their soil health tested, it appears as though any additional practice that farmer implements is eligible for RAI funds. Outreach to NRCS did not clarify this element of the program, and there is a lack of clarity within the department. Without clear guardrails from the top, there will be mixed implementation results across the states and territories.  

The RAI practice list and the climate-smart list share some similarities. As shown in the above table, many of the most popular practices are on both the RAI and IRA lists. Additionally, the IRA funded 55 different EQIP practices (out of roughly 160 possible EQIP practices), while the RAI only lists 17. Certainly, by NRCS’s definition of regenerative, there are more than 17 practices that should fit the bill.  

Some of the practices on the RAI list, such as cover cropping and prescribed grazing, are already among the most popular conservation practices in the country. Most farmers will know what these practices are, and it generally is a lower lift to promote them and educate people about these practices’ benefits.  

There are other practices on the list that were used by fewer than four farmers in the entire country in 2025. Such practices as strip cropping, which requires specialized equipment, will likely be a larger lift in terms of not only educating farmers of the benefits, but also educating NRCS staff on how to implement these practices. In a time of lower staffing and higher workload, this seems implausible.  

Where are the trees? 

One glaring omission in the RAI practice list is trees. Only one practice is directly related to trees: forest stand improvement, a practice that allows for forest management to maximize carbon sequestration, biodiversity in forest stands, and general forest health and productivity. However, there are many additional practices that allow farmers and landowners to plant trees or incorporate them into their farms more comprehensively. For example, the practice known as silvopasture helps farmers incorporate trees into livestock grazing, providing important shade and forage opportunities. Other tree-focused practices such as windbreaks, shelterbelts, and buffers can have multiple benefits for farmers, helping prevent wind or water damage to crops while allowing for food-producing trees to be planted as well.  

Regenerative agriculture should mean farms can regenerate the land and restore it to a place where humans and nature can coexist and benefit from one another. Intentional planting of native tree species can, for example, reintroduce native birds that can reduce pest pressures on crops.  

What should happen now?  

The Regenerative Agriculture Initiative has the potential to benefit both farmers and the land. However, as currently designed and given the staffing limitations, it may not have much impact and could disproportionately benefit large-scale farms whose owners already know how to navigate NRCS application processes. USDA and HHS did not have a public input process in the creation of the RAI, where some of these issues could have been raised ahead of program rollout.  

It is our hope that USDA is open to reforms to make the program stronger. Some key changes could steer the program in a more productive direction: 

• Rehire up to pre-2025 NRCS staffing levels and dedicate additional funds to technical assistance. 
• Expand the list of eligible practices to include more comprehensive conservation, in addition to those involving planting more trees, native grasses, and other native species. 
• Do not fund practices that are not on the RAI list. 
• Reinstate payment limits for EQIP and CSP. 

Some of these changes could happen through administrative action alone, while others will require the input of Congress. While these are practical reforms that could make a difference immediately, a larger scale agroecological transition is needed where farmers have the resources and ability to farm with natural methods and food production intertwined. We encourage NRCS to look into what has worked in the past, and not simply hit all the right notes but realistically consider what it takes for a program to be successful.  

While whole farm conservation planning is considered a centerpiece of the program, we are learning that the requirement of a “whole farm assessment” does not mean that every farm will be required to complete Conservation Practice 199 or a conservation plan for the whole farm. Assessments could be at the field or parcel level. In many states Technical Service Providers or TSPs who help farmers plan and certify practices for NRCS including CP 199 are in short supply to even write comprehensive conservation plans which are a gold standard in looking at the entire property and conducting holistic planning for the operation. 

A key component that differentiates RPP is the requirement of soil health testing at the first and fifth year of participation. The practice known as Conservation Evaluation and Monitoring Activity or CEMA 216 Soil Health testing can be completed by a “qualified individual” (QI).  There are many questions about who can be a QI, how and where to get that testing done and some state NRCS offices are providing education on who can be certified in that capacity. 

USDA stated that there will be a Regenerative Agriculture Advisory Council composed of 15 members–nine regenerative farmers representing production systems, three corporate supply-chain or consumer packaged goods representatives, and three consumer or MAHA representatives. The Council is to meet quarterly with the Chief of NRCS for one year.  Our partners at the National Sustainable Agriculture Coalition put forth the names of several potential farmer members of that advisory council but to date, no notice of who has been appointed or the process has been released. – Amalie Lipstreu, Agriculture Conservation Director, Midwest Agriculture Conservation Network

This blog was originally published here by Michael Happ of the Institute for Agriculture and Trade Policy on February 5, 2026. It is reposted on the CalCAN website with permission.

Share This

FacebookTwitter/XEmail