Grant Management

Posted on

September 8, 2025

Navigating CPA-52: A Step-by-Step Guide for AMP Conservation Practice Planning

Isabelle Talkington
Farmer Success Associate

Completing the NRCS-CPA-52 Environmental Evaluation Worksheet is one of the most common pain points in conservation planning today. For partners in the USDA’s Advancing Markets for Producers (AMP) initiative, the form is more than paperwork, it is the backbone of conservation planning, ensuring that natural resources are protected, environmental concerns are documented, and practices meet federal regulations like NEPA and the Clean Water Act.

Yet program managers, service providers, and landowners often struggle with eligibility rules, amendments, version tracking, and supporting documentation. That confusion ripples upward, overwhelming state points of contact (POCs). This guide will help your team complete and manage the NRCS-CPA-52 with confidence.

We’ll break down each section of the worksheet, highlight practice standards, provide templates and guide sheets, and share practical “do/don’t” examples. Along the way, we’ll tie requirements to real-world scenarios like composting, riparian buffers, wetlands mitigation, and wildlife habitat enhancement.

Why CPA-52 Matters Right Now

In February 2025, the USDA released updated CPA-52 forms and environmental evaluation worksheet instructions. Every conservation practice supported by NRCS technical or financial assistance must now include an approved CPA-52. The form ensures alignment with:

  • Federal agencies’ obligations under NEPA, the Endangered Species Act, and cultural resources laws.
  • State office procedures for mitigation and outreach.
  • Local government permitting is tied to land use and water quality.
  • Long-term management plans and easements are required for program eligibility.

Without a signed CPA-52, no conservation practice can proceed. That includes cropland practices like cover cropping, irrigation water management, or nutrient applications; livestock systems like waste storage and grazing; and landscape protections like riparian buffers or wetland restoration.

Step 1: Gather Basic Client and Project Information

Section A–D of the form asks for client details, plan ID, and objectives. Sounds simple, but missing identifiers is a top reason forms bounce back.

  • Do: Use the official farm, tract, and field numbers from FSA records.
  • Don’t: Substitute informal field nicknames or GIS-only coordinates.
CPA-52 Section A-D

This section sets the foundation for identifying resource concerns—whether that’s soil erosion, sediment delivery, or invasive species pressure. Tie objectives to measurable benchmarks. Example: “Reduce phosphorus runoff to improve downstream watershed health and comply with state water quality standards.”

Step 2: Document Resource Concerns and Benchmark Conditions

Section F asks you to inventory soil, water, air, plant, and animal conditions.

For example:

  • Soil: “64 acres, sheet & rill erosion at 6T/ac/yr”
  • Water: “Seasonal high water table, 12 acres cropland”
  • Animals: “Migratory birds present in the riparian corridor”

Do/Don’t callout:

  • Do: Use approved NRCS measurement tools (e.g., RUSLE2, Soil Data Mart).
  • Don’t: Rely solely on anecdotal landowner reports.

This baseline provides the competency benchmark for tracking change over a period of time.

Step 3: Evaluate Alternatives

Sections H and I record the “no action” path versus one or more proposed alternatives. Each must address the underlying need, whether that’s reducing groundwater nitrates, restoring wildlife habitat, or improving irrigation water efficiency.

  • No Action: Document what happens without USDA assistance (e.g., sediment loads continue to rise).
  • Alternative 1: Example—adopt composting and cover crops.
  • Alternative 2: Example—install filter strips and riparian buffers.

👉 Add hover text over “No Action” explaining that it requires the same level of analysis as other alternatives.

Step 4: Address Special Environmental Concerns

Sections G and J pull in Special Environmental Concerns Evaluation Guide Sheets. This is where issues like wetlands, cultural resources, migratory birds, invasive species, and riparian areas are flagged.

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CPA-52 Section G and J

Example:

  • Wetlands: If present, document impacts and whether mitigation or a Clean Water Act permit is needed.
  • Cultural resources: Consult state historic preservation offices if construction may disturb archaeological sites.
  • Migratory birds: Plan timing of practices to avoid nesting season.

Step 5: Mitigation Measures

Section L records how adverse impacts will be avoided, minimized, or offset. Examples include:

  • Relocating a pipeline to avoid a burial site.
  • Installing silt fences during construction to protect clean water and groundwater recharge.
  • Designing composting pads to control leachate.

Do/Don’t callout:

  • Do: Tie mitigation directly to identified resource concerns.
  • Don’t: List vague promises like “we’ll protect wildlife.”

Step 6: Other Agency Coordination

Section K ensures you note required permits or easements—from Corps of Engineers Section 404 permits to state stormwater authorizations.

Coordinate early with:

  • Federal government agencies like EPA and USFWS.
  • Local government for land use and property tax implications.
  • Service providers for technical designs and financial assistance.

Step 7: Record Preferred Alternative and Context

Sections M and N document the selected conservation practice system and explain why it best addresses resource concerns while staying within eligibility requirements.

👉 Add note that context analysis considers significance at multiple scales (farm, county, watershed).

Step 8: NEPA Compliance Finding

Section Q is where the Responsible Federal Official (RFO) certifies whether the action is:

  1. Not a federal action.
  2. Categorically excluded.
  3. Covered by an existing programmatic EA.
  4. Covered by an adopted federal NEPA document.
  5. Requires further EA/EIS.

Do/Don’t callout:

  • Do: Ensure all supporting documentation is attached before the RFO signs.
  • Don’t: Submit with incomplete consultation records.

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CPA- 52 Section Q

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Step 9: Attach Guide Sheets and Supporting Documentation

At the end of the CPA-52 packet are Evaluation Procedure Guide Sheets for Clean Air, Clean Water, wetlands, endangered species, etc.. These must be included whenever a concern is present.

CPA-52 Evaluation Procedure Guide Sheet Clean Air Act
CPA-52 Evaluation Procedure Guide Sheet Migratory Birds, Bald, and Golden Eagle Protection Act
CPA-52 Evaluation Procedure Guide Sheet Riparian Area

Version Control and Amendments

One of the top questions raised during the NRCS webinar was how to handle amendments and additional information.

  • Dropping acres: Allowed without a new CPA-52.
  • Adding acres: Requires a revised CPA-52.
  • Renewals: Same field, same practice = no new form.
  • New practices: Requires a new or revised CPA-52.

Do/Don’t callout:

  • Do: Clearly label submissions as “initial” or “revision” in the Box portal.
  • Don’t: Email environmental evaluation worksheets—PII rules prohibit it.

Tips for Success

  • Use templates and state-specific guide sheets.
  • Leverage technical assistance from NRCS state specialists.
  • Conduct on-site visits to verify conditions.
  • Maintain consistent naming for uploaded files in Box.
  • Provide additional information up front to avoid delays.

Real-World Example: Missouri CRCL Project

The Missouri Center for Regenerative Agriculture enrolled more than 117,000 acres in conservation practices through AMP using a custom digital portal powered by FarmRaise.

“FarmRaise developed a custom enrollment app that has allowed farmers to easily sign up for our $25 million project through a phone, tablet, or computer.” – Dr. Rob Meyers

This project shows how strong CPA-52 workflows can unlock financial assistance, improve environmental quality, and reduce burdens on stakeholders.

Final Thoughts

The CPA-52 environmental evaluation worksheet is not just a compliance form. It is a structured way to ensure conservation practices protect natural resources, support clean water, and align with the U.S. Department of Agriculture’s conservation planning process.

By following the steps outlined above, AMP partners can reduce POC workload, meet federal government requirements by law, and streamline decision-making for both landowners and program staff. With the right templates, outreach, and digital tools, completing the CPA-52 becomes less of a bottleneck and more of a pathway to resilient landscapes and thriving watersheds.

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