What AMP Partners Need to Know About Environmental Evaluation Requirements

Partners in the USDA’s Advancing Markets for Producers (AMP) program are facing a new reality: environmental evaluation requirements have changed. While many AMP grantees have already been working hard to enroll farmers, streamline payments, and track outcomes, NRCS recently clarified that all projects must now follow updated compliance rules under the National Environmental Policy Act (NEPA) and related statutes.

This shift affects every AMP partner organization. The good news is that NRCS has provided a clear environmental review process to keep projects moving forward while ensuring accountability to federal regulations and environmental protection standards. This blog provides a high-level summary to help partners establish trust with producers, maintain compliance, and avoid delays.

Why the Change?

During a recent national environmental compliance webinar, NRCS leaders explained that prior exemptions and guidance are no longer valid for AMP. Instead, all partners must conduct a formal environmental evaluation using NRCS’s CPA-52 worksheet. This ensures every federal action funded under AMP meets requirements for environmental laws, executive orders, and federal regulations.

The agency emphasized three drivers of this change:

1. Consistency across federal agencies – Aligning AMP with the National Environmental Policy Act (NEPA) and related environmental review standards.
2. Transparency for stakeholders – Documenting how projects avoid or mitigate significant environmental impacts.
3. Partnership accountability – Meeting commitments to tribal nations, states, and other agencies such as the Environmental Protection Agency (EPA), the U.S. Fish and Wildlife Service, and the Department of Transportation.

In short, NRCS must show that every proposed action under AMP is legally defensible, environmentally responsible, and transparent to the public.

Core Environmental Requirements

The updated rule emphasizes compliance with three major laws:

• National Environmental Policy Act (NEPA) – Requires evaluation of potential impacts on the human environment, including land use, water quality, air quality, and environmental consequences of a proposed project.
• Endangered Species Act – Ensures projects consider reasonable alternatives and avoid harming threatened or endangered species or their habitats.
• National Historic Preservation Act – Protects cultural and historic resources, requiring consultation with state and tribal preservation offices when conservation practices may affect historic properties.

Partners should also be aware that other federal statutes and executive orders apply, covering areas such as wetlands, hazardous materials, contaminants, and historic preservation.

The CPA-52: Your New Compliance Roadmap

The central tool in the environmental review process is NRCS’s CPA-52 worksheet. All AMP partners must complete this form before implementing new conservation practices. The CPA-52:

• Documents environmental assessments, including scoping for environmental issues.
• Identifies mitigation measures and reasonable alternatives.
• Determines whether a project qualifies for a categorical exclusion, results in a Finding of No Significant Impact (FONSI), or requires a full Environmental Impact Statement (EIS).
• Provides a clear table of contents for reviewers and ensures required appendices and references are included.

Importantly, NRCS clarified that most AMP projects will not require a stand-alone draft EIS or environmental impact statement. Instead, they will rely on the programmatic environmental assessment already in place, provided each partner documents site-specific evaluations and addresses any extraordinary circumstances.

What This Means for Partners

1. Every new practice requires an evaluation

For each proposed project location or conservation practice, a new CPA-52 must be completed. If the same farmer continues the same practice on the same field in future years, the original form remains valid.

2. Expansion triggers reevaluation

If acres are added or new practices introduced, partners must complete a revised environmental evaluation. Dropping acres is simpler, but any expansion requires a fresh look at environmental effects.

3. Implementation cannot proceed without approval

The CPA-52 must be approved before any conservation practice is installed. While contracting with producers can occur earlier, NRCS made clear that no on-the-ground work should begin until the record of decision (ROD) or FONSI is confirmed.

4. Consultation is an NRCS function

AMP partners cannot conduct direct consultation with regulatory agencies. For example, if the Fish and Wildlife Service or a State Historic Preservation Office must be engaged, NRCS will lead the communication. However, partners must provide accurate maps, site descriptions, and other supporting environmental documents to keep the process efficient.

Key Compliance Considerations

Endangered Species

Partners must coordinate with NRCS state offices to compile species lists, often using the Fish and Wildlife Service’s IPAC tool. Mitigation measures such as altering practice timing or location may be required to avoid adverse effects on species.

Historic Preservation

Projects that may disturb archeological sites, burial grounds, or historic structures require NRCS-led consultation. In states without programmatic agreements, the full Section 106 process under CFR part 800 applies.

Human and Environmental Health

Environmental evaluations also consider risks from contaminants, hazardous materials, or impacts to wetlands and air quality. If adverse environmental consequences are found, projects may require mitigation or redesign before approval.

How Submissions Work Now

A major concern during the webinar was the loss of the old Clark Group portal used to submit environmental evaluations. NRCS has transitioned to a new submission system using a Box intake portal, which feeds into SharePoint for agency review.

Key points:

• All new CPA-52 forms must be submitted through this portal.
• Email submissions are not accepted due to PII protections.
• Partners will receive notifications when their evaluations are approved and can retrieve final files directly.

Building Trust Through Compliance

These requirements may feel like added paperwork, but they provide important benefits:

• Transparency – Producers and communities can see that projects comply with federal standards for environmental quality.
• Legal security – By documenting environmental effects and using the CPA-52, partners shield themselves from challenges under environmental laws.
• Credibility with funders – Demonstrating adherence to NEPA, EPA guidelines, and related statutes reassures gov agencies, grantors, and stakeholders that AMP projects are sound.

FarmRaise's Program Management Solution can help you to manage this additional step when it comes to your applications! 

Next Steps for AMP Partners

1. Review the CPA-52 guidance – Familiarize yourself with the environmental evaluation worksheet, including sections on scoping, mitigation, and environmental impact assessment.
2. Coordinate with your NRCS state office – Each state may have slightly different procedures or programmatic agreements.
3. Prepare accurate supporting data – Maps, narratives, and photographs of proposed actions speed up NRCS’s decision-making.
4. Communicate with producers early – Farmers should understand that environmental reviews are required before practices begin.
5. Stay updated – NRCS will host office hours, share training materials, and provide written clarifications to support partners.

Final Thoughts

The new environmental evaluation requirements for AMP are now in effect. While the changes require careful attention to compliance, they also provide partners with a structured path to ensure projects are legally sound, environmentally responsible, and transparent.

By embracing the environmental review process, AMP partners can protect farmers, uphold commitments to federal and local government stakeholders, and keep conservation practices moving forward.

With strong coordination, clear environmental documents, and proactive communication, AMP projects can continue to deliver measurable benefits to soil, water, and farm communities while meeting the highest standards of environmental protection.