Kevin Craum had just climbed down from the silo and, with an eye toward the sky, wondered if the October afternoon was going to bring yet more rain.

"We're still hoping to get a little more seeding done," he said. Seeding, as in planting a nutrient-absorbing cover crop on one of his farm's recently harvested fields.

It's one of the many conservation practices he and his brother, Steve, use on their 950 acres of rolling Shenandoah Valley farmland. Their livestock is mostly fenced out of the streams on their pastures. They practice no-till agriculture to minimize erosion on their cropland.

"We are trying to do the right thing," said Craum, who is on the Shenandoah Valley Soil and Water Conservation District Board of Directors. "But everyone falls short."

Like many farmers, Kevin Craum is worried that state and federal agencies - people who know little about how his farm operates - will soon increase regulatory controls on his and other farms and write rules for him, his brother and other farmers to follow.

In a step they hope could fend off such rules, the Craums last year began participating in a pilot program started by Water Stewardship, an Annapolis-based nonprofit group, aimed at bringing their farm into compliance with state nutrient reduction goals over a 12-year period.

The program encourages farmers to commit to continuous improvement programs that set a series of two-year goals spread out over a period of 12 years. In exchange for their commitment, Water Stewardship would provide plans, monitor progress and vouch for the farmers' achievement. The organization's independent observation would give state and federal regulators a third-party's validation that pollution reduction goals were met.

That third-party validation is important. As part of its Bay cleanup plan, the EPA is pressing states to establish enforceable and accountable agricultural programs to provide "reasonable assurance" that nutrient reduction goals will be met.

Tom Simpson, a retired soil scientist from the University of Maryland who is executive director of Water Stewardship, said the independent validation is a contrast to the past, when self-reported, but unconfirmed, activities sometimes counted as progress toward goals.

"The days of saying 'trust me, I did it,' are kind of past," Simpson said. "We absolutely think this (validation provided by Water Stewardship) should constitute reasonable assurance."

The incentive for farmers, he said, is "we will stand behind them." The organization will vouch that the farmer is delivering promised improvements, and will have its independent records to prove it.

Simpson isn't necessarily against new regulation, but he thinks they should be written to guarantee the performance of Water Stewardship and other third-party evaluators.

"Regulate the verifiers, not the farmer," he said.

Rich Batiuk, associate director for science with the EPA's Bay Program Office, said it is too early to say whether such a program would constitute reasonable assurance, and some issues remain to be sorted out, such as the validity and level of certainty provided by agreements between farmers and nongovernmental organizations.

"It is a concept that does have some merit," he said. "A lot of us are open to considering different ways to get there, and reasonable assurance is going to take a bunch of different forms."

Third-party review of farm operations is not new. For instance, the nonprofit Food Alliance provides independent verification that producers have safe working conditions, have good environmental stewardship and treat animals humanely. Certification by the organization can aid marketing and other efforts to enhance the value of the produce.

But the verification by Water Stewardship is unique in that it focuses on farm water quality issues linked to Chesapeake Bay goals. For instance, Virginia cleanup plans call for reducing nitrogen and phosphorus runoff from agriculture by 55 percent.

Participating farmers send information about their operation to Water Stewardship, which analyzes the data, then visits the farm. They verify whether practices are being fully implemented - for instance, are stream buffers as wide as recommended?

The assessment examines the entire farm, from the fields that grow the feed to the animals that eat it to the handling of the animal's manure, whether applied on the farm's fields or shipped off-site. They also inspect whether protections, such as fencing, are in place for streams.

Then they calculate the amount of nutrient reductions expected to be achieved from actions taken to date, and how much more has to be done to meet the 55 percent reduction goal.

A representative from the organization then writes a two-year plan for the farm, which incorporates both priorities of the farmer, and recommendations from the organization. The plan also outlines steps, often more difficult actions, the farmer should consider making in the future.

The farmer has to sign the plan to be in the program. While the plan is not binding, it ensures continued follow-up and participation by Water Stewardship—and ensures the organization will vouch for the farmer's actions.

In two years, a representative from Water Stewardship will again visit the farm, verify whether recommended actions were taken, and draw up a new two-year plan.

If a farmer fails to implement all of the objectives in two years, the organization would like them to take alternative runoff control actions. If they are not making progress, they may be dropped from the program.

"The only penalty is that we won't stand behind them if anybody asks," Simpson said.

Water Stewardship gains more access to a farm than a government agency because it signs a confidentiality agreement with farmers up front. Many farmers are wary that government officials will report any problems they find.

"We are private, and being a private, independent third party creates a different level of trust," Simpson said.

As a nongovernmental organization, the organization also has better access to the Mennonites in the valley, who typically don't participate in government programs. Simpson and Dale Gardner, who has been heading the Shenandoah Valley project for the organization, have had several "barn meetings" with Mennonites.

"I feel pretty good that we've been able to reach a critical mass with the Mennonite community," Gardner said. One of the church leaders has strongly encouraged participation in the program. When that happens, he said, "things tend to get done."

Cory Guilliam, district conservationist with Harrisonburg Service Center of the USDA's Natural Resource Conservation Service, said the program is filling an important void in agricultural outreach.

County conservation offices such as his are too short-staffed to develop "whole farm" plans. Instead, they promote a few priority practices to farmers. Often, those practices may not be the farmer's priority.

In contrast, the continuous improvement plans from Water Stewardship would likely include the conservation agency's priority measures, but place them in future years while other actions that better fit the immediate goals and financial conditions of the farmer are taken sooner. Yet the two-year goal setting ensures overall progress continues, but in a way amenable to the farmer.

That, Guilliam said, is a better approach for most farmers. "If you set up a long-term plan...they are going to be more apt to listen to you and consider what you are saying," Guilliam said.

"That is truly a problem with government programs," he added. "People making decisions think that we should walk onto a farm and immediately have (the farmer) address all of the issues that they have. That can't work in any business, much less a farm. If you have issues, you need time to address them as time and money allows."

The confidentiality agreement that Water Stewardship signs with a farmer encourages a farmer to be more frank, Guilliam said: "They have nothing to lose, basically." In contrast, farmers tend to worry that an agency representative may report a problem they see.

If the plans are implemented, Guilliam said, "I think they will help keep regulatory agencies off the farms and keep them from being a headache."

But, he cautioned, farmers who are likely to sign onto such a program are probably already more progressive in their conservation actions.

"Will it work for everybody? I don't think so," Guilliam said. "The farmers that are serious and really want to stay in business and want the family to continue farming are the ones that are going to go with that type of thing."

A key question is who should pay for the evaluations over the long term. The pilot project is funded by a group of foundations involved with Bay-related activities.

Simpson expects the program to cost about $1,500 per farm for the initial assessment, and $300 to $600 every two years for the follow-up reviews.

He said the program could be funded by participating farmers if there is a clear benefit or it becomes a substitute for regulation. Or, the companies purchasing the farm products might pay a premium to farmers involved in the continuous improvement program. It's also possible some government farm programs could help cover the initial farm assessment.

"We prefer for it not to fall fully on the farmer, simply because it seems that everything falls fully on the farmer," Simpson said. "They are already at the short end of the stick."

Last year, 33 farmers participated in the pilot program, and that is expected to grow to 100 by the end of this year.

It wasn't hard to get Buff Showalter to join. "I love to hunt and fish and am interested in water quality," said Showalter, whose farm has been in the family since the 1830s. "To me, the motivation is to leave the land better than I found it."

No crop land has been plowed on his farm for 15 years and, because all of his streams have 100-foot vegetated buffers - far beyond the minimal 35-feet required - he has invested in 3 miles of pipes to provide off-stream watering troughs for his livestock.

Still, there are things to be done. Since signing onto the continuous improvement program, he has been taking a closer look at nutrient levels in fields, and planting crops that help draw down phosphorus levels that have built up over the years.

But Showalter hopes there might be a payoff down the road. If farmers can be certified for meeting tougher standards, they might eventually be paid a premium for their products.

Indeed, Simpson said it is possible that food manufacturers may one day want to boast in marketing materials that their products all come from farmers who "meet or exceed" water quality expectations by participating in the program.

"If we can make a couple of extra dollars that way, that never hurt anything," Showalter said. "I'm a capitalist.