National Association of Conservation Districts

Comments

On behalf of the nation’s 3,000 conservation districts, I am pleased to submit comments on the long-term policy for the future implementation of the Conservation Reserve Program. Conservation districts have been strong supporters of the CRP since its inception and, in fact, were closely involved in establishing the program and its various components.

The general program, the Continuous CRP (CCRP) for buffers and other conservation practices, the Conservation Reserve Enhancement Program (CREP) and the specialized signups for bottomland hardwoods and wetlands conservation have all added up to one of the most successful conservation efforts in our nation’s history. The program has been especially successful in dramatically reducing erosion on fragile cropland and in providing critical habitat for wildlife on America’s private lands.

Today, as throughout CRP’s 20-year history, conservation districts play a significant role in implementing the program by identifying resource concerns, establishing priorities, identifying potential CRP lands and assisting in the development of CRP conservation plans. Under the CRP statute, conservation districts are also the entities that approve the final CRP conservation plans. All this adds up to making the CRP a truly locally led program; and it is critical in the long-term policy guiding implementation of the CRP that it remain so with decisions made as close to the land as possible.

With respect to the tremendous amounts of contract acreage that are scheduled to expire over the next several years, NACD supports the administration’s commitment to full enrollment of CRP by offering early re-enrollments and contract extensions for producers who wish to continue their participation in the program. Given the fact that resources to provide technical assistance for both new and expiring contracts is already at a premium, offering contract extensions and early re-enrollment options for those already enrolled in the program will go far to help alleviate the CRP workload.

With respect to the long-term CRP issues on which the department is requesting comment, we offer the following:

1. How should CCC address the large number of expiring CRP contracts and their associated acres in a manner that achieves the most environmental benefits but is also administratively feasible and cost effective? What methods should be pursued that would address the large acreage expiring beginning in 2007?
   
   
   • NACD supports the suggestions that the CCC stagger the contract expirations over several year intervals to help the Farm Service Agency and the Natural Resources Conservation Service better manage the workload associated with the nearly 29 million contract acres that will expire between 2007 and 2010. In order to maintain the substantial environmental benefits that have accrued on this acreage, we believe priority should be accorded to re-enrolling existing contract acreage. Extending existing contracts over time will spread the considerable workload over several years and reduce implementation costs rather than allowing large numbers of contracts and acres to expire over a short period of time.
     
     
2. What factors should be considered in determining the acceptability of offers for CRP to provide an equitable balance between soil erosion, water quality, and wildlife benefits, and why?
   
   
   • The 1985 Food Security Act, as amended, provides for a balance in CRP’s environmental goals among soil erosion, water quality and wildlife benefits. In addition to considering a balance among these resource criteria, NACD supports weighing the acceptability of extension and re-enrollment offers based upon the likelihood of the producer maintaining existing conservation practices beyond a contract period. We also support an emphasis on planting native vegetation where new cover is required to be put in place. Although we support the use of planting historically native vegetation, we do not believe it is always wise, necessary or economically practical to require a producer to remove existing non-native vegetation for that purpose.
     
     
3. How could the Environmental Benefits Index (EBI) be modified?
   
   
   • NACD supports the EBI as it is currently used. (Note also answer to # 4 below.)
     
     
4. How could the program be better targeted, whether to certain practices (e.g., filter strips, riparian buffers), geographically, or on some other basis?
   
   
   • CRP enrollment should continue targeting through the use of the EBI with those lands achieving the highest environmental benefit also achieving the highest rental payment. We further believe that the EBI should be a product of the State Technical Committee and not designed as a “one size fits all” program criteria at the national level. States should retain the flexibility that will allow them to choose the criteria that gives them a high EBI. For instance, if soil productivity and soil erosion are major concerns, the EBI should be structured to account for a mix of on-site as well as offsite soil erosion benefits.
     
     
   • The CRP also should be targeted toward retaining long term retention of benefits once investments by the producer and the public are made. These enrolled lands should be retained in the pool of eligible lands and producers should be offered other incentives such as easements to retain them in the program.
     
     
   • We also encourage continual changes to help make the program more geographically dispersed and useful to producers in all parts of the country. CREP and the CCRP for example have greatly broadened the geographic impact of the program.
     
     
5. If CCC offered CRP re-enrollment without competition, how could it ensure that program goals are achieved in a manner that results in the most environmental benefits but is also administratively feasible and cost effective? How could CCC determine which contracts and acres would be most environmentally valuable to re-enroll into CRP without competition through a standard EBI ranking process?
   
   
   • NACD supports offering automatic re-enrollment without competition for producers whose EBI score exceeds a certain benchmark. We believe that this would be a cost-effective and environmentally defensible approach to addressing the issue of a large amount of contract acreage expiring within a relatively short window of time.
     
     
6. In what ways and for what purposes could acreage be set aside to assist local areas to meet local priority concerns?
   
   
   • NACD strongly supports the approach used in the CREP, through which states identify priorities and provide matching resources to address local and state natural resource issues that also address national conservation priorities. We also support the continuation of the of the acreage set-aside and approach used in the continuous CRP enrollments, including acres eligible under CREP, the FWP, and wetland and bottomland hardwood tree restoration, and other initiatives such as isolated wetland restoration initiative and the northern bobwhite quail habitat initiative included in the CRP long-term policy discussion.
     
     
7. Because CCC is concerned about the supply, quality, and cost of seed and tree stock, how can the agency manage large CRP enrollments in future years to address the need to seed and plant vegetation on newly enrolled acres?
   
   
   • As noted in the draft policy discussion, on September 30, 2007, CRP contracts on approximately 16 million acres will expire. Allowing early re-enrollments and contract extensions to producers will spread the need for re-seeding large portions of these 16 million acres of expiring land over a longer, more manageable time frame.
     
     
8. How can Geographical Information System (GIS) technology be used more effectively?
   
   
   • NACD supports expanding the use of GIS technology to assess and capture information for environmental benefits and to assist farmers and ranchers understand the impacts of various offer scenarios. We also support the use of GIS technology to capture data for program evaluation purposes.
     
     
9. How can local adverse economic impacts, if any, be mitigated?
   
   
   • Although NACD supports the 25 percent county acreage cap, a recent report by the USDA Economic Research Service (Agricultural Economic Report No. (AER834), October 2004 ) showed that high levels of CRP enrollment appear to have affected farm-related businesses over the long run, but growth in the number of other non-farm businesses moderated CRP’s impact on total employment. The report suggests that the CRP’s impact on outdoor recreation spending, for example, increased local economies by up to $300 million per year in rural areas.
     
     
   • Since the CRP has been functioning for 20 years, if the program is responsible for any adverse economic impacts, they likely took place long ago and have since been absorbed or mitigated.
     
     
10. What performance measures can be adopted that are most meaningful and accurately reflect CRP’s benefits, but also can be reasonably measured and evaluated?
    
    
    • We believe the most meaningful performance measure is whether a producer is fully implementing his or her conservation plan. Since soil and water quality benefits are good indicators of success, tools such as the National Resources Inventory provide accurate indicators that the CRP is, in fact, doing what we expected—saving soil, enhancing water quality and increasing wildlife habitat.
      
      
11. How could CRP be designed to most effectively address hypoxic conditions in the Gulf of Mexico?
    
    
    • CRP is already playing a significant role in mitigating agriculture’s contribution to hypoxia in the Gulf of Mexico. Through the base program and its various offshoots—CCRP, CREP, the bottomland hardwoods, isolated wetlands and northern bobwhite quail initiatives—are providing significant improvements in stemming soil erosion and nutrient runoff. Support for the program needs to continue these important initiatives.

Finally, conservation districts have 20 years experience in implementing and maintaining the CRP as one of the nation’s most successful conservation efforts, we strongly encourage USDA full utilize their capacities to continue its success.

We appreciate the opportunity to provide our views.



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