The NGFA submitted comments on Sept. 14, 2017, in response to the U.S. Department of Agriculture’s request for ideas on how to provide better customer service and remove unintended barriers to participation in USDA programs in the July 17, 2017 issue of the Federal Register.
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The NGFA’s comments addressed regulations for the following programs:
- Farm Service Agency’s Conservation Reserve Program (page 2)
- Risk Management Agency’s Prevented Planting Coverage (page 6)
- Animal and Plant Health Inspection Service’s Part 340 Proposed Rule (page 9)
- Natural Resources Conservation Service’s Agricultural Conservation Easement Program (page 11)
Farm Service Agency’s Conservation Reserve Program
While there are environmental benefits reaped from targeted use of the Conservation Reserve Program (CRP), NGFA continues to have concerns when productive non-environmentally sensitive land is enrolled in CRP.
“There currently are far too many acres of prime farmland that could generate millions of dollars in economic activity in rural communities being locked up in CRP,” NGFA comments noted. “A more targeted approach will provide more opportunities for beginning farmers and avoid harming the agricultural communities that depend on farming.”
Risk Management Agency’s Prevented Planting Coverage
The NGFA remains a strong supporter of the Federal Crop Insurance Program as it serves as the backbone of the farm safety-net for American crop farmers. However, NGFA members continue to express concerns about the impact of prevented planting provisions on producers’ planting decisions. To help ensure prevented planting coverage within crop insurance does not lead to moral hazard, NGFA urged USDA to align the prevented planting coverage levels with the findings from a 2015 study commissioned by USDA. In addition, NGFA urged USDA to offer producers the option to save on premiums by not purchasing prevented planting coverage. Further NGFA requested that USDA correct the disparate treatment of actual production history (APH) under prevented planting coverage that provides an incentive to not plant the intended or alternative crop. Lastly, NGFA recommended shortening the required delay for planting an alternative crop if a prevented planting payment is collected on the intended crop.
Animal and Plant Health Inspection Service’s Part 340 Proposed Rule
USDA’s Animal and Plant Health Inspection Service’s (APHIS) has proposed revisions to regulations under “Part 340” applicable to the importation, interstate movement and environmental release of certain genetically engineered organisms.
NGFA insists that “APHIS’s regulatory approach must be recognized by, and acceptable to, government regulatory authorities in U.S. export markets so as not to trigger regulatory action against U.S. commodities produced using genetic engineering or plant-breeding innovation, including gene-editing, in international commerce.”
Natural Resources Conservation Service’s Agricultural Conservation Easement Program
NGFA urged USDA to carefully consider the future viability of U.S. crop production when making decisions on granting conservation easements and to avoid the use of the conservation easements that permanently ban crop production and further exacerbate the acceleration the long-term downtrend in the amount of U.S. cropland.
Lacy Holleman
National Grain and Feed Association
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