By Sarah Gonzalez, Director of Communications and Digital Media, and Max Fisher, Director of Economics and Government Relations
NGFA is providing several recommendations to improve the U.S. Department of Agriculture’s (USDA) draft environmental assessment of the Conservation Reserve Program (CRP), which it completed as part of the rulemaking process for implementing the 2018 farm law.
NGFA’s comments, which will be submitted to USDA on Oct. 27, counter portions of the USDA Farm Service Agency’s (FSA) draft report, in which the agency assessed the anticipated environmental impacts of potential changes to the CRP made by Congress in the 2018 farm law.
Signed into law in December 2018, the farm law allows USDA to permit dryland agricultural uses on land enrolled under the Conservation Reserve Enhancement Program (CREP) so long as these agreements involve significant long-term reduction of consumptive water use. However, FSA’s draft environmental assessment published earlier this month would disallow any dryland agricultural uses under CREP.
In its statement, NGFA will urge USDA to reconsider its position. “This provision was included (in the 2018 farm law) for communities that are losing irrigation, which usually helps generate higher than normal economic activity,” NGFA said. “Disallowing agricultural use for the regions that are losing irrigation could result in additional significant economic harm to the affected local communities.”
NGFA’s statement also disagrees with FSA’s assertion that no disadvantaged groups would be adversely or disproportionately affected by CRP. NGFA suggested the agency track the financial transactions of a landowner with large tracts of CRP enrollments compared to the financial transactions of owners/operators of neighboring large tracts of land that are in crop production. For example, NGFA found in Wayne County, Iowa, one acre of corn cropland can generate $1,342 of local economic activity associated with the production and sale of the crop. Meanwhile, one acre of CRP land in Wayne County generated a government CRP outlay of $114. Several county-by-county economic analyses of CRP are available on NGFA’s farm bill issues webpage.
In the 2018 farm law, Congress included several CRP reforms that the NGFA supported throughout the process, including reducing CRP rental rates to better target the program to marginal, environmentally sensitive land. “Too much productive farmland currently is enrolled in CRP, and reducing rental rates should help refocus the program on truly highly erodible and environmentally sensitive land,” NGFA says in its statement to FSA.
The reforms are intended to help remove more productive farmland from CRP, but the NGFA’s statement expresses disappointment that FSA chose to not consider the Farmland Protection Policy Act of 1981 as part of its CRP analysis. Congress enacted the Farmland Protection Policy Act as a subtitle of the 1981 farm law with the intended purpose to “…minimize the extent to which federal programs contribute to the unnecessary conversion of farmland to non-agricultural uses…” The law is in place, in part, because of the National Agricultural Lands Study, which found that a significant number of federally sponsored programs contribute to farmland conversion.
More recently, USDA’s Natural Resources Conservation Service’s 2015 Natural Resources Inventory noted that between 2012 and 2015, approximately 6 million acres of former cropland expired from CRP and only half of the former cropland thereafter was restored to cropland. In addition, roughly 25 percent of the land enrolled in CRP is prime farmland. NGFA urged FSA to reconsider the Farmland Protection Policy Act in its assessment of CRP.