Letter to Tom Vilsack, Secretary of Agriculture - Regarding Mid-Contract Management for CRP Practices

Letter

Dear Secretary Vilsack:

The Conservation Reserve Program (CRP) has provided landowners and operators an effective means of protecting marginal and fragile lands, enhanced wildlife populations, and has delivered emergency feed when severe drought and other natural disasters have occurred.

Although many blame increased commodity prices over the past few years for the reduced enrollment in CRP, another factor has contributed greatly to the decreasing interest in CRP participation--the current required destruction of residue removed from CRP land enrolled under several different conservation practices (CP). Destruction of this residue, rather than allowing it to be utilized as feed, is resulting in unnecessary CRP maintenance costs that make CRP a much less attractive and cost-effective program for enrollees. Additionally, payment for the destruction of this residue, which is far less than the actual cost to harvest and destroy the residue, results in needless costs to taxpayers.

Mid-contract management, conducted once on a 10-year contract and twice on a 15-year contract, is critical for enhancing permanent vegetative cover quality and wildlife productivity on CRP acreages. And, for certain practices, requires CRP participants to destroy the residue by baling and stacking the residue and burning it. The logic behind burning this vegetative cover, which could instead be used for feed, is not only difficult for producers and others to understand, but the burning creates a safety risk as well.

Practices CP8A, CP9, CP15A, CP21, CP22, CP23, CP23A, CP24, GP25, CP27, CP28, CP29, CP30, CP33 CP 37, CP 38-SAFE, CP41, and CP42 are subject to the current restriction of destroying residue removed under mid-contract management. Policy allows that managed haying and grazing, and emergency haying and grazing can be used in conjunction with mid-term activity; however, these activities are limited to only a select few practices and do not include the subject practices.

Several CRP participants and strong supporters of CRP in South Dakota have shared with me their displeasure over the restriction that permanent vegetative cover removed from land enrolled in any of the above-mentioned practices cannot be utilized in a practical and common sense manner in lieu of being destroyed. They are concerned that this requirement is a major factor in discouraging CRP enrollment in the subject practices.

The South Dakota State Farm Service Agency Committee, the State Technical Committee, the South Dakota Department of Game, Fish & Parks, the U.S. Fish & Wildlife Service, the Association of Fish and Wildlife Agencies, Ducks Unlimited, National Wildlife Federation, and Pheasants Forever all support this request.

I strongly recommend that CRP participants with land enrolled under the subject practices have the choice of making commercial or personal use of the residue removed for mid-contract management or donating the residue to a third party instead of destroying the residue. The following would apply:

A haying or grazing plan created by the Natural Resources Conservation Service must be followed.
Midterm cost-share payments for removal and use of vegetative cover would not be paid.
This would not apply if the residue is donated in the form of haying or grazing.
A 25 percent reduction in annual CRP rental payment would be assessed.
This would not apply if the residue is donated in the form of haying or grazing.
The haying and grazing would not be conducted during the primary nesting season.
Frequency would be according to midterm requirements as established by state and national policy.
As you pointed out at the May 7, 2014, Farm Bill implementation hearing before the Senate Committee on Agriculture, Nutrition, and Forestry, emergency haying and grazing was authorized on many of these practices in 2012. As you know, an environmental analysis was completed in 2012 allowing haying and grazing under emergency release provisions for the subject practices.

Making this recommended change could potentially save $12 million in South Dakota for one required mid-contract management activity on 400,000 of the acres enrolled in these practices. This savings is based on the average continuous CRP rental rate average of $89.23 per acre a 25 percent payment reduction, and the forfeiture of the cost-share payment.

I strongly urge you to make this requested and common-sense change and allow utilization of residue removed from the subject practices for commercial or personal use beginning with mid-contract management in 2014. Doing so would not compromise the objectives of mid-contract management, but would dramatically improve the public perception of CRP and greatly increase CRP enrollment potential.

Thank you for your consideration of this request.

Sincerely,

JOHN THUNE
United States Senate

Source