NCC Comments on the Long Term Policy of the Conservation Reserve Program

The submitted comments to USDA's Farm Service Agency regarding the long term policy of the Conservation Reserve Program.

Published: February 27, 2002
Updated: December 8, 2004

Director, Conservation and Environmental Programs Division
Farm Service Agency
Room 4714-S, Stop 0513
1400 Independence Avenue, S.W.
Washington, D.C. 20250-0513

Dear Sir:

The National Cotton Council of America is pleased to submit comments on the Long Term Policy of the Conservation Reserve Program (CRP) authorized by the Food Security Act of 1985. 

The National Cotton Council is the central organization of the United States cotton industry.  Its members include producers, ginners, cottonseed processors and dealers, merchants, cooperatives, warehousemen, and textile manufacturers.  While a majority of the industry is concentrated in 17 cotton producing states, stretching from the Carolinas to California, the downstream manufacturers of cotton apparel and home furnishings are located in virtually every state.

The industry and its suppliers, together with the cotton product manufacturers, account for one job of every thirteen in the U.S. Annual cotton production is valued at more than $5 billion at the farm gate.  In addition to the fiber, cottonseed products are used for livestock feed, and cottonseed oil is used for food products ranging from margarine to salad dressing.  While cotton’s farm gate value is significant, a more meaningful measure of cotton’s value to the U.S. economy is its retail value.  Taken collectively, the business revenue generated by cotton and its products in the U.S. economy is estimated to be in excess of $50 billion annually.  Cotton stands above all other crops in its creation of jobs and its contribution to the U.S. economy.

The Conservation Reserve Program has provided significant environmental benefits across the nation, primarily by providing wildlife habitat, improving stream quality, and reducing soil erosion.  CRP has been a tremendous asset to producers who have environmentally sensitive land.  Cotton production areas in West Texas have experienced substantial benefits in the reduction of soil erosion due to CRP.  Many aspects of the current program work well for producers including the Continuous Sign-up provision, incentive payments, and wildlife components. 

However there are challenges the program will face in the coming years.  Between September 30, 2007, and 2010, CRP contracts for more than 28.7 million acres are scheduled to expire.  This will create a host of questions and a tremendous amount of work for USDA. 

In general, we recommend the current components of the CRP continue as they appear to be working for landowners. Consistency in sign-up criteria will facilitate educational efforts for participants and administers of the program.  We urge FSA to ensure that rental rates continue to reflect local rates to ensure balanced participation in this program. In addition, we urge adequate training for FSA staff in order to assist landowners who are interested in signing up for this program.  FSA offices in areas of the country where CRP is not widely used should be encouraged to be proactive in promoting the program to individuals with land that could benefit from CRP. 

Policies such as continuous sign-up have been well-received by landowners in many parts of the Cotton Belt and have complimented overall farm conservation plans.  This procedure allows more flexibility in implementing conservation practices .The use of incentive payments is also a practice that should continue to be utilized in future CRP policy.  The use of CRP in some areas of the country is contingent on these incentives. 

One of the challenges facing the administration of CRP is the question of how to deal with the over 27 million acres of expiring contracts between 2007 and 2010.  We believe the Presidential declaration earlier this year made a good start to answering this question.  President Bush’s directive to USDA to offer early re-enrollment and contract extensions for CRP contracts expiring during these years offers USDA the opportunity to sustain the benefits already achieved through this program and help ease a “manpower” problem the department faces. 

The land with expiring contracts has a tremendous amount of conservation investment by the government.  Such investment would be lost if these contract expire and the landowner who wishes to re-enroll in the program is denied.  USDA should offer re-enrollment to all CRP participants whose contracts are set to expire.  These lands have previously been scrutinized regarding the environmental benefits and found to be eligible for the program. 

If USDA chooses a more traditional review in the re-enrollment process then it is our recommendation that special consideration be given to expiring contracts.  Those landowners that wish to continue their participation should have a reasonable expectation of meeting the minimum enrollment score based on the environmental concerns most prevalent on their land. They should also be given a reasonable opportunity to enhance these benefits by expanding the scope of their offers to address additional CRP focus areas such as water quality enhancement and improving wildlife habitat.  However, given the acres have already been found to meet stated environmental objectives and accepted into the program; voluntary automatic re-enrollment would produce tremendous cost-saving and a reduction in “man hours” to operate the program. 

Through the President’s directive it would seem logical that USDA should consider offering staggered contract enrollment terms so that in 10-15 years we are not met with this same problem.  By offering contract extensions and encouraging early re-enrollment the department could balance their workload over several years and have a more manageable expiration. 

The National Cotton Council compliments USDA on the administration of the Conservation Reserve Program and urges it’s continuation as one of the most successful of the government conservation initiatives.  We appreciate the opportunity to provide these comments.

Sincerely,

Woody Anderson, Chairman
National Cotton Council of America