September 14, 2015
Administrator Val Dolcini
Farm Service Agency
U.S. Department of Agriculture
1400 Independence Avenue, S.W.
Washington, DC 20250
RE: RIN 0560-AI30
Dear Administrator Dolcini:
Thank you for the opportunity to comment on the Conservation Reserve Program (CRP) and the agency's implementation of the changes from the 2014 Farm Bill. Our organizations represent commodity growers that have been participants in CRP over its successful 30 year history. Our members look forward to continuing to work with the Farm Service Agency (FSA) to implement CRP conservation practices on their operations into the future.
The changes of the 2014 Farm Bill included several modifications to the program that recognize that conservation objectives can be achieved while increasing farmers' ability to use the land working within the requirement of their conservation plan. Specifically, these modifications cover greater flexibility in the haying and grazing provisions, incidental grazing provisions, wetland provisions related to subsurface drainage, transition incentive payments, allowing access to land in the final year of the contract, and providing transition to other conservation programs. We welcome these modifications and the agency's work to implement these provisions.
CRP has a long, successful history of reducing soil erosion, improving water quality and increasing wildlife habitat. The three priorities for the program of improving soil, water and wildlife resources should be balanced as FSA seeks to re-enroll acres and accept new contracts through CRP. We understand the statutory reduction in the CRP acreage cap can lead the agency to prioritize acres for acceptance into the program, and we ask that you ensure there is an appropriate balance to protect soil, water and wildlife resources. Growers are interested in protecting soil health, water quality and wildlife habitat, and the CRP program should not prioritize one resource concern at the expense of others.
As conservation practices are being developed and refined, a grower's ability to implement the practice should be evaluated. For instance, pollinator habitat conservation practices have been challenging for growers due to the specific seed requirements, the high cost of the seed and the difficulty in seeding and establishing successful plantings. The White House Pollinator Strategy includes increased pollinator habitat. To ensure that growers can be a part of this effort and help USDA meet their goals, practices need to be achievable in the field. We hope to work with you to refine your strategy and work toward practices that create habitat and are workable for growers.
Thank you again for the opportunity to comment on CRP implementation.
Sincerely,
American Soybean Association
National Association of Wheat Growers
National Corn Growers Association
National Cotton Council