Testimony of
Doug Wolf
on behalf of the
National Pork Producers Council
for the
Subcommittee on Conservation, Credit, Energy &
Research
April 19, 2007
INTRODUCTION
Good morning,
Chairman Holden and Ranking Member Lucas, and good morning to all the Members
of the Committee and staff. My name is
Doug Wolf. I am a pork producer from
I am here this
morning representing the
Along with my wife, son and daughter, we own and operate a mixed livestock and crop operation in the southwest portion of the state. We are a farrow to finish hog operation, raising sows and market pigs. We also raise corn, soybeans and hay. We have permanent pasture where we operate a cow-calf operation and we finish cattle at our farm. We, like our fellow pork producers and most everyone in agriculture, have always taken very seriously our responsibilities to conserve and protect the resources entrusted to us and the environment around us. We have tried to participate in, and help make successful, many of the USDA and state of Wisconsin conservation programs intended to help farmers, and perhaps we have been more active than average in this regard.
The
The hog industry
in the
The
Exports of pork also
continue to grow. New technologies have been adopted and productivity has been
increased to maintain the
It is without a doubt that pork
producers are strong and vital contributors to value-added agriculture in the
Just as importantly, though, pork producers take a broad view of what it means to be environmentally responsible farmers and business people, and we have fully embraced the fact that our pork producing operations must protect and conserve the environment and the resources we use and effect. We take this responsibility with the utmost seriousness and commitment, and it was in this spirit that our producer members made a major commitment to the Conservation Title of the 2002 Farm Bill.
We were proud of how our commitment helped support in 2002 this Committee’s and Congress’s efforts to dramatically increase funding for conservation programs, particularly for the Environmental Quality Incentives Program (EQIP). The re-emphasis given in the 2002 Farm Bill ensured that EQIP be directed toward helping farmers deal with their top federal and state regulatory challenges. We looked forward to enthusiastically participating in the EQIP program to help us continue to improve our environmental performance and meet and/or exceed any state or federal regulatory requirement.
Many of the challenges pork producers faced in 2002 remain with us today, and new ones have developed. We still await full implementation of the 2003 Clean Water Act’s CAFO rule, which has been delayed as a result of the Waterkeeper decision by the U.S. Court of Appeals for the Second Circuit. We now expect the final rule to be issued later this summer. Furthermore, over the next several years, greater emphasis will be placed on the proper management of air emissions from livestock operations. As a result, pork producers see no diminishment in the need for conservation financial assistance, and the associated technical assistance delivery demands, from the 2007 Farm Bill relative to the 2002 bill. It is in this light that our comments are offered.
AVOID DISRUPTIVE CONSERVATION PROGRAM REFORMS
We strongly encourage Congress not to fundamentally overhaul USDA’s conservation financial assistance programs in the 2007 Farm Bill. We believe there is a practical limit to how many complicated and disruptive changes that the USDA’s Natural Resources Conservation Service (NRCS) can manage as we go from Farm Bill to Farm Bill. A tremendous quantity of NRCS’s staff time in the field and in headquarters is consumed by developing new policies and learning new programs’ delivery requirements that come from Farm Bill innovations. Such changes have been necessary and appropriately called for in the past, and the agency has had to cope with that as our set of conservation policies have been fundamentally reformed over the last 20 years. But there is no question that such changes can be highly disruptive and that in the process can interrupt the agency’s basic and important work of delivering conservation assistance to farmers. So every effort should be made to avoid creating such disruptions wherever possible.
Major reforms, for example, were initiated in the Environmental Quality Incentives Program (EQIP) in the 2002 Farm Bill. These were good reforms, and our testimony below will discuss details in this regard. But further fundamental reforms to EQIP in 2007 would simply throw the program into disarray for a few years, and that time will be lost to NRCS and us as the agency struggles to adapt. Starting in 1985, and in every Farm Bill since, we have fundamentally changed conservation financial assistance programs or added fundamentally new ones. The 2002 Farm Bill was perhaps the most significant in this regard in terms of complexity. In general, we are of the view that the operational demands placed on NRCS to implement these changes, in the field and in headquarters, have pushed the NRCS delivery system to the breaking point. This does not help farmers, it hurts them. We encourage you to keep this in mind as you consider reforms to the conservation title.
NPPC’s view on this matter should not be read as indicating pork producers are satisfied with how EQIP has performed for pork producers since the 2002 Farm Bill. Nothing could be further from the truth. Having received nationwide only about 3 percent of the total financial assistance funds made available by EQIP over the last few years, pork producers as a sector are deeply disappointed and very much want to see this situation turned around. Pork producers need EQIP’s assistance to help them move forward with their advanced manure management practices and know that the environment will be the big winner if this can occur. But pork producers are also of the view that this result can be achieved with only modest, non-disruptive changes to EQIP and the program rules. We present our ideas in this regard below. We need a better performing program that by and large can be achieved without fundamental legal or rulemaking reforms.
Furthermore, NPPC will always support efforts to make the administration of USDA’s conservation financial assistance programs simpler and easier wherever possible. This is because such changes could save taxpayer dollars and result in better program service for farmers. We will support legitimate and practical efforts to do this in the 2007 Farm Bill. But we caution Congress to think carefully about specific administrative reforms from the perspective of what it will do to NRCS’s ability to move immediately into the delivery of programs that today, with perhaps some modest changes, will be able to work well. It is very easy to underestimate how much time and effort it will take for agency staff to understand and implement administrative reforms. And it is not at all uncommon for so-called administrative reforms and reorganizations designed to create efficiencies and more “simplified” systems to result in even greater inefficiencies and complications and associated losses of staff time that could have been better used to deliver services under existing systems and organizations.
Our bottom line consideration is a request that the disruption to the conservation financial assistance programs be minimized as you proceed with the 2007 Farm Bill. We ask that practical, grounded consideration be given to the effects that changes Congress might institute in these programs, whether programmatic, policy, or administrative, could realistically have on the NRCS system’s ability to move promptly into delivering assistance to farmers shortly after the Farm Bill becomes law.
Substantial changes appear to be needed in the Conservation Security Program, or CSP, but what is probably needed here represents the exception that proves this rule. We discuss below the need to find ways for that program to be truly national in scope, simpler to operate, simpler and more transparent for producers to understand, all the while remaining within its overall budget constraint. A complete reinvention is not needed, though, and many of the program elements in existence today should allow you to create in a straightforward manner a simpler and more effective program. We fully understand how difficult this task is, and we do not have detailed recommendations as to a path forward to this end. We also know that such changes will require considerable work from NRCS to implement. But this common-sense call to minimize disruption is a good principle to keep in mind as you work on the CSP, too.
We believe that in the case of EQIP and the other conservation financial assistance programs, Congress has in place a good basic platform for the delivery of financial assistance from which NRCS and producers can operate. These programs can be fine tuned, and we offer some suggestions along these lines below. But major extensive additions or complications are not called for in these programs at this time.
NEW DIRECTION FOR CLEAN WATER ACT CAFO POLICY
Pork producers, along with others in the livestock and poultry sectors, called on Congress in 2002 to increase substantially the funds dedicated to EQIP. We were facing at that time the anticipated completion in 2003 of a Clean Water Act (CWA) National Pollution Discharge Elimination System (NPDES) rulemaking applicable to animal feeding operations (CAFOs). The 2003 CAFO rule was expected to establish unprecedented environmental requirements on CAFOs, including several thousand pork operations. We, along with the rest of the agricultural and conservation community, appreciated that Congress was able to increase the amount of funds in EQIP in 2002 with the purpose of helping producers comply with federal and state environmental requirements.
The final CAFO rule issued in 2003 did make many of the regulatory changes that had been anticipated, but its issuance was not the end of the policy development process. Subjected to legal challenges across the country after its issuance, all of which were consolidated in the U.S. Court of Appeals for the Second Circuit, the rule was fundamentally revised in two key areas by the court’s decision in the so-called Waterkeeper case. The court also reaffirmed a key exemption for CAFOs under the CWA. The Environmental Protection Agency (EPA) is now in the final stages of reissuing a CAFO rule to reflect the Waterkeeper decision, and that rule is expected later this summer or fall, just as the 2007 Farm Bill should be getting completed for implementation. The net result of these changes, in our view, is that pork producers, and the entire livestock and poultry sectors, need a well-funded and properly functioning EQIP now as much as they did in 2002.
First, the court said in Waterkeeper that only a CAFO that is discharging manure into waters
of the
The court also affirmed the CWA’s key agricultural stormwater exemption for which CAFOs appropriate land application practices would qualify. The court found that any CAFO that is using “appropriate” manure agronomic land application practices, along with “appropriate” soil and manure testing practices and “appropriate” record keeping, qualifies for the CWA’s agricultural stormwater exemption, and the runoff that may be occurring from this land does not constitute a point source discharge.
The overall result of the court’s decision has been to create a policy whereby CAFOs must avoid manure or waste water discharges from their animal production areas, and they must be properly applying manure to land they control. Not to do so will subject them, potentially, to substantial and costly penalties. But all of these water quality protections can be accomplished under Waterkeeper without the CAFO having to get an NPDES permit. NPPC is of the view that this is a strong and worthwhile development. Producers have strong incentive to properly manage their manure but can do so without having to go the further expense and difficulty of getting a federal NPDES permit and in the process also saving the taxpayer the not inconsequential cost of the regulatory agency having to manage and oversee that permit.
But the Waterkeeper decision did something else. High quality, well-performing manure containment and nutrient management practices are as important as they were in 2002, and for that CAFO deciding not to get an NPDES permit, maybe even more so. It was critically important that Congress add substantial new funding to EQIP in 2002, and in light of Waterkeeper and the revised CAFO rule to be issued, that funding must be preserved under the 2007 Farm Bill and continue to be available to producers seeking assistance with meeting their regulatory requirements.
IMPROVING EQIP’S
PERFORMANCE
As we noted above, while we do not think that fundamental policy or administrative reforms to EQIP are needed or desirable in the 2007 Farm Bill, this view should not be read as pork producers’ satisfaction with how EQIP has performed under the 2002 Farm Bill. We have testified several times before the House and the Senate over the last few years where we have documented the program’s failures with respect to pork producers, and we have offered our views as to why this has occurred. We refer you to that testimony for documentation of this record. NPPC also has appreciated the efforts of the leadership of NRCS to correct this situation over the last few years, and we believe that with some modest changes to the statute, EQIP should be able to provide a more reasonable level of assistance to pork operations.
Sustain EQIP’s funding level
It is imperative that EQIP’s funding not be eroded in the 2007 Farm Bill. As noted above, the evolving CWA regulatory program applicable to CAFOs means the $1.3 billion a year in EQIP’s baseline is needed now as much as in 2002. Furthermore, there is another significant environmental challenge that will soon be facing pork and other livestock and poultry farmers – compliance with the Clean Air Act and possibly with other federal statutes dealing with air emissions. EQIP must be available over the course of the 2007 Farm Bill to help producers adopt air emissions mitigation technologies and practices, and we offer specific suggestions below for how this can be assisted in the context of swine operations.
Furthermore, the period covered by the 2007 Farm Bill will be one where livestock producers will have significant opportunities to make positive contributions to the country’s efforts to develop greater renewable fuels supplies and to reduce or offset greenhouse gas emissions. Funds from EQIP can be of tremendous assistance in helping pork producers adopt advanced manure management practices to generate renewable fuels such as methane for firing boilers or driving electricity generation and in the process, to make a significant contribution to reducing overall greenhouse gas emissions. We also offer below specific thoughts on this subject.
The bottom line consideration, given all these needs and opportunities, is that we continue to be major supporters of EQIP and ask that Congress retain the funding in its baseline for EQIP purposes to help ensure these needs can be met.
Reemphasize
EQIP’s priority on regulatory assistance
The 2002 Farm Bill re-emphasized that one of EQIP’s top priorities is to help producers meet their pressing federal and state regulatory compliance needs. In light of the discussion above, the need for this emphasis has not diminished, and we ask that the Committee make a meaningful statement to this effect during the Farm Bill reauthorization.
EQIP’s current payment limitation is sound
The 2002 Farm Bill amended EQIP to create a payment limitation for the amount of assistance a producer could receive, limiting it to no more than $450,000 per producer from all EQIP contracts that the producer might hold. The Soil and Water Conservation Society (SWCS) and Environmental Defense recently jointly issued a report evaluating EQIP’s performance under the 2002 Farm Bill and noted that this payment limitation provision was opposed in some quarters and was the source of concern that it would skew EQIP’s financial assistance to larger producers. (See “Environmental Quality Incentives Program (EQIP) Program Assessment,” March 2007, by the Soil and Water Conservation Society and Environmental Defense). But as their report discusses, this has not occurred. The average size of an EQIP contract from 1997 to 2001 was almost $8,000, and since 2002 that has increased to almost $17,000. But this remains only 4 percent of the total amount of funds that would be allowed under the 2002 limitation. The SWCS and Environmental Defense report states that “raising the contract limit has not resulted in a significant shift in funding to a smaller number of much larger contracts.” (See EQIP Program Assessment, page 9). NPPC supports the current payment limitation and does not believe it needs modification in either direction.
EQIP’s current size-neutral orientation is sound
The 2002 Farm Bill also amended
EQIP to make it size-neutral when it came to operations seeking EQIP
assistance. The 1996 version of EQIP prohibited large livestock operations from
receiving financial assistance for structural, manure management facilities. The
2002 Farm Bill removed this prohibition. This entire matter has been among the
most contested issues in EQIP since the program was created in 1996. NPPC
argued for the removal of this provision in 2002 on the basis of the common
sense view that it fundamentally defeated EQIP’s environmental purpose by
ensuring that the vast majority of livestock producers managing the largest
proportion of the country’s manure were not eligible for manure management
assistance from EQIP. In light of this and the then-pending CAFO rule
requirements, which created a need to help commercial livestock and poultry
operations deal with the rule’s costs to prevent further consolidation in the
industry, this limitation needed to be removed. Congress made the decision to
do so.
The SWCS and Environmental Defense EQIP Program Assessment report discusses this matter. It notes, despite some data limitations, that “the data do suggest, however, that the majority of EQIP financial assistance is not going to practices and operations that were previously prohibited from receiving that assistance.” (See page 12). Pork producers believe that in their case the statement can be even stronger. As we can attest, and as the species specific EQIP data available from 2003 to 2005 clearly shows, pork producers both small and large in total only received about 3 percent of all EQIP financial assistance over that period. Large pork producers have clearly not been major recipients of EQIP assistance. NPPC believes that Congress must keep EQIP size-neutral if it is to be able to achieve its environmental goals and does not believe this provision needs any modification in the 2007 Farm Bill.
Livestock operations receiving 60 percent of EQIP funds
NPPC supports continuation of
the current policy in EQIP whereby 60 percent of the program funds are to
support the conservation and environment work of livestock producers. The fact
is that many of these producers use the EQIP funds they receive either in
support of better manure management in the context of their associated crop
fertility programs or for better forage and pasture management. Given livestock
producers enormous regulatory challenges, the use of our manure in context of
cropping operations and the foundation that we represent for the nation’s feed
grain producing sector, we believe the need remains for this provision, and we
support its continuance.
EQIP and wildlife
Pork producers support wildlife and wildlife habitat. Many of our producers take an active interest in promoting wildlife and wildlife habitat on their farms and in their communities. In this context, NPPC continues to support the use of USDA conservation financial assistance for wildlife habitat. At the same time, pork producers do not believe that wildlife purposes need to be incorporated into each and every conservation financial assistance program. Doing so in EQIP has created frustration and problems when producers find themselves competing against wildlife interests and producers seeking wildlife assistance from EQIP when a pork producer is seeking assistance with critical manure management issues to protect water or air quality. Certainly, as we discuss in greater detail below, in no instance should a pork producer’s EQIP application for manure management assistance ever be ranked alongside applications for wildlife assistance. We encourage Congress to consider making this explicit in the EQIP statute.
We also note that the SWCS and Environmental Defense report came to essentially the same conclusion with respect to ranking applications. We include here the summary statement (See page 2) in its entirety as it makes this point so clearly:
Many states rank diverse EQIP applications against each other, which
requires difficult “apples and oranges” comparisons. For example, it is very
difficult to compare an application proposing to implement a rotational grazing
system with another application proposing to apply integrated pest management,
or to compare an application proposing to protect at-risk species habitat with
an application proposing to construct a manure management facility.
Applications proposing to address the same resource concerns should be compared
to each other, and those applications that most effectively and efficiently
address that resource concern should be selected. NRCS state offices could
better accomplish their conservation goals by first allocating funds to
different resources of concern and then using different ranking systems
specifically designed to compare the relative effectiveness of applications in
addressing each individual resource concern.
EQIP must remain available to producers everywhere
NPPC believes that pork and all agriculture producers
facing conservation and environmental challenges need to have a fair and open
shot at receiving EQIP assistance. The 1996 EQIP’s emphasis on working in only
a limited number of geographic priority areas was one of the most unpopular
elements of that Farm Bill’s conservation title among producers and had to be
changed in 2002 if that program was to be able to continue, let alone grow
substantially. Under no circumstances does NPPC believe that current baseline
funds in EQIP now available across the
EQIP Conservation Innovation Grants should be continued
NPPC believes that the Conservation Innovations Grant (CIG) option in EQIP has been a very worthwhile programmatic innovation and that CIG should be continued under the 2007 Farm Bill reauthorization.
Some specific refinements to EQIP
As noted above, pork producers and NPPC are not satisfied with the extremely small amount of assistance provided to swine operations under EQIP since the 2002 Farm Bill. While this must change during the implementation of the 2007 Farm Bill, we believe that relatively modest refinements in the EQIP statute and regulations would permit the program to perform more fairly and reasonably. The particular modest changes to EQIP we are seeking follow below:
Pork producers’ experience with the EQIP application process to evaluate requests for conservation financial assistance is that it commonly undervalues and denies those applications from pork producers involving a limited number of practices with high environmental benefits. Pork producers have invested heavily in advanced manure management systems that involve both storage (and often times treatment) of their animals’ manure for several months, nutrient management planning and agronomic manure application practices. Under the Federal Clean Water Act (CWA) CAFO rule to be issued later in 2007, in conformance with the decisions of the Second Circuit Court, all swine CAFOs will need to have zero discharge from their production areas and use “appropriate” land application practices. CAFOs meeting these requirements will not have to get a federal CWA permit, and many will choose not to get a federal permit. But even if no federal permit is used, in essentially all of the major swine producing states, these operations are subject to a state water quality permit or requirements, where the state permit or requirements represent the comprehensive environmental and conservation management of the manure and land resources involved in the farming system.
Swine producers with these advanced manure management systems are at a considerable disadvantage when applying for EQIP funds. This is because they are commonly looking to EQIP to assist them with the adoption of one or a limited number of targeted practices that raise the intensity of manure management of their operations and are simply elevating even further the level of manure management performance of their system. In practice, such EQIP applications with a limited number of practices are given extremely low priority relative to applications for a larger number of practices, and subjecting them to a full blown EQIP application ranking and evaluation process is a poor use of federal resources and a source of considerable frustration for all involved. This means that swine producers, whose added practice or practices would add considerable environmental benefits on a dollar for dollar basis, are being penalized for the previous environmental and conservation investments on their farms, and the immediate and considerable environmental improvements that would have been possible are not attained;
Producers from an extremely diverse set of farming or ranching production
systems with extremely diverse conservation needs come to EQIP seeking
assistance. Each of the major categories of farming systems – specialty crop
producers, row crop producers, grass-fed or non-confined livestock or poultry
systems and animal feeding operations with animals in housing or confinement – are
highly unique in their conservation needs and circumstances and commonly
require very different types of assistance from EQIP. But in many states, the
process for selecting among applications for EQIP assistance from all of these
types of operations involves evaluating all of them together in a single pool
after attempting to rank them on the basis of their environmental and natural
resource benefits. This process unavoidably ends up creating an “apples and
oranges” evaluation system. These operations and their conservation needs
cannot be accurately evaluated and compared to each other, and the results are
rightfully perceived as confusing at best and unfair at the worst, despite the
best efforts of NRCS to be fair and accurate given the information available to
them.
This situation can be avoided to a great extent, if not completely, by creating at the state-level separate pools of EQIP applications representing comparable types of farming and ranching operations with conservation or environmental needs that are as comparable as possible. A pool of EQIP funds at the state level for animal feeding operations all seeking to improve their manure management systems to protect water and/or air quality can be evaluated as a group and selections made from among them. A similar pool can be created for grass-fed or non-confined livestock and poultry operations. A similar pool can be created for row crop operations and also a pool for specialty crop operations. Exactly how this could be best done will depend on the state, the production systems in that state and their conservation needs. But accuracy and transparency in NRCS’s application and evaluation process would result if states adopt this general approach of creating pools of comparable operations and needs.
The EQIP statutory language governing the EQIP application evaluation process is simple and straightforward. The Secretary is directed to create a process that gives a higher priority to assistance and payments that encourage the use of cost-effective conservation practices that address national conservation priorities. NPPC does not believe that this statutory language needs to be amended in that it provides adequate flexibility for the Secretary to create the evaluation process deemed needed. But NPPC requests that Congress express in report language the clear need for the Secretary to create a process at the state level where to the extent possible comparable types of farming or ranching operations with comparable environmental needs are ranked and evaluated, and that such an approach could include the use of separate funding pools intended for this purpose.
As stated above,
pork producers have invested heavily in advanced manure management systems.
Further, under the forthcoming CAFO rule, all swine CAFOs will need to have
zero discharge from their production areas and use “appropriate” land
application practices. CAFOs meeting these requirements will not have to get a
federal CWA permit, and many will choose not to get a federal permit. But even
if no federal permit is used, these operations are going to be subject to a
state water quality permit with requirements that represent the comprehensive
environmental and conservation management of the manure and land resources involved
in the farming system. Essentially, this state or federal permit constitutes
all of the elements of an EQIP plan as it relates to manure management on the
operation, and the EQIP statute should reflect this.
Consistent with the amendments made to EQIP in the 2002 Farm Bill, NRCS is now allowing EQIP participants to receive EQIP financial assistance funds to acquire from a TSP a CNMP. The financial assistance funds are limited by each state to reflect the costs of acquiring the CNMP from the TSP. But EQIP’s statutory authority does not allow for these financial assistance funds to be used by NRCS to contract directly with TSPs for the provision of CNMP development to multiple producers. As a result, some farmers may find that what is required of them in terms of paperwork, management and oversight of the TSP is so great that they do not want to get involved. Significant economies of scale and efficiencies would be possible if NRCS were also able to use these financial assistance funds to contract directly with TSPs so that a single TSP could develop CNMPs for multiple producers. The benefits would include:
1. Efficient NRCS quality control. Once NRCS knows in great detail and with certainty a particular TSP and who will be users on multiple projects for multiple farmers, NRCS really only needs to check closely the work product for the first few projects to ensure they are being done correctly. NRCS then reviews the remaining work products but can devote a much lower level of scrutiny. This saves NRCS time and money – and will save the producer time and money as well because fewer farmers will be waiting for NRCS approval before people are paid.
2. NRCS financial paperwork and accountability. While paperwork will be required of a TSP who is working on a set of projects under contract with NRCS, NRCS will be dealing with only one provider who will know and use properly the financial management systems with fewer errors and delays, and only one check will need to be cut. Audits of such work will only require an audit of one business relationship, not several.
Similar economies of scale are possible, in practice, when producers are choosing to work with a TSP or TSPs whose work quality is well known to NRCS. This is a matter of administrative practice that needs to be considered and evaluated by NRCS to ensure that all possible efficiencies and taxpayer savings are being realized. However, the bundled contracting approach and its possible taxpayer-benefiting efficiencies and the potential for reducing farmer hassle, are simply not possible under current EQIP law when it comes to use of EQIP financial assistance funds for TSP work.
Finally, farm biogas recovery systems at pork
production facilities have the potential to provide not only a cost-effective
source of clean, renewable energy that reduces greenhouse gas emissions but can
also have a significant impact in reducing the environmental footprint of a
swine CAFO. While EQIP funds are currently available for the installation of
anaerobic manure digesters, Congress should provide additional encouragement to
USDA to ensure that this support materializes.
CONSERVATION
SECURITY PROGRAM
A relatively small number of pork producers have sought to or have participated in the Conservation Security Program (CSP), and as such, it has not been a priority focus of NPPC. As a result, it is much more difficult for us to formulate the same kind of in-depth observations and suggestions for CSP as we have provided with respect to EQIP. At the same time, many of our most experienced conservation farmers in the pork producing sector have taken part in the program, or sought to do so, and we therefore do have some body of experience from which to offer you observations. Furthermore, we have heard from pork producers who might have sought to participate in the program or who tried to do so and did not qualify for one reason or another. We also recognize that Congress has made a serious commitment to adhering to pay-go budgeting and spending principles and that there is not a large sum of new money to be used to fundamentally amend or expand CSP. We understand, therefore, that significant challenges face Congress as it decides how to work with the CSP foundation to create a program that works for producers and is sustainable for years to come. Our limited observations as to what you should consider as you struggle with this are presented below.
First, we cannot emphasize enough the need to develop a program that is legitimately national in scope. It is very hard to create any type of real grassroots momentum for a program and its objectives if the grassroots has not significant, ongoing opportunity to participate. Second, we believe that the program must be made simpler for the agency to implement, simpler for farmers to understand and more transparent for all involved. In particular, we suggest that collapsing the current three tiers into two tiers would allow the program to continue to achieve its environmental objectives with a greater level of simplicity. Third, one way to make the program more practical and transparent to farmers and all involved is to ensure that CSP payments are closely tied to what it actually costs, or at least a best estimate of what it actually costs, for a producer to adopt or maintain the practices called for under the tier. Fourth, every effort must be made to create greater certainty and predictability to the application approval and contract funding process over the course of the program year. Determinations of a producer’s eligibility, notification of approval or disapproval to producer applicants and the disbursement of funds to contract holders during the program year need to be more predictable and timely.
INCREASING THE
CONSERVATION RESERVE PROGRAM’S EMPHASIS ON TARGETTED ENVIRONMENTAL BENEFITS
NPPC continues to support the Conservation Reserve Program (CRP) whenever it can be focused on retiring lands providing the highest environmental and conservation benefits. We believe that in most instances this means a focus on enrolling portions of fields, leaving the remainder available for feed and food production. As a result, we have significant concerns with the current CRP’s contract acreage, which remains overly concentrated on the retiring of entire fields and in many cases entire farms that could be productively involved in food, feed and fiber production while conserving the associated soil, water and even many of the wildlife habitat resources.
Our concerns in this regard are only exacerbated by the dramatic increases in demand for corn for grain ethanol, the large and record number of estimated corn acres to be planted this spring notwithstanding. We are only one significant drought or significant crop disease outbreak from a dramatic run-up in feed prices and serious feed shortages. It is for this reason that we support the Secretary’s recent decision not to hold further CRP signups at this time to replace any of the contract acres not being extended or reenrolled. We encourage Congress and the Secretary to ensure that there are no new signups to replace acres not being reenrolled or extended under current contracts until we get through the 2008 crop year.
Furthermore, we believe this Farm Bill should continue to provide the Secretary with the authority to allow early exit from the CRP without penalty, as this remains an important possible safeguard during this time of short supplies. We believe the Secretary may need to reconsider his recent decision not to offer such a penalty-free early exit for existing contract holders, and we ask the Committee to monitor the evolving supply and demand situation closely and, if appropriate, urge the Secretary to take a second look at this issue.
Finally, NPPC believes with others that to help the country meet its energy independence objectives, we must be able to create capacity to generate ethanol from cellulosic feedstocks. We support Congress’s efforts to determine if CRP contract holders should be allowed to harvest biomass crops such as switchgrass for energy production from CRP acres without loss of rental payments, taking environmental considerations into account.
CONCLUSION
The National Pork Producers Council and the many pork
producers we represent, thank you for holding this hearing and allowing us to
share the