WAWG
By Keva Herron Guszkowski
WAWG Policy Director
The Conservation Reserve Program (CRP) is important to many wheat farmers because it helps them address natural resource concerns, such as water and air quality, soil erosion, energy efficiency, sustainable agriculture, wildlife habitat preservation and emergency response for natural disasters. CRP is administered by the U.S. Department of Agriculture’s (USDA) Farm Service Agency (FSA). Technical assistance for CRP is administered by the Natural Resources Conservation Service (NRCS). As part of the 2014 Farm Bill, USDA was required to make changes to CRP. The new rules went into effect in September 2015.
As part of our mission of informing and educating our members, the Washington Association of Wheat Growers has detailed some of those changes and the concerns we have with them and CRP in general.
• The 2014 Farm Bill reduces CRP’s enrollment ceiling from 32 million acres to 24 million acres by FY2018, meaning fewer farmers will have the ability to use the program as part of their working farm. CRP has reduced an estimated 8 billion tons of soil erosion since the program’s inception in 1986. FSA estimates annual conservation benefits include a 52 million metric ton net reduction in carbon dioxide from sequestration. As of FY2014, 25.45 million acres were enrolled in CRP. 
• The explicit opportunity costs of a producer to enroll land into CRP are, in many instances, too high relative to keeping the land in agricultural production. The annual rental payment limitation cap needs to be raised or removed to more aptly compensate producers for their conservation efforts. Presently, rental payments and incentives earned by the producer in excess of the cap must be forfeited.
• The amount of cropland that is allowed in a state Conservation Priority Area (CPA) has been reduced from 33 percent to 25 percent. CRP Grasslands Initiative and State Acres for Wildlife Enhancement (SAFE) initiative enrolled acres will count against the state CPA cap. Washington state’s CPA is specific to air quality. WAWG is concerned that the state CPA reduction will have a disproportionate impact on air quality relative to wildlife habitat acreage in Washington. The Sage Grouse SAFE needs to be exempted from counting against both the state CPA area zone and acre totals, and the area of the air quality CPA needs to be reduced to be exclusive of the Grouse SAFE.
• CRP rules don’t provide farmers a way to re-align continuous and general CRP contract length, which will allow a grower to put the entire field back into production at once. In the new rule, there will be penalty-free, early contract termination opportunities for FY2015 for contracts in effect for 5+ years and that meet certain criteria. Unfortunately, re-enrollments, extensions, transfers and terminations are often only eligible to certain types of contracts, and this can present a problem when a producer decides to take a field out of CRP and put it back into production. For example, the majority of a field is usually enrolled through general CRP, but any filter strips and buffers in that field are enrolled through continuous CRP. If an optional extension is offered for the general CRP acres, but not on the continuous ones, it means that part of that field goes back into production before the rest of it does. This misalignment in contract length is more than inconvenient. Often farmers will farm steep, narrow strips of land for a number of years waiting for the remainder of the field to come out of contract because the financial loss to not farm that land with no CRP revenue is too great.
• Washington state does not have buffer requirements, and WAWG recommends that buffers continue to be a voluntary conservation measure. The rule clarifies that state, local or tribal laws which require environmental measures (such as riparian buffers) to be taken on land is ineligible for enrollment into CRP.
• CRP Pollinator Habitat has not been very successful in Washington. Producers have had difficulty in meeting stand requirements. Restrictions need to be loosened and seed cost share rates need to be increased if such expensive seed is required.
• Transition Incentives Program (TIP) funds are utilized by our growers but run out quickly, indicating a clear need for more funding. TIP was reauthorized, and veteran farmers and ranchers are now also eligible for this program.
Other CRP rule changes are:
• AGI limitation has been reduced from $1 million to $900,000. The prior waiver for the AGI limit was not reauthorized in 2014.
• Up to $10 million is allocated for incentive payments for tree thinning and other measures to improve performance of CRP tree plantings.
• CRP participants can make certain conservation and land improvements for economic use in the final year of the CRP contract that facilitate protection of enrolled land after contract expiration.
• The provisions for managed harvesting and other commercial use was amended to reflect a payment reduction of not less than 25 percent and the limitation that the activity occur at least every 5 years but not more than once every 3 years.
• The 2014 Farm Bill removes payment reduction for emergency haying, emergency grazing or other commercial use of the forage on the land in response to drought, flooding or other emergency.