July 18, 2014
On Tuesday, July 15, 2014, the U.S. Department of Agriculture’s Farm Service Agency (FSA) released its Draft Supplemental Programmatic Environmental Impact Statement (SPEIS) for Conservation Reserve Program (CRP). The draft SPEIS seeks to assess the ways in which changes made to CRP in the 2014 Farm Bill will impact vegetation, wildlife, protected species, soils, surface water, groundwater, floodplains, wetlands, air quality, recreation, and socioeconomics.
In order to assess impacts, FSA chose to focus on three hypothetical changes that FSA could choose to make. The draft SPEIS refers to these options as “Proposed Action Alternatives”:
The targeted reverse auction enrollment option was not specified by the 2014 Farm Bill. The proposed action alternative, if selected, would make it a new third type of CRP enrollment option, alongside the current general sign-up and continuous sign-up options. The SPEIS indicates the proposed targeted reverse auction option would supplemental, not replace, the traditional general sign-up, though it also indicates there would be an annual enrollment period under the reverse auction option, something that is not guaranteed under the general sign-up option.
The SPEIS also assesses the impacts of two CRP provisions from the 2014 Farm Bill. These two provisions, which the draft SPEIS referes to as “No Action Alternatives,” are:
NSAC fought for both policy provisions during the 2014 Farm Bill debate as a way to retain conservation values on the millions of acres expiring from CRP. NSAC also supported the liberalized rules for managed grazing within CRP.
No Action Alternatives
Unfortunately, the SPEIS does not examine any alternative scenarios for implementation of the grassland reservation, despite the fact that the Farm Bill gives FSA significant discretion in how to administer the provision. USDA writes:
Many elements of the 2014 Farm Bill are mandatory and therefore, non-discretionary or specifically required to be implemented. As FSA has no decision-making authority over those non-discretionary provisions of the 2014 Farm Bill, they are specified and assessed in the Draft SPEIS as part of the No Action Alternative.
It is true that FSA is required by law to implement the grassland reservation; and it is also true that land eligibility provisions for the grassland reservation are the same as those previously defined for the Grassland Reserve Program (GRP). However, many important details are left to the Agency to decide. For example, the Farm Bill authorizes, but does not mandate, that USDA prioritize acres that are expiring from CRP. Would the environmental impact of the grassland reservation be the same whether or not FSA prioritized expiring CRP acres for enrollment? Similarly, the SPEIS leaves out any discussion of geographic scope. What would the environmental impacts of a geographically targeted grassland enrollment be versus a nationwide grassland enrollment? Nor does it address whether or not to target at-risk acres, or whether targeted acres should be the same or different than acres targeted for grassland easements under the Agriculture Conservation Easement Program.
With just two million acres eligible to be enrolled out of over 500 million acres of privately held grasslands nationwide, these are very important environmental impact questions, not to mention critical cost-benefit questions. In submitting formal comments on the draft SPEIS, NSAC will recommend that FSA examine possible alternative actions related to the grassland acreage reservation, including the option of enrolling only expiring CRP acres.
As far as baseline environmental impacts go, the assessment finds that both the new grassland acreage reservation and the option to enroll in CSP and ACEP will convey multiple conservation benefits in the long-term. Grassland-dependent wildlife and protected species, “especially in the Great Plains Ecoregion would receive long-term benefits from habitat conservation,” the assessment states. By keeping land covered, the grassland reservation will limit soil erosion and therefore improve the soil resource.
Across all resource concerns, the CRP-to-CSP or ACEP transition option will convey long-term benefits “by allowing acreage to remain in conservation and not development.” Both provisions will have long-term positive impacts on surface water, groundwater, wetlands, and floodplains by reducing erosion and the transport of farm pollutants, maintaining or increasing permeability by preventing development, and decreasing water use relative to land not enrolled in a conservation program. The assessment concludes that both the grassland reservation and the CRP final-year transition option will “continue greenhouse gas (GHG) emissions reduction through carbon sequestration.” While the grassland acreage reservation will not have an appreciable impact on socioeconomics, the final-year transition option “reduces the risk to the contract holder,” “prevents the likelihood of agricultural conversion,” and will “have long-term benefits to the socioeconomics of the local area.”
Proposed Action Alternatives
The assessment defines the reverse auction option as targeting the enrollment of specific conservation practices and specific types of eligible land to meet specific environmental goals and maximize environmental benefit, so it is not surprising that the evaluation finds that a reverse auction would benefit all resources of concern and improve environmental outcomes. Under a reverse auction, all bids would be grouped according to which conservation practice(s) would be pursued, and then selection would be made solely or primarily based on cost, with the low bidders winning. Cost is currently a factor within the Environmental Benefit Index (EBI) used to assess general sign-up bids, but cost is a relatively low percentage of the total available EBI ranking points. Cost would be primary in a reverse auction. The SPEIS does not look at the alternative option of substantially increasing the weighting given to the cost factor within the EBI.
Easing restrictions on managed harvesting and routine grazing on CRP land would have some negative impacts and some positive impacts, according to the assessment. It may reduce vegetation growth, increase soil compaction and erosion, and harm ground-nesting birds and other wildlife, but could better maintain early successional grasslands and improved plant diversity and function in the long term. Finally, the draft SPEIS examines the potential environmental impacts of allowing emergency haying and grazing on grassed waterways, filter strips, riparian buffers, wetland restorations, rare and declining habitats and other types of wetlands and habitats. The assessment finds that consecutive years of haying and grazing could have long-term negative impacts on vegetation, wetlands, and riparian areas, as well as short-term negative impacts on wildlife, soil quality and quantity, and “the ability of conservation cover to sequester carbon through loss of living biomass.”
The draft SPEIS does not examine the potential impacts of a variety of other Farm Bill changes, including: a reduction in the acreage enrollment cap, enrollment changes to the CRP Farmable Wetland Program, changes to tree thinning payments, changes to rules on early termination of contracts, payment reductions for managed harvesting and grazing, the funding increase for the CRP Transition Incentives Program, and new language clarifying that prescribed grazing is allowable to control invasive plants, so long as such grazing occurs in consultation with State Technical Committees.