December 23, 2014
On Tuesday, December 23, the U.S. Department of Agriculture’s Farm Service Agency (FSA) published a Final Supplemental Programmatic Environmental Impact Statement (SPEIS) examining the changes made to the Conservation Reserve Program (CRP) through the 2014 Farm Bill.
FSA will accept public comments on the final SPEIS through February 15, 2015.
NSAC submitted comments on the Draft SPEIS in September, calling for greater analysis around implementation of a two million acre grassland enrollment option. We also expressed concerns that FSA’s proposed “reverse auction” strategy for targeting enrollment overemphasizes cost while underemphasizing environmental benefits. For a closer look at the Draft SPEIS and our comments, read our analysis from this summer.
Throughout the public comment period, FSA received 18 comments addressing 75 individual issues. The issues most commonly noted among commenters were emergency haying and grazing, grassland and targeted enrollment, and managed harvesting/routine grazing frequencies.
Changes Not Addressed
The final SPEIS notes 15 changes made to CRP through the 2014 Farm Bill, including everything from changes in maximum enrollment authority to funding for the Transition Incentive Program (CRP-TIP). Of the 15 changes, eight were not included in the SPEIS—either because the agency determined they lacked an environmental impact or because they were addressed in a previous EIS. Those changes were:
Changes Addressed by the Final SPEIS
For the most part, the final SPEIS assesses the same alternatives as the draft, including provisions allowing for final contract year enrollments in other conservation programs like the Conservation Stewardship Program (CSP) and the Agricultural Conservation Easement Program (ACEP). However, to some extent, FSA did respond to NSAC’s comments regarding grassland enrollments and the reverse auction alternative action.
Grasslands – In our comments on the draft SPEIS, we argued that, given the limited number of grassland acres available within CRP, the SPEIS should assess the environmental impacts of a variety of implementation options, including targeting enrollment to expiring CRP lands, certain landscapes, or at-risk species.
The final SPEIS notes that FSA is in the process of developing ranking criteria for the 2 million acre grassland reservation; beyond noting, however, it does not provide any analysis of the potential environmental impacts of targeting or not targeting certain acres. The potential ranking criteria include:
One criterion that is strikingly absent from this list is whether the land is native prairie. Given that so little native grass remains in the U.S., we strongly believe that these acres should be targeted for enrollment along with expiring CRP acres.
Reverse Auction – The final SPEIS includes significantly greater detail around the proposed targeted enrollment strategy. The agency is proposing a method of targeting enrollment of specific practices or land types through a “reverse auction” where FSA could select contracts of similar environmental benefit based on cost.
In our comments on the draft SPEIS, we argued that by focusing on cost, a reverse auction would exclude critical EBI factors, such as wildlife habitat benefits resulting from increased cover, water quality benefits resulting from reduced erosion, runoff, and leaching. We urged FSA to examine an alternative scenario under which there is no reverse auction—but instead the Environmental Benefits Index (EBI) cost factor is weighted close to one half of total points. This option, we argued, would have the same general effect as a reverse auction (getting more bang for the buck) without completely discounting all of the other factors in the EBI, which FSA uses to assess general sign-up bids for CRP enrollment.
Unfortunately, the final SPEIS does not assess this alternative scenario. Instead, it includes the following descriptions of key features of the same targeted enrollment strategy as well as more examples of where similar strategies have been employed in other conservation programs:
FSA would work with the STC and other Federal, regional, state, and local partners to determine practices or lands that could be targeted to address local, regional, or national resource concerns through this enrollment process. While the reverse auction appears to hold considerable promise for CRP, FSA would safely implement the reverse auction on a small scale as a proof-of-concept pilot to determine its effectiveness and applicability to the future of CRP. Appendix F provides a simulation of a potential reverse auction for CRP. Utilizing a reverse auction approach for targeted enrollment would have the following key features:
- A specific enrollment period would be defined annually; one sign-up and offer selection period with clearly defined eligibility requirements, anticipated conservation goal, and enrollment target.
- The specific conservation goal, initiative, geographic or otherwise targeted areas would be determined by FSA with input from national, regional, state, or local partners, providing flexibility to meet a variety of conservation goals.
- Eligible participants submit offers that include the desired, eligible practice and bid amount, which is unconstrained by a cap to encourage enrollment.
- When environmental other benefits can be treated as constant across offers, offers can be selected on the basis of cost. As necessary and feasible, selection can consider benefits as well. Either way, program benefits per dollar spent could be maximized.
Emergency Haying and Grazing Payment Reductions – The 2014 Farm Bill eliminates the payment reduction requirement for haying or grazing on CRP acres during specific severe drought conditions or other natural disasters. This elimination of payment reductions did not receive analysis in the draft SPEIS, but was included in the final document, largely in response to comments from the U.S. Fish and Wildlife Service (FWS). The final SPEIS concludes that “no significant cumulative impacts would be expected from removing the payment reduction for emergency haying and grazing. Emergency haying and grazing is only authorized under severe drought conditions. Several restrictions and stipulations for emergency haying and grazing are in place to provide protection and long-term viability of the cover to include requiring the producer to replace CRP cover that is lost due to emergency haying and grazing activities.”
FSA will accept comments throughout a 45-day waiting period before issuing a Record of Decision (ROD). Individuals and organizations can submit comments through February 15, 2015 on the regulations.gov comment portal.