* establishes soil quality as national environmental goal on
equal footing with air and water (where have we heard that before;
* "strive to achieve nondegradation of soil, water, and other
natural resources by the year 2010"
* a new "No sodbusting" compliance provision imposed on any
producer enrolling land in ACRP [yes, "No sodbusting" period, does not
allow sodbusting with a plan]
* authorizes payments for base retirement, which could allow Sec.
to accept higher bids for producers willing to permanently retire base
[this may need some more thought, could get costly and for no reason]
* lets a farmer protect base history after contratcs expire as
long as land stays in permanent cover
* good bidding procedures; NO caps/cups on re-enrollment payment rates
* there is a new "Environmental credits" provision, which is
unclear, but a new provision says that farmers do not have to pay income
tax on payments received under this title!! [oh great, Ways and Means
* when a farmer loses money through compliance, the funds get
transfered to the CIP fund, and held for 1 year while grower tries to get
into compliance, and if they do, they get some/all of the money.
The ACRP (CRP+WRP) provisions are generally good and fully in
accord with AFT, Cam. for Sus Ag and other conservation org.
recommendations, with some exceptions. The bill does not
mention EI>8 as an eligibility requirement, and should add it. It opens
up enrollments expansively to pasture and range, hardwood trees, riparian
areas, wetlands, sensitive lands, etc, so the need for adherence to the
EBI for targeting will be critical, as will exercising some discipline in
administration to avoid souring the mood of the country when thousands
try to get into the program but find the money lacking for new
Three provisions open the ACRP to land devoted to living snow
fences, and PERMANENT filterstrips contiguous to water bodies/streams, and
grassed waterways/shelterbelts. One wonders what this means; would
bidders have to accept permanent easements when enrolling these lands?
These are also the lands that would quality for 110% of county average
rental rates if enrolled via partial fields. A thought -- maybe a new
provision could be added for these sensitive parts of the landscape
enrollments -- get payments for 10 years, leave in the practices for 30.
The BEST provisions are the funding --
* ALL conservation programs funded from CCC
* S. 854 levels (plus some) and mechanism whereas when ACRP
dollars go down, cost-share money goes up, holding total assured spending
at $2.15 billion through 2005!!
And the bill imposes a hard cap on conservation spending, AND
authorizes Sec. to reduce ALL payments through the title by a proportional
amount in a year when total commitments exceed total funds available,
just as conservation/environmental groups are arguing in reference to
commodity program payments.
Several issues are either worrisome or disappointing --
* the nondegradation goal includes a clause, "where feasible",
opening the door to some degradation. Like national wetlands policy,
perhaps an option is to adopt a "no net degradation" policy, whereby a building
permit authority, road builder, conservation office, etc, that sanctions
degradation somehow extracts as a cost a pledge to improve soil quality
elsewhere by a comparable amount, or pay into a fund administered to
restore degraded lands, or whatever. This extends the transferable
development rights concept to soil quality.
* in ACRP, land is eligible for enrollment to protect soil quality
if "best economically attainable conservation systems" are not able to
reduce erosion "significantly", which is not defined. This sort of vague
provision is a problem, has been since 1985. An alternative is needed,
like the economic cost per ton of soil erosion avoided criterion that
has been floating around for almost 10 years. Would work this way; USDA
calculates cost per ton of erosion reduction to get from where farmer is
to 2T and to 1T; if the cost per ton from 2T to 1T is twice what it cost
to get the farmer to 2T, then the farmer can go to just 2T.
* no haying and grazing; and no provision to recover part of rental
payment in years when emergencies are declared and livestock producers are
bailed out by getting access to ACRP land.
The bill also consolidates all the cost-share programs, and sets
up the foundation. The functions/roles and partnership-arrangements are
not adequately set forth; there is no discussion of federal-state
cost-sharing, although such an outcome could happen, given the open-ended
Post-veto, both the House and the Senate will have time to
consider weaving additional conservation title reforms into round II of
the reconcialiation package. Some of the worthy provisions in this USDA
bill might find their way into the package; or alternatively, this bill
in its entirety will serve as the basis for an alternative to the
Dole/Allard conservation bills which not even a mother could love.