|
Letter of Transmittal:
Click here for the August
21, 2002 Letter of Transmittal to USDA Secretary Ann M. Veneman
Click here for Press Release that
went to state agencies, farm bureaus and cattlemen associations
Click
here to read comments submitted by
Stewardship America
on the interim rule for Technical Service Provider Assistance
These documents are in PDF format and require
Adobe Acrobat Reader (which you can
download for free)
Comments on Title II
Conservation Programs:
Sec. 2001, Conservation
Security Program --
| Since rule making for
this program has yet to begin, comments on this
program will be provided in a separate letter at a later date. |
Sec. 2003, Partnerships and
Cooperation --
| A very important
program to Florida producers. Provides an opportunity to
implement the Farmland Stewardship Program, which was originally introduced
by Rep. Adam Putnam (R-FL) last July as HR 2542. Can be used to
address many of the issues raised in GAO Report #02-295,
"Agricultural Conservation - State Advisory Committees’
Views on How USDA Programs Could Better Address Environmental
Concerns."
For more details, please visit
the following links:
|
Sec. 2005, Reform and
Assessment of Conservation Programs --
| Also important to
Florida producers. Comments and links that apply to documents
for Sec. 2003, Partnerships and Cooperation, above, also apply
here. |
Sec. 2101, Conservation
Reserve Program --
| There are 3 points critical to
Florida. (For more details on each, please see the links
below.)
1.
Definition of "marginal grazing land."
Need to be sure the type of pastureland we have in Florida is
eligible and not excluded (in CRP, CREP, EQIP, Grassland
Reserve, etc.)
2. Rulemaking/policies on "managed grazing" (especially
in CRP and CREP, but also in EQIP). Suggest that this be
referred to as "prescribed grazing." Need
to be sure that the types of grazing that occur in Florida are
acknowledged and accommodated. We graze because it
achieves specific objectives. For example, we often use
grazing as a means of controlling invasive species and reducing
fuel loading. Grazing
also is used to improve or maintain wildlife habitat, maintain a
stable herbaceous plant community, facilitate nutrient export,
and slow the flow of water across the landscape, thereby
reducing or slowing the amount of sediment or nutrient into
surface waters.
If rental payments are reduced because of these types of
grazing, there will be no incentive for an owner/operator to
participate in the program.
Need
to stress that so long as the haying or grazing is part of an
approved management plan for exotic plant control, fire fuel
suppression, or other management purposes, there will not be a reduction in payments.
Our point is that prescribed grazing is an important management tool
that can
offer a cost reduction or cost avoidance in the management of
lands.
So
long as these activities have been identified as a component in
an approved management plan, there should not be a reduction in
rate payment or such reduction should be as small as possible.
Please see
links to specific language to be considered in rule making, below.
3. Increased flexibility.
Need to be sure statutory language included under
Sec. 2101, Conservation Reserve Program, in—
Sec.
1231(b)(4)(B);
Sec. 1231(b)(4)(C);
Sec. 1231(b)(4)(E);
Sec. 1231(c);
Sec. 1231 (g);
Sec. 1231(h)(2)(A)(i);
Sec. 1231(h)(3);
Sec. 1232(a)(1) and (4); and
Sec. 1232(a)(7)(A)(i),
is
interpreted through the rule making process to:
-
allow
fuller use of the CRP in all states (and especially
Florida);
-
ensure
landowners are encouraged and rewarded for maintaining land
in uses to improve water quality and provide habitat for
important plant and animal species;
-
ensure
landowners are able to properly manage enrolled land to
prevent the encroachment of invasive species;
-
ensure
landowners can qualify for the program by broadening the
eligibility criteria for what constitutes a "planted
agricultural commodity" to include multi-year grasses
and legumes and conservation uses of land; and
-
as
a result of these new criteria, ensure the program minimizes
"unintended consequences" to prevent abuses under
the old criteria whereby tracts of native lands previously
were converted to agricultural uses solely so the landowner
could qualify for the program.
|
Sec. 2201-2203, Wetlands Reserve Program --
| With the final rule
published, we look forward to increased funding over the next
seven years for this valuable program, which Florida intends to
use extensively.
We hope OMB will expedite its
approval of the USDA proposal for FY02 funding -- INCLUDING
ALL NECESSARY TECHNICAL ASSISTANCE FUNDING -- so NRCS can
begin processing applications and initiate as many projects as
possible prior to the November elections, so that the
Administration can point to immediate and positive results from
the Farm Bill (and use this to obtain good publicity from the
media for the Farm Bill).
|
Sec. 2301, Environmental Quality Incentives
Program --
|
The Environmental Quality
Incentives Program (EQIP) is one of the primary federal cost share
programs that Florida producers can utilize.
EQIP is particularly
valuable because it provides a combination of technical, financial and
educational assistance to landowners to address various natural resource
concerns.
Again, there are 3 points critical to
Florida. (For more details, please see the links below.)
1. Definition of
"marginal grazing land." Need to be sure the type of
pastureland we have in Florida is eligible and not excluded (in CRP, CREP,
EQIP, Grassland Reserve, etc. To view proposed language to be
included in definition, click here).
2. Rulemaking/policies on "managed grazing" (especially
in CRP and CREP, but also in EQIP). Suggest that this be
referred to as "prescribed grazing." Need to be
sure that the types of grazing that occur in Florida are acknowledged and
accommodated. We graze because it achieves specific objectives.
For example, we often use grazing as a means of controlling invasive
species and reducing fuel loading.
Grazing also is used to improve or maintain wildlife
habitat, maintain a stable herbaceous plant community, facilitate nutrient
export, and slow the flow of water across the landscape, thereby reducing
or slowing the amount of sediment or nutrient into surface waters. If rental payments are reduced because of this
type of grazing, there will be no incentive for an owner/operator to
participate in the program. Grazing
should be an approved method of controlling invasives,
reducing of fuel loading,
and
maintaining wildlife habitat under EQIP.
(To view proposed language for included practices,
click here).
3.
Need to ensure credit/acknowledgement is received in program applications
for installed practices and expenditures already made and that these
practices/expenditures can be transferred from one program to another.
This applies
not only to EQIP, but to other USDA conservation programs as well. Please
see link to "conservation parity payment" under points to be considered in rule making, below.
|
Sec. 1240H, under Sec. 2301, Conservation
Innovation Grants --
|
One
of the stumbling blocks to encouraging more owners/operators to
participate in conservation programs, and in taking initiatives to enroll
owners/operators in programs across an entire region is the lack of
pre-application funding to assist owners/operators in getting program
information, deciding which programs or combination of programs will work
for them and providing support through the information-gathering,
application and negotiation phases.
These
grants could be extremely valuable in helping initiate projects, filling
in gaps in technical assistance funding when producers are applying for
more than one program, and providing pre-agreement funds for working with
landowners on applications and "program assembly," that could
facilitate development and use of the stewardship agreements described in
Sec. 2003, "Partnerships and Cooperation."
|
Sec. 1240I, under Sec. 2301, Ground and
Surface Water Conservation Program --
Sec. 2401, Grassland Reserve Program --
|
Language
was included in the Grassland Reserve Program to ensure Florida
producers would qualify by specifying that:
- existing
habitats for important plant and animal species can be retained
-- and not replaced in order to qualify for the program;
- the
program applies to all areas of the country; and
- existing
plant and wildlife habitats can be protected through the
program, when theses habitats support important species, even if
the current grasses and shrubs are not the original native
species. A purely technical interpretation of "natural
grass and shrublands" or "natural grasslands," as
originally described in the House and Senate versions of the
Farm Bill, would have disqualified many ranch operations in the
U.S., even though many operations currently provide habitat for
a large number of threatened and endangered species. This is
because older grasses that had lower nutritional values have
been replaced in many cases by newer, more nutritional grasses
and legumes that now support large, very diverse populations of
livestock, deer and other wildlife.
We wish to ensure that the rules for
Grassland Reserve Program reflect these three objectives.
Again, we need to be sure that the type of pastureland we have in Florida is
eligible and not excluded, and the types of grazing that
occur in Florida are acknowledged and accommodated.
|
Sec. 1240M, under Sec. 2502, Conservation of
Private Grazing Land Program --
Sec. 1240N, under Sec. 2502, Wildlife Habitat
Incentives Program --
|
Language was
included in the Wildlife Habitat Incentives Program that allows the
Secretary of Agriculture to enter into agreements of 15 years or longer to
provide payments to landowners who are willing to maintain, manage and, if
necessary, improve existing habitats that support important plant and
animal species.
This
provision is of great interest to many Florida producers whose land
holdings included habitats for listed species and who are interested in
managing these habitats in a manner consistent with their conservation
purposes, and
would like to have the opportunity to enter into
long-term (but not permanent) contracts to obtain compensation for
practices carried out to maintain this habitat, and to provide a revenue
stream for this land, in return for not converting it to another more
traditional farm use that would generate revenues.
For the most part, these landowners do not want to sell their land to the government or place it under permanent conservation easements, and are not interested dealing with the
complexities (and expense) involved in working with the U.S. Fish and
Wildlife Services in developing a Habitat Conservation Plan.
Hence, this provision in WHIP offers another valuable "tool" for
expanding conservation on private lands, and provides another option to
owners/operators that will fit situations and needs that are not addressed
in other programs.
|
Sec. 2503, Farmland Protection Program
--
|
The best way to protect farming is to make it
profitable. Rep. Putnam's office, the Florida Congressional delegation and
Florida's producers are committed to working in any way they can with the
USDA to improve opportunities for profitability for agricultural producers
so they can be economically strong, regionally diverse and globally
competitive.
We support programs that provide funding to
willing landowners who wish to place permanent conservation easements on
their property in return for fair compensation. We do not think
these programs will protect farming, but we believe they are good public
policy, and will result in retaining pastoral landscapes that provide open
space, wildlife habitats and other environmental and social values.
The Florida Legislature has approved a
program to act as a companion to the Farmland Protection Program (which
includes permanent easements, 30-year easements and funds for "stewardship
agreements"). Funding for this program is proposed to be $100
million a year for 10 years, or a total of $1 billion.
We hope to make good use of the Farmland
Protection Program to complement our state program. It is an
important tool for those who wish to participate.
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Other Comments
|
Third
Party Technical Assistance.
If all the
planning is done by a 3rd party, does the cost for this technical
assistance count toward the program caps that limit how much each
owner/operator can receive under each conservation program? Or does
technical assistance (by NRCS or by 3rd party) come out of the technical
assistance funds that are earmarked for each program?
Need
clarification on how 3rd party technical assistance will work and
how different groups in Florida -- soil and water conservation
districts, Department of Agriculture and Consumer Services and water
management district staff, producer groups such as Florida
Cattlemen's Association, private groups such as Glades Crop Care and local land trusts, and individuals
who work under contract with private landowners -- will be
compensated for the work that they perform on behalf of a landowner,
and what certification will be required.
These
costs should fall under the Technical Assistance earmarked.
At present the certification process is open but not being
used much according to Florida’s State Conservationist, Niles
Glasgow.
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Thank you for taking the time to
review these comments and to take them
into consideration.
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