Comments for Consideration in Rule Making

Title II - Conservation Programs

Sec. 2101, Conservation Reserve Program --

Points critical to Florida:
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.

Possible language to be considered in rule making
Here is some suggested language to be included in the definition of “prescribed grazing.”

Suggested language for the CREP procedures:

Harvest of herbaceous or woody vegetation through the use of prescribed grazing or mechanical harvest will be planned and implemented through an approved management plan to accomplish one or more of the following objectives:

1                 Control noxious weeds or exotic, invasive plants,

2                 Reduce the potential for wildfire due to the buildup of herbaceous vegetation,

3                 Alter the structure and/or composition of the vegetation to maintain or improve wildlife habitat,

4                 Increase the removal of nutrients from wetlands and/or lands immediately adjacent to wetlands,

5                 Reduce nutrient and sediment loads to surface waters by maintaining a stable and vigorous herbaceous plant community.

All vegetation management activities shall be based on an on-site evaluation of the vegetation will be consistent with Standards and Specifications developed by the USDA-Natural Resources Conservation Service for Prescribed Grazing (Code 528A) and Forage Harvest Management (Code 511).

Recommended definition of Prescribed Grazing:

Prescribed Grazing is the controlled harvest of vegetation by grazing or browsing animals to accomplish a specific purpose. Prescribed Grazing may be applied as part of an approved land management system to accomplish one or more of the following objectives:

1                 Control noxious weeds or exotic, invasive plants,

2                 Reduce the potential for wildfire due to the buildup of herbaceous vegetation,

3                 Alter the structure and/or composition of the vegetation to maintain or improve wildlife habitat,

4                 Increase the removal of nutrients from wetlands and/or lands immediately adjacent to wetlands,

5                 Reduce nutrient and sediment loads to surface waters by maintaining a stable and vigorous herbaceous plant community.

The prescribed stocking rate, time of grazing, and duration of grazing will be based on an on-site evaluation of the vegetation and level of treatment need to accomplish the objectives.

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