August 17, 2018

The Honorable Michael Conaway
House Committee on Agriculture
1301 Longworth House Office Building
Washington, DC 20515

The Honorable Collin Peterson
Ranking Member
House Committee on Agriculture
1305 Longworth House Office Building
Washington, DC 20515

CC: 2018 Farm Bill Conferees

The Honorable Pat Roberts
Senate Agriculture, Nutrition, and Forestry Committee
328A Russell Senate Office Building
Washington, DC 20510

The Honorable Debbie Stabenow
Ranking Member
Senate Agriculture, Nutrition, and Forestry Committee
328A Russell Senate Office Building
Washington, DC 20510

Dear Chairman Conaway, Chairman Roberts, Ranking Member Peterson and Ranking Member Stabenow:

The National Wildlife Federation, on behalf of our over six million members and supporters, along with the undersigned 37 state affiliates, thank you for your tireless work to move forward a new Farm Bill this year. As you and other members of the Farm Bill Conference Committee work to find compromise on a final 2018 Farm Bill, we urge you to craft a final Farm Bill with full conservation funding and strong provisions for soil, water, grasslands, wetlands, and wildlife.

We wanted to share with you our recommendations for a wildlife-friendly final Farm Bill, including a detailed set of programmatic recommendations (attached). In addition, our top-level, high priority recommendations include:

• Conservation Funding: With conservation programs hugely oversubscribed and the need for conservation greater than ever, it is critical that funding for the conservation title not be cut. We urge you to maintain or increase baseline conservation funding for this and future farm bills.
• Wildlife Funding: When the 2014 Farm Bill combined the Wildlife Habitat Incentives Program into the Environmental Quality Incentives Program (EQIP), the net result was a decrease in funding going towards practices that create wildlife habitat. We urge you to increase the minimum amount of funds within the Environmental Quality Incentives Program required to be used for wildlife habitat conservation practices annually from 5 percent to 10 percent.
• Sodsaver: America’s grasslands are disappearing at a rapid rate, and with them, the wildlife that depend on grasslands. The 2014 Farm Bill took an important step forward with the creation of a 6-state Sodsaver provision to help reduce grassland loss by decreasing premium subsidies for native grassland that is converted to cropland. We urge you to strengthen this provision by closing an existing loophole and expanding the provision beyond the six states – either by adding other states, or at a minimum, giving governors the authority to opt in.
• Conservation Reserve Program: The Conservation Reserve Program (CRP) is one of the most important conservation programs for soil, water, and wildlife, yet acreage in the program was cut by 15 million acres over the last two Farm Bills. While it is important this Farm Bill increase acreage in the program if possible, the increase must not come at the expense of the quality of the program.
• Crop Insurance: We urge you to clarify that cover crops are considered good farming practices in order to ensure that farmers are not deterred from adopting cover crops and other conservation practices. In addition, we urge you to include provisions from the Agricultural Data Act providing for better data collection on conservation practices, and to provide USDA the authority to offer premium discounts for conservation programs
• Conservation Compliance: We are pleased that both bills maintain the linkage between conservation compliance and crop insurance subsidies. Please ensure that the final bill is free from provisions to weaken or undermine wetland or soil conservation compliance provisions.
• Riders: We urge you to keep the Farm Bill clean and free from attacks on the Clean Water Act, Endangered Species Act, National Environmental Policy Act, and other bedrock environmental laws.
We thank you for your work to craft a 2018 Farm Bill that will protect our nation’s soil, water and wildlife.

National Wildlife Federation

Alabama Wildlife Federation
Arizona Wildlife Federation
Arkansas Wildlife Federation
Audubon Society of New Hampshire
Colorado Wildlife Federation
Conservation Coalition of Oklahoma
Conservation Federation of Missouri
Conservation Northwest (Washington)
Environmental League of Massachusetts
Delaware Nature Society
Florida Wildlife Federation
Georgia Wildlife Federation
Idaho Wildlife Federation
Indiana Wildlife Federation
Iowa Wildlife Federation
Kansas Wildlife Federation
Kentucky Waterways Alliance
Louisiana Wildlife Federation
Michigan United Conservation Clubs

Minnesota Conservation Federation
Mississippi Wildlife Federation
Montana Wildlife Federation
Nebraska Wildlife Federation
Nevada Wildlife Federation
New Mexico Wildlife Federation
North Carolina Wildlife Federation
North Dakota Wildlife Federation
Ohio Conservation Federation
Planning and Conservation League (California)
Prairie Rivers Network
Sociedad Ornitológica Puertorriqueña Inc. (Puerto Rico)
South Dakota Wildlife Federation
Texas Conservation Alliance
Vermont Natural Resources Council
VI Conservation Society (Virgin Islands)
Virginia Conservation Network
Wyoming Wildlife Federation

Detailed Programmatic Recommendations for the 2018 Farm Bill Conference Report

Conservation Compliance
• Retain the linkage between compliance and crop insurance
• Reject any provision that could undermine current law, including all efforts to weaken the Swampbuster program

• Strengthen Sodsaver by closing the ‘alfalfa loophole’
• Expand Sodsaver beyond current states, either through adding additional states or at the very least, retaining the Senate provision for states to voluntarily opt in

Agriculture Conservation Easement Program (ACEP)
• Increase ACEP funding back to at least $500 million
• Reject provisions to allow mineral rights development
• Retain the requirement for all easements to have conservation plans, but allow the plans to be separate from deed terms for greater flexibility
• Allow the Secretary to waive the AGI requirement for wetland reserve easements
• Increase flexibility for non-federal cost share of easements
• Raise wetland reserve easements county cap to 15% — up from 10%

Conservation Reserve Program
• Increase CRP acres if possible, but not at the expense of program quality
• Given the anecdotal evidence, just coming in, regarding the current CRP sign-up, we strongly urge caution when considering capping the rental rate, particularly for continuous practices
• Retain current incentive payment levels for those CRP practices that have high environmental benefits
• Keep cost-share in place at a base rate of 50% to ensure that landowners are not deterred by cost of installing quality conservation practices that address soil, water and wildlife
• Authorize longer term/permanent CRP Easements
• Codify and prioritize State Acres for Wildlife Enhancement (SAFE) and Conservation Reserve Enhancement Program (CREP)
• Reject giving governors the authority to authorize emergency haying and grazing.
• Allow greater flexibility for haying and grazing, provided that this is in exchange for a reduction in the rental rate of 40 percent for haying and 25 percent for grazing, and that key safeguards for vegetation and wildlife, such as were included in the Senate bill, are included
• Allow grazing without a reduction in rental rate when completed as a mid-contract management activity

Regional Conservation Partnership Program
• Provide at least $250 million per year in mandatory funding
• Allow more flexibility and streamlining through standalone RCPP contracts
• Allow partnership agreements to extend beyond 5 years
Allow for additional program flexibility by allowing a limited portion of partners’ administrative costs and outreach costs to be funded through RCPP, and by providing for aggregate and/or alternate contracting arrangements to reduce burdens on partners, producers, and NRCS staff
• Better target projects by allowing for funding for watershed planning

• Require that at least 10 percent of EQIP funds are dedicated to funding wildlife habitat conservation practices each year
• Increase the amount of livestock funding targeted at grazing management practices within EQIP
• Do not make drainage districts eligible for funding unless a provision is added to ensure that no additional land or wetlands are drained
• Require a review of EQIP practice standards and payment rates to ensure conservation benefits
• Allow up to 10- year wildlife contracts

Conservation Stewardship Program
• Maintain CSP as a standalone program
• Add supplemental payment for advanced grazing management

Other Recommendations
• Add chronic wasting disease to the list of high priority research and extension initiatives
• Include report language that would direct USDA to implement a native vegetation standard
• Reauthorize and provide at least $50 million over 5 years for Voluntary Public Access
• Adopt the House bill provision authorizing USDA to measure, evaluate, and report on conservation program outcomes
• Add funding for feral swine eradication in a way that does not lead to a reduction in conservation title baseline