The Union of Concerned Scientists
Food & Environment Program
Written Farm Bill Comments
Submitted to the House Committee on Agriculture
June 2006

On behalf of the Union of Concerned Scientists' 100,000 members and supporters, we write to offer the following comments on high priority farm policy considerations.  We thank you for considering our comments and hope to see them reflected in the House Committee on Agriculture's farm bill.

The Union of Concerned Scientists (UCS) is the leading science-based nonprofit working for a healthy environment and a safer world.  UCS combines independent scientific research and citizen action to develop innovative, practical solutions and secure responsible changes in government policy, corporate practices, and consumer choices.  UCS' Food and Environment Program seeks to ensure that food is produced in a safe and sustainable manner. 

Title II Conservation Programs

The Union of Concerned Scientists strongly supports Title II conservation programs and would like to see greater funding for these programs.  While we applaud Congress for setting strong levels of funding for Title II in the Farm Security and Rural Investment Act of 2002 (the farm bill), we have been disappointed these amounts have been reduced each year. 

UCS supports all Title II conservation programs.  We'd like to take this opportunity to focus in particular on two: the Conservation Security Program and the Environmental Quality Incentives Program.

Conservation Security Program

UCS strongly supports the Conservation Security Program (CSP) as it was envisioned by Congress, as do many agricultural producers across the country.  We would like this vision realized.  We believe that CSP will be an important program that produces significant, geographically-diverse conservation benefits when it is funded and administered as a truly nationwide program with a continuous open enrollment, offering sufficient incentives for agricultural producers to employ ambitious and effective conservation practices. 

Specifically, CSP should be funded as an entitlement program.  CSP enrollment should be open to all agricultural producers in the nation regardless of location.  Sign up should be continuous.  CSP should reward agricultural producers who are already good stewards of the land, as well as those who want to implement needed conservation practices prior to enrolling in CSP.  Agricultural producers who are already good stewards of the land should be given more – not fewer – rewards than other agricultural producers enrolled in CSP. 

The program should provide sufficient incentives for effective conservation practices.  Limits on cost-share payments should be sufficiently high to encourage agricultural producers to continue to undertake ambitious and efficacious conservation practices.  CSP cost-share rates should be at least as high as those set for the Environmental Quality Incentives Program.  CSP should provide a 90 percent cost share rate for beginning and limited resource farmers.  All other CSP participants should receive a 75 percent cost share rate.

CSP should reward well-managed grass-based pasture operations.  It should support rotational grazing and other pasture management approaches that protect native animal and plant species.  We believe that enrollment of grass-based pasture operations in CSP has so far been far too low.  Enrollment of these operations would be increased by allowing CSP to support permanent cover and multi-year rotation of alfalfa and hay and by adding more enhancement payments for well-managed grass-based pasture operations.

Additionally, CSP should reward those livestock producers that do not use antibiotics and should aid other livestock producers transitioning away toward significant, sustained reductions in antibiotic use.

CSP should pay for research and demonstration projects on CSP farms. 

Environmental Quality Incentives Program

The Union of Concerned Scientists supports farm bill conservation programs only in so far as they are used to produce conservation benefits.  We believe EQIP supports many beneficial projects, but under current rules we are concerned that significant amounts of EQIP funds can go to pay for projects that are potentially environmentally harmful, such as the construction of manure lagoons at large concentrated animal feeding operations (CAFOs).  We would like to see an EQIP in the 2007 farm bill that is a true conservation program. 

To achieve this, UCS supports:

• limiting eligibility for cost-share payments for structural practices at livestock operations to those with fewer than 1,000 animal units;
• significantly reducing the dollar maximum per contract to well below the current $450,000;
• increasing the minimum term of contract; and
• providing greater balance between EQIP funds targeted to livestock operations as compared with other operations. 

EQIP should not underwrite and promote the expansion of large CAFOs.  We recommend that USDA give the highest priority for use of EQIP livestock funds to sustainable livestock and poultry producers whose systems are designed to minimize the risk of harm to natural resources and public health, or to those operators seeking to transition to such systems.  For example, EQIP funds should be used, in the case of livestock operations, for managed rotational grazing, pasture and range management, hoop houses, composting, and other environmentally sound non-confinement alternatives to large-scale animal operations.

To the degree that EQIP funds are directed to CAFOs, USDA should focus this funding to providing long-term solutions to environmental and public health threats posed by existing CAFOs.  These funds should not be provided to new or expanding CAFOs nor to re-construct waste handling and management facilities with demonstrated design and operation flaws, particularly large-scale liquid waste lagoons and effluent sprayfields.  EQIP cost-share funds should not be used for structures and waste handling facilities located in 100-year floodplains, except to help producers safely remove the facilities from the 100-year floodplain. 

We recommend that all EQIP contracts that require Comprehensive Nutrient Management Plans (CNMPs) be ten-year contracts.

Congress should restore conservation planning language from the 1996 EQIP rule that the USDA stripped away.  EQIP Plans of Operations to assess the resources (such as soil, habitat, and water resources) present on the farm or ranch that is the subject of the contract are essential and should be required.  An analysis of the environmental challenges facing the property must be required, as well as the most cost-effective practices to solve the challenges.

EQIP should be expanded to provide additional benefits to well-managed grass-based pasture operations as well as those livestock producers that do not use antibiotics and those transitioning away toward significant, sustained reductions in antibiotic use.

Congress should correct the USDA's overreaching interpretation of privacy provisions relating to EQIP.  Privacy arguments should not be used as a barrier to sound administration, public participation, and public accountability of this program.

Grass Fed and Grass Finished Animal Production Systems

The Union of Concerned Scientists strongly supports grass-fed and grass-finished production systems for beef cattle, dairy cows, swine, and poultry.  There is a growing demand for grass-fed and grass-finished animal products, both in the U.S. and around the world.  The USDA should provide financial and technical assistance to encourage the increased production of these products.  UCS supports increased funding for existing programs that support producers of grass fed and grass finished animal products, including research programs, value added programs, and extension and outreach programs.  Both CSP and EQIP should be retooled to provide greater assistance to a larger number of well-managed grass-fed and grass-finished production systems. 

Antibiotic Resistance

The GAO warned in an April 2004 report that the current U.S. approach to antibiotic use in animal agriculture could become a trade problem in the future with the European Union, Canada, and possibly other countries.  ("ANTIBIOTIC RESISTANCE: Federal Agencies Need to Better Focus Efforts to Address Risk to Humans from Antibiotic Use in Animals.")  It is important for the next farm bill to encourage more prudent antibiotic use practices now to prevent future barriers to international trade.

The routine feeding of antibiotics to farm animals that are not sick promotes development of antibiotic-resistant bacteria that can be transferred to people, making it harder to treat infections in humans.  Resistant bacteria can reach people through the consumption of meat, through on-farm contact, and through the environment.  Scientific studies have linked the overuse of antibiotics in animal agriculture to antibiotic-resistant infections that cause more severe illnesses, longer hospital stays, and sometimes medical treatment failures resulting in death.  The National Academy of Sciences has estimated that antibiotic resistance costs at least $4 to $5 billion annually.

Congress should ban the addition of medically important antibiotics to animal feed and water.  Medically important antibiotics are those that belong to classes of antibiotics also used in human medicine, namely penicillins, tetracyclines, macrolides, lincosamides, streptogramins, aminoglycosides, and sulfonamides.    

If Congress falls short of this needed action, the next farm bill should encourage the increased production of competitive animal products demanded around the world by providing assistance to those producers employing a more sustainable approach to antibiotic use in animal agriculture and to those producers seeking to transition toward more sustainable use.  The next farm bill should aid these producers by funding relevant research, conservation practices, demonstration projects, and transition programs.  One useful research project, for example, could examine the benefit of delayed weaning of piglets in reducing the routine use of medically important antibiotics during the weaning and nursery stages.

Competition

The role of government should be to facilitate properly operating markets and to bring balance to the economic relationships among farmers and ranchers, consumers, and food companies. Current lack of fair business policies and lack of enforcement of anti-trust policies are having a negative impact on not only farmers and ranchers, but also on rural communities, the environment, food quality, food safety, and consumer prices.

UCS recommends that the next farm bill encourage competition and ensure fair business practices by supporting Country of Origin Labeling, prohibiting packer-owned livestock, ensuring contract fairness in agriculture, and taking other pro-competition measures.  

Country of Origin Labeling (COOL) was passed as a provision of the Farm Security and Rural Investment Act of 2002.  This popular measure allows consumers to determine where their food is produced while allowing producers to differentiate their products for quality and safety and enter new markets.  It also limits the ability of global food companies to source farm products from any country while passing them off as of U.S. origin.  Unfortunately, implementation of this law has been needlessly delayed.  The House Committee on Agriculture should support mandatory COOL to benefit producers and consumers and should see that it is fully implemented in the near future.

Balance in the Farm Bill

There should be a greater balance between farm bill titles in the 2007 bill, with titles other than Title I gaining in funding.  It has been disappointing that both the President's budget and Congressional appropriations have routinely achieved cuts in farm bill spending by disproportionately taking from titles of the farm bill other than Title I.  Title II conservation programs have been especially hard hit.

The USDA should ensure that the assistance provided through the farm bill is more evenly distributed, so that small and medium-sized producers around the country will be able to thrive.  Reasonable caps on Title I payments would allow better funding for other farm bill titles, such as conservation and rural development.  USDA Value-Added Producer Grants provide one specific example of a program meriting greater funding for the purpose of enhancing rural economic growth.

Agricultural Product Development

UCS supports USDA programs that aid agricultural product development, marketing, and research, including the Farm-to-Cafeteria program, the Farmers Market Promotion Program, National Research Initiative/Initiative for Future Agriculture, Rural Business Enterprise Grants, and Value-Added Producer Grants.  We would like to see the USDA work with Congress to ensure that strong funding is both authorized and appropriated for these programs.

Thank you once again for your thoughtful consideration of these comments.