-------- Original Message --------
Subject: SAC releases press release on EQIP changes; please pass on
Date: Mon, 8 Apr 2002 17:16:49 EDT
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Defenders of Wildlife * Natural Resources Defense Council *
Sierra Club * Sustainable Agriculture Coalition *

For Immediate Release
Contact:
Melanie Shepherdson, NRDC, 202-289-2393
April 8, 2002
Martha Noble, SAC, 202-547-5754

CONSERVATION GROUPS URGE FARM BILL CONFEREES TO ADDRESS
SHORTCOMINGS OF ENVIRONMENTAL QUALITY PROGRAM

WASHINGTON, D.C. – Leading conservation groups today urged House and
Senate farm bill conferees to refrain from stripping the Environmental
Quality Incentives Program (EQIP) of key conservation and environmental
measures, noting that the House bill in particular is a radical
departure from the current EQIP.  According to the organizations, the
EQIP proposals being considered in conference committee could lead to a
new large subsidy scheme for expansion of industrial-sized confined
livestock operations, with serious, negative environmental consequences.

“The farm bill conferees have to decide whether to keep real
conservation measures in this bill, or turn it into just more subsidies
for polluting factory farms” said Ed Hopkins, senior Washington
representative with the Sierra Club.  “Our groups are united in urging
them not to make a mockery of this important conservation program.”

The EQIP program, established by the 1996 farm bill, is the major
federal agricultural conservation cost share program.  Both the House
and Senate farm bills would greatly increase annual funding for the
program, from $200 million per year under current law to well over $1
billion per year.  The House bill, however, completely rewrites the
program to reduce its environmental objectives.  Both bills delete
current law prohibitions on payments to build waste lagoons for large
scale animal factories, though the Senate bill retains some critical
basic minimum restrictions on these types of payments.

Environmental Targeting

The House bill removes existing language targeting the program to
serious environmental threats, removes existing language allowing USDA
to focus money on priority watersheds, and removes existing language
directing USDA to maximize environmental benefits per taxpayer dollar
expended.  The House bill also reduces the EQIP contract term to just
one year, which would in essence do away with conservation planning, the
linchpin of the existing program.  In each of these proposals, the House
farm bill dramatically reverses the policy established by Congress in
the last farm bill.

“The House bill is the worst of both worlds – it more than
quintuples
funding and puts per farm payment limitations through the roof, yet
destroys the basic environmental nature of the program.” said Susan
Prolman, government relations associate with Defenders of Wildlife.
“The House proposal is EQIP in name only – in substance it creates
an
unfocused and potentially anti-environmental program, coupled with
vastly increased funding.”

In addition to retaining most of the existing targeting language, the
Senate bill also provides for new conservation innovation grants within
EQIP to leverage state and private funds in pursuit of special projects
to protect source drinking water, reduce nutrient applications, and
promote carbon sequestration.  The Senate bill also includes an
innovative pilot project for the Chesapeake Bay region to nutrient
applications and loadings.

Animal Factories

Under current law, USDA does not provide payments from the Environmental
Quality Incentives Program (EQIP) for the construction of large-scale
(over 1,000 animal units as defined by USDA) confined livestock and
poultry feeding operations, often referred to as CAFOs.  CAFOs above the
current Clean Water Act regulatory threshold of 1,000 animal units
currently represent 5 percent of total animal confinement operations in
the country, according to USDA figures, and a much smaller percentage
when grazing and other non-confinement livestock operations are
included.

Large-scale animal factories have proliferated across the nation with
little regard for the environmental damage and public health threats
arising from the huge amounts of animal waste generated by these
operations.  Many rural communities have seen drinking water supplies
and recreational waters degraded.  In some cases, neighboring property
owners, including those who have lived in their communities for
generations, have been driven from their homes.  Farmers and ranchers
have joined with others in bringing legal actions against these
facilities.

For 25 years, since implementation of the Clean Water Act in 1976, CAFOs
have been directed, at least in theory, to comply with environmental
safeguards as “point sources” of pollution.  The weakness and
inconsistency of those regulatory controls spurred a new proposed EPA
rule in January 2001, a rule subsequently attacked by national livestock
trade associations.

“It is ironic that industrial-sized technologies with a very
substantially negative environmental track record would become eligible
for subsidies to foster and encourage expansion under a purportedly
environmental quality program,” said Martha Noble, senior counsel with
the Sustainable Agriculture Coalition.  “In the name environmental
safeguards, the industry is asking the taxpayer to absorb its capital
and production expansion expenses, expenses which would normally be
considered a cost of doing business, especially for a regulated
industrial sector.”

Over 70 farm, rural, and environmental organizations wrote to farm bill
conferees in March supporting provisions in the Senate version of EQIP
that provide some safeguards against abuse.  The letter (attached)
describes a number of protections added to the Senate bill that together
retain a degree of integrity to EQIP, including lower payment
limitations, a prohibition on owners of multiple CAFOs from receiving
funding, and requirements for CAFOs to have approved plans for
environmentally sound waste disposal practices.

Payment Limitations

The House bill lacks any effective payment limitation.  The House bill
nominally limits EQIP payments to $50,000 a year or $200,000 per every
“multiyear” contract.  Under the House bill, a contract may be of
just
one year’s duration, making a multiyear contract potentially as short
as
two years.  Over the life of the proposed 10 year House bill, this could
result in $1 million being made available to the same operation (i.e.,
10 year bill divided by 2 year contract times $200,000 equals $1
million).

In reality, however, the House bill has no limit at all.  Unlike the
Senate bill in which all payments are directly attributed to real
persons, the House bill allows payments to multiple business entities
(often referred to as “paper farms”) that are actually the same
operation.  Unlike current crop subsidies that at least limit producers
to three such entities (the so-called “three entity rule” – a rule
which
the Senate bill would eliminate as part of its payment limitation reform
provision), the House EQIP proposal would allow owners to collect EQIP
payments through unlimited numbers of entities.

“For the past several months people have been asking how it came to
pass
that specific individuals have received millions of dollars in
government crop subsidies,” said Ferd Hoefner, Washington
representative
for the Sustainable Agriculture Coalition. “The answer is quite simple
–
Congress, over succeeding farm bills, has laced the payment limitation
law with legal loopholes, a process that will be started all over again
with respect to livestock should the House EQIP provisions prevail.”

Prior to passage of the 1996 farm bill, the annual conservation
cost-share limit was $3,500.  Since the implementation of EQIP in 1997
and its new $10,000 annual limit and $50,000 5-year limit, cost-share
payments for animal waste storage structures of various kinds have
averaged $7,000-$14,000 per 5-year contract per farm on a national
basis, according to USDA data.  This is considerably less than even the
current law limitation and just a small fraction of the proposed
$150,000 5-year limit in the Senate bill and $200,000 nominal 2-year
limit in the House bill.

Confidentiality

Both the House and Senate bills, through different mechanisms, would
keep information relating to conservation programs private, potentially
compromising the implementation and enforcement of EPA's permitting
program for CAFOs mandated by the federal Clean Water Act.  In 1972 when
Congress enacted the Clean Water Act, it recognized that CAFOs are
significant sources of water pollution and as a result specifically
identified these industrialized livestock facilities as point sources
requiring regulation under the federal National Pollutant Discharge
Elimination System (NPDES) permitting program.

Realizing that chronic over application and misapplication of animal
manure contributes to water pollution, the states and EPA are beginning
to require CAFOs to develop nutrient management plans.  In order to
prevent pollution from excess waste application, the terms of these
nutrient management plans need to be incorporated into the NPDES permit
and be enforceable.  USDA provides technical assistance to many CAFOs to
develop nutrient management plans.

Both farm bills contain provisions that could shield the information
provided to or developed by USDA for technical or financial assistance
not only from the public eye, but also from any federal, state, local
agency, or Indian Tribe.  Withholding this information would interfere
with ability of state agencies and EPA to effectively implement
regulatory programs designed to protect the environment and public
health, such as the control of water pollution from CAFOs.  USDA
confidentiality provisions should not be used to impede the ability of
EPA, the Department of Justice, state agencies, and citizens to bring
enforcement actions against bad actors under environmental and public
health laws.

"USDA should not be given license to interfere with the implementation
and enforcement of a federally mandated Clean Water Act permitting
program," said Melanie Shepherdson, an attorney with the Natural
Resources Defense Council.  "Federal courts and the EPA have recognized
that controlling runoff from the land application of waste is just as
important as preventing spills from waste storage lagoons. The conferees
should ensure that any privacy language adopted be narrowly tailored and
not undercut EPA's jurisdiction or shield bad actors from being held
accountable for violating the Clean Water Act and other regulatory
programs that protect the environment and public health."

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