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Kansas Technical Committee Minutes | July 26, 2012

Kansas Technical Committee Minutes - July 2012

Kansas Technical Committee (KTC)
Thursday, July 26, 2012
by Electronic Mail

Emergency Haying of Conservation Practice (CP)-25, Rare and Declining Habitat for 2012 Only

Due to the current exceptional circumstances of extreme drought the Farm Service Agency (FSA) requested state conservationist Eric Banks' approval to expedite the KTC process by requesting input from the KTC by email on July 26, 2012. FSA was requesting input on the emergency haying of Conservation Reserve Program (CRP) CP-25, Rare and Declining Habitat. The email message from the Kansas FSA and the responses from KTC members are found below:

KTC members,

Yesterday, Senator Pat Roberts and Governor Sam Brownback called together Kansas leadership for a roundtable discussion meeting on drought assistance and coordination efforts in Topeka. In addition to the Senator and Governor in attendance were the leadership from Kansas Department of Agriculture, Kansas Water Office, U.S. Department of Agricultural (USDA) Risk Management, USDA FSA, Kansas State Climatologist, Kansas Rural Water, Kansas Farm Bureau, Kansas Livestock Association and Kansas Grain and Feed Association.

The senator described the 2012 drought as extreme with fully eighty percent of Kansas now in extreme drought and twenty percent in severe as designated on the U.S. Drought Monitor Map and requested all leadership to take all necessary steps within their organization to provide assistance to livestock and crop producers.

One of the key issues raised during the session is the lack of forage for livestock due to loss of pasture, hay crops, forage crops and corn silage due to the extreme drought covering most of the country. The current steps taken to release forage available on CRP acres through emergency grazing and haying including emergency grazing on CP-25, Rare and Declining Habitat, in a timely fashion has been of significant importance.

The group identified the need for further action to also release practice CP-25 for emergency haying as well. This discussion was based upon pastures being nearly completely gone statewide, with producers now feeding winter hay supplies from half of a 2012 hay crop to sustain core herds. In 2012, no reserves remain from 2011, and the area impacted covers most of the country. The forage needed is hay for winter hay supplies. Kansas has 725,000 acres enrolled in practice CP25.

Kansas FSA believes that a onetime haying of CP-25 limited to 50 percent of each field is less detrimental than losing the enrollment of the CRP cover due to lack of availability of desperately needed hay to a farmer or rancher who will determine whether the acreage will be re-enrolled in the program in the future.

This decision is not a Kansas decision and will be made at the secretary level. We fully realize the proposed action for this practice has not been evaluated under an assessment per the National Environmental Policy Act (NEPA), but are seeking your counsel on whether there is support or there is not.

Following the meeting, FSA was requested to seek your input on the consideration for releasing CP-25 for emergency haying. Please provide your input via email to Carla Wikoff and Jean Kunze Peterson using the email address reflected above.

Thank You,

Rod Winkler
Kansas FSA

The following responses were received from KTC members on haying CRP CP-25:

Member Organization Response
Steven Sorensen Kansas Wildlife Federation Favorable with restrictions
Steve Swaffar Kansas Farm Bureau Favorable
Greg Foley Kansas Department of Agriculture Favorable
Michael Disney Kansas Partners for Fish and Wildlife, U.S. Fish and Wildlife Service Favorable with restrictions
Matt Smith Kansas Department of Wildlife, Parks and Tourism Favorable
Jordan Martincich Pheasants Forever and Quail Forever Favorable
Ron Klataske Audubon of Kansas Strongly object

Carla/Jean?Thanks for the opportunity to respond to Rod's request for input on the request to authorize emergency haying of CP-25, Rare and Declining Habitat, in Kansas. We are concerned that with the severe and extensive drought this year, CRP fields, especially CP-25, may offer the only habitat to support native wildlife species. Native prairies and pastures are overgrazed because of the drought. That leaves CRP fields as the only suitable habitat. To cut these fields by 50 percent significantly impacts the benefits CRP provides. Wildlife is impacted by the drought just as much as the producer.

That said, the Kansas Wildlife Federation can concur with the emergency haying of CP-25 in 2012 only with the following stipulations in place:

  • Don't allow consecutive year grazing or haying, open only acres that weren't grazed last year
  • No whole-field haying, regardless of field size (50 percent maximum)
  • No commercial sale of forage by producer or lessee. There is a considerable amount of low quality CRP hay from last year still sitting around Kansas. This has depressed commercial hay operations with CRP hay dumped on the market
  • Assess and report results on impacts of this year's harvest action on CP-25, possibly the USDA and state, federal, and non-government organization (NGO) conservation partners cooperate to conduct such assessment
  • USDA should fund the NEPA analysis and possible environmental impact statement to facilitate grazing as an authorized management tool on CP-25
Again, thanks for the opportunity to respond.

Steve Sorensen
Conservation Vice President
Kansas Wildlife Federation



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Kansas Farm Bureau encourages the use of CP-25 for haying in this drought situation.

Steve M. Swaffar
Director of Natural Resources
Kansas Farm Bureau 800 SW Jackson, Suite 1300
Topeka, KS 66612
swaffars@kfb.org  785-234-4535



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Carla, as per the subject matter below, and as a member of the KTC, the Division of Conservation, Kansas Department of Agriculture supports the efforts to assist ranchers in allowing one-time haying of CP-25 for forage in these extreme drought–stricken counties.

The secretary and the governor have both addressed support for this as well, at the very recent video conference on drought with Senator Roberts. If you need written comments from both or either, in addition to this email reply, please let me know.

Thank you, Rod and Adrian for your efforts to respond to producer needs during this extreme drought.

Thanks Carla, Greg Foley



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Carla and Jean:

The service appreciates the opportunity to comment on the consideration of releasing CP-25 for emergency haying. We commend your ongoing efforts to provide relief to producers struggling to cope with the effects of this drought. The CRP is once again playing a vital role in sustaining the agricultural operations of our private landowners who in turn play a vital role in sustaining our nation’s fish and wildlife resources.

We concur with this consideration provided that the following clarifications and provisions are incorporated:

  • No more than 50 percent of an enrolled field is hayed.
  • A statement that authorization of emergency haying on CP-25 acres constitutes a one-time waiver for 2012 only.
  • Reports be provided to the state CRP Committee, the Natural Resources Conservation Service (NRCS) state conservationist, the Kansas Department of Widlife, Parks and Tourism (KDWPT), and the U.S. Fish and Wildlife Service concerning the acres actually hayed and grazed by practice and by county.
Once again, thank you for providing the ability to comment on this consideration.

Sincerely,

Michael Disney
Kansas Partners for Fish and Wildlife Program
U.S. Fish and Wildlife Service
2609 Anderson Ave
Manhattan, KS 66502
Telephone (785) 539-3474 ext. 107
http://www.fws.gov/mountain-prairie/pfw/kansas/



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Rod, Carla:

KDWPT recognizes the difficult situation the drought has placed Kansas producers and would agree to allow haying on 50 percent of each field enrolled in CP-25 outside of the primary nesting season. KDWPT has advocated in the past haying and grazing be approved as a management practice on CP-25, hopefully emergency use of CP-25 forage will prompt the FSA national office into completing the NEPA process on all currently ineligible practices.

It will be critical for producers and wildlife to keep the 50 percent limitation on haying. No one can say how long the drought will continue so we should not allow all the forage reserves to be used at once. The 50 percent rule provides a safety net for nesting wildlife and livestock producers.

I would encourage we work together in the future to evaluate the effects haying and grazing have on CRP cover to ensure all statutory program requirements are being met. Thank you for the opportunity to provide comment on this important issue.

Matt Smith
Farm Bill Coordinator
Kansas Department of Wildlife and Parks
Office - 785-658-2465 Ext. 204
Cell - 620-450-7207
Note new email address - matt.smith@ksoutdoors.com



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Rod and Carla:

Pheasants Forever echoes the below CP-25 recommendations made by Matt Smith of KDWPT and urges FSA to consider these recommendations.

“KDWPT recognizes the difficult situation the drought has placed Kansas producers and would agree to allow haying on 50 percent of each field enrolled in CP-25 outside of the primary nesting season. KDWPT has advocated in the past haying and grazing be approved as a management practice on CP-25, hopefully emergency use of CP-25 forage will prompt the FSA national office into completing the NEPA process on all currently ineligible practices.

It will be critical for producers and wildlife to keep the 50 percent limitation on haying. No one can say how long the drought will continue so we should not allow all the forage reserves to be used at once. The 50 percent rule provides a safety net for nesting wildlife and livestock producers.

I would encourage we work together in the future to evaluate the effects haying and grazing have on CRP cover to insure all statutory program requirements are being met. Thank you for the opportunity to provide comment on this important issue.”

Please let us know if there is anything we can do to help.

Thanks,

Jordan Martincich | Development Officer

Pheasants Forever, Inc. and Quail Forever | 1740 South Willow Street | Ottawa, Kansas 66067

p. (785) 242-3175 | m. (816) 560-1070 | JMartincich@pheasantsforever.org



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July 30, 2012
Dear Rod:

Although Audubon of Kansas has concurred with reasonable requests for emergency grazing and restricted haying of appropriate CRP fields prior to this proposal, we strongly object to the release of 725,000 acres enrolled in practice CP-25 in Kansas at this time, or any time during this ongoing drought. Although we share concern that hay supplies may be limited in many areas, and as with last year hay prices are elevated (like other agricultural commodities), the potential loss of hundreds of thousands of acres with haying of CP-25 “rare and declining habitat” CRP plantings could be astronomically costly for wildlife, conservation programs and elements of the economy that dependent on wildlife for as many years as it will take to recover the wildlife populations.

This is one of those occasions when the critical habitat provided by CRP fields with expenditures of hundreds of millions of tax dollars already invested in them in the Great Plains needs to be protected. Under the extended drought conditions that are being experienced over a vast area of the Great Plains, fields enrolled in practice CP-25 may be all there is in terms of survival habitat in significant landscapes for a wide range of wildlife species. This is particularly true for the imperiled Lesser Prairie-Chicken of southwestern Kansas and portions of four other states in that area. Although Lesser Prairie-Chicken populations in Kansas have reportedly “recovered some” in recent years, it has only occurred in Kansas and the primarily reason is because of habitat created by enrollment in CRP in the southwestern third of Kansas. The declines in other states may have been every more precipitous if it weren’t for CRP in those areas. Because Lesser Prairie-Chicken populations, and the survival of this species, are so precarious and have been for a number of years, landowners have received extra environmental index points for establishment of CRP enrollment (especially practice CP-25) in that area of the country. Now is when the birds (and other wildlife) need that habitat most for brood cover, foraging and escape habitat, winter cover in a few months, and critically as potential nesting habitat next spring—or the springs after if this drought continues and there is insufficient regrowth in other CRP fields cut this year or native grasslands grazed short.

It seems counter-productive to release hundreds of thousands of acres of CP-25 for haying when a broad coalition of conservation entities (federal, state and NGOs) have been working hard to build support for the NRCS Environmental Quality Incentives Program (EQIP) Lesser Prairie–Chicken initiative, and tens of thousands of additional acres to be enrolled to specifically benefit Lesser Prairie-Chickens (and other at-risk species in that area) with State Acres for Wildlife Enhancement (SAFE), CP-38E Lesser Prairie–Chicken Habitat Enhancement. SAFE proposals have been an ongoing effort since 2070. The purpose:

  • To restore mixed-grass grasslands to maintain and enhance Lesser Prairie– Chicken populations.

Considerable progress has been made, but pales in comparison to what may be lost if several hundred thousand acres of CRP enrolled in CP-25 are hayed this year in the range of the Lesser Prairie-Chicken, especially considering that most other CRP fields have already been released for haying and grazing and at such a low cost for consumption that it makes it highly likely that it will be harvested regardless of hay quality or immediate need. Benefits to many wildlife species will be lost, as there will be few refugia for these species. Added mortality from predation, insufficient food and other factors will reduce survival in the few remaining suitable habitat areas of with concentration.

Because of astronomically high grain prices in recent years due in considerable measure to programs diverting grains from livestock feed and human food to mandated and subsidized production of ethanol and other biofuels, many hundreds of thousands (probably millions) of acres of native grassland (previously used as rangeland or haylands) have been converted to cultivated agriculture. Grain producers benefit from numerous subsidities and programs, however landowners who produce hay for market or retain native rangelands for rental generally do not. To some degree the value of their resources are diminished by CRP give away proposals. The drought will increase hay prices and pasture rent, but shouldn’t the market be allowed to benefit those with hay production and pasture for rent?

Last year thousands of trucks hauled hay from the Dakotas to Texas. Hay that would normally have sold for less that $100 per ton was delivered to Texas cattle producers and feedlots with a value of $300 per ton or more, with the federal government reported paying two thirds of the cost ($200 per ton in many cases). Whether they knew it or not, taxpayers stepped up to the plate to dramatically help producers. Some stockmen hauled herds to Nebraska and elsewhere to graze corn stubble fields while awaiting rains and better soil moisture recovery back home. Risk management and land stewardship require adjustments in livestock numbers in years when available pastureland and hayland is unable to support optimum production, however severe droughts (particularly if they are multi-year) challenge the best of managers and often require herd reductions at less-than-optimal times in terms of price. We trust that many of the low yielding crop fields will not be harvested and will be available for grazing this fall and winter along with fields that are harvested.

It is expensive to haul hay long distances, and heart-wrenching for livestock producers to cut their herds to the carrying capacity of the land and resources they have available, but it is impossible to transport critical habitat needed for wildlife.

Earlier this month, Senator James Inhofe (R-OK), Ranking Member of the Senate Committee on Environment and Public Works, along with five members of the Kansas Congressional delegation and others, sent a letter to Dan Ashe, Fish and Wildlife Service (FWS) Director, urging the FWS not to list the Lesser Prairie-Chicken under the Endangered Species Act (ESA). (See the following news report: http://www.canadafreepress.com/index.php/article/48128)

If USDA makes a decision to release 725,000 acres of CP-25 fields for haying in Kansas and more in other states it will become increasing likely that the Lesser Prairie-Chicken will become threatened, or even endangered, if the drought persists and habitat conditions do not improve dramatically. Lesser Prairie-Chicken nesting and brood-rearing success has already been dramatically diminished by drought conditions—and it is much worst when even that remaining drought-impacted habitat is diminished (possibly cut in half).

The proposed action of releasing additional CRP fields, especially CP-25 fields, for haying is likely to make it imperative that the Fish and Wildlife Service make a finding that the species is threatened or endangered.

In addition to imperiled species, there are other consequences to dramatic reductions in wildlife habitat contained in CRP fields. The State of Kansas and many entities within the state benefit economically from the presence of CRP habitat that supports populations of game species (including Pheasants, Northern Bobwhites, Greater Prairie-chickens, Mule Deer and White-tailed Deer to mention a few). Not only will wildlife populations be diminished, but also fields with suitable cover for hunting opportunities and the sale of resident and nonresident hunting licenses—and the economy that hunters contribute to ranging from motel stays, restaurant meals, sporting equipment sales to outfitting.

Ron Klataske
Executive Director
Audubon of Kansas
210 Southwind Place
Manhattan KS 66503
785-537-4385
Ron_Klataske@audubonofkansas.org



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KTC Recommendation: With a majority of responses in favor of emergency haying of practice CRP CP-25, the KTC has recommended to FSA the approval of emergency haying of CRP CP-25 for 2012.
STC Decision: Concurred with this recommendation.