Archive | July, 2012

Defenders recommends framework for conserving candidate species

Wildlife conservation is generally less expensive and more effective when deployed as early as possible.  Yet the U.S. Endangered Species Act (ESA) does not always encourage early conservation.  If a land developer finds a rare plant that might become listed under the ESA, how can the act reward him for protecting that plant now?

Pre-listing conservation (PLC) can answer this question in certain situations.  PLC involves the U.S. Fish & Wildlife Service using its authority under the ESA to issue “credits” for conservation measures taken to benefit at-risk and imperiled species before they are listed under the ESA.  Those credits could then be used to offset harmful impacts to the species, including impacts that occur after listing and hence are regulated under the ESA.  A person can use credits to offset his own impacts or sell the credits to another person who needs offsets.  In both cases, the tangible value of credits is one reward for taking early conservation.

In March of this year, the Fish & Wildlife Service issued an advance notice of proposed rulemaking to request public comment on how the Service can create PLC projects.  Today, we submitted an extensive comment letter that includes a proposed framework for creating PLC “pilot projects” using the Service’s existing rules, policies, and guidance under the ESA.  No new rulemaking is involved.

Our framework allows the Service to determine how to structure a project based on (1) whether project participants are federal agencies or non-federal entities and (2) whether the participants have provided enough information about the activities to be offset by the pre-listing conservation measures, such that the Service can evaluate, at the time the prelisting conservation agreement is drafted, the adverse impacts of those activities on the species.  Page 11 of our letter includes a diagram that captures this decision framework.

Over the next few years, we expect the Service to add dozens, if not hundreds, of species to the list of candidate species.  PLC and other pre-listing measures could improve the status of those species and create a smoother glide path for an eventual listing or even prevent listing altogether.

Posted in Imperiled Wildlife, Paying for Conservation, private lands, Public Lands0 Comments

10 Steps Backwards for Wildlife in the House Ag Committee Farm Bill

10 Steps Backwards for Wildlife in the House Ag Committee Farm Bill

In the early hours of the morning on Thursday, July 12th the House Committee on Agriculture passed a Farm Bill that cuts conservation while expanding insurance and price support programs that will encourage habitat destruction on lands and wetlands poorly suited to produce food for America. Here are the ten most problematic provisions in the House Committee bill.

  1. Funding Cuts for Conservation: Conservation funding has been cut by more than $6 billion, with the steepest cuts to the Conservation Reserve Program, likely resulting in at least 5 million acres of grassland, stream buffers and wetland habitat coming out of the program and going under the plow.
  2. Dedicated Funding for Wildlife Eliminated: The Wildlife Habitat Incentives Program, a popular and effective program, is eliminated in both the Senate and House bills but the Senate creates opportunity for wildlife funding through the Environmental Quality Incentives Program (EQIP) with a minimum 5 percent of program funding going to wildlife.  The House makes this set aside for wildlife a 5 percent maximum, meaning that many farmers with wildlife projects will likely be turned away.
  3. More Expensive Crop Insurance Subsidies: Annual taxpayer subsidies to crop insurance companies and farmers’ insurance premiums have already gone up by more than $6 billion over the last decade.  The Agriculture Committee proposes another $9 billion increase which is structured in ways that make the taxpayer bear the risk while encouraging farmers to plow fragile lands that are poorly suited to food production.
  4. Conservation Compact between Farmers and Taxpayers Destroyed:Conservation compliance’ has been a deal between farmers and taxpayers for more than 25 years.  In exchange for public support, farmers agree to modest protections for soil, water and wildlife on approximately 500 million acres of farmland.  The House Agriculture Committee chose to ignore the Senate’s extension of this compact that recent polls show has the support of the majority of farmers themselves.
  5. Modest Habitat Protections Voted Down: A limited version of conservation compliance called ‘sodsaver’ was also rejected by the Agriculture Committee despite strong support from hunters and fishermen, environmentalists, the ethanol industry and National Farmers Union.  This provision would have made farmers who plow up wetlands or the less than 1 percent of virgin prairie remaining in America ineligible for crop insurance for just five years.  Even this moderate penalty failed to pass the Committee, despite evidence that compliance provisions have been successful  and provide a net economic benefit.
  6. Reduced Support for Organic Farming: The Committee tilts an already tilted playing field further toward industrial agriculture.  It eliminates dedicated support to help farmers use less pesticide and go organic by repealing the National Organic Certification Cost Share program, reduces funding for organic research and maintains barriers that impede organic farmers’ efforts to insure their crops.
  7. Renewable Energy and Energy Conservation Zeroed Out: No support is provided for renewable energy, eliminating what were highly successful programs to help capture methane emissions from dairies and feedlots, energy audits, and other programs that have helped thousands of farms reduce energy bills and fossil fuel use and switch to renewable energy sources.
  8. No Oversight of Pesticide Application into Waterways: Section 10017 of the House farm bill axes all Clean Water Act protections for pesticides that are sprayed directly into waterways.  This would result in the direct application of pesticides into streams and rivers without any oversight, as the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) – the law under which pesticides are registered – does not require tracking of such pesticide applications.
  9. Blocks Protection of Endangered Species from Pesticides: Section 10016 of the House farm bill puts the interests of pesticide manufacturers ahead of the health of our wildlife and communities.  This section prescribes non-science based roadblocks and delays for measures recommended by federal wildlife experts to protect endangered species from pesticides.  This spells disaster for species already on the brink of extinction because of pesticides and other threats.
  10. Increased Logging in our National Forests: Section 8301 would give the Forest Service broad discretion to designate sweeping areas of our National Forests for expanded logging, roadbuilding and other development by exploiting the danger of wildfires and harmful pests.  Projects in these “critical areas” would be permitted to move forward with almost no environmental review or public involvement, and projects as large as 1,000 acres would not be required to have any environmental review at all. This provision would undercut public involvement and important environmental analysis that protects water and wildlife on our public lands.

Posted in Agriculture0 Comments

Shifting Farm Safety Net Threatens Conservation Investments

Shifting Farm Safety Net Threatens Conservation Investments

The Farm Bill has an entire title dedicated to conservation, and USDA, which implements the Farm Bill, dedicates tens of millions of dollars to helping restore and recover species like the sage grouse and red-cockaded woodpecker. But with the 2012 Farm Bill shifting farm subsidy support from direct payments to crop insurance, the farm safety net could work at cross purposes to conservation investments by encouraging farmers to plant on environmentally sensitive land.

To read more about conservation compliance and crop insurance subsidies, see our fact sheet.

Between 1982 and 2003, the U.S. lost 25 million acres of grassland, most of which was converted to cropland. Subsidies to farmers are an important factor driving this land use change because subsidies reduce the financial risks farmers face and government payments can make farming marginal land profitable. A recent USDA report found that certain farm subsidies (crop insurance, marketing loans and disaster assistance payments) increased the conversion of habitat by 2.3 million acres in just a portion of the Northern Plains and with crop prices at record highs, between 1.5 million and 3.3 million acres of wetlands are at risk of conversion. It’s not only that insurance subsidy payments contribute to grassland and wetland conversion but that they contribute to this conversion on some of the most vulnerable land.

We have the tool to decrease these habitat losses – conservation compliance. The idea behind conservation compliance is simple: farmers receiving taxpayer support must take measures to protect environmental resources that provide valuable public benefits. That means not planting on native grassland or draining wetlands if they receive farm subsidies.

Conservation compliance has been part of direct payments since 1985 but was de-linked from crop insurance subsidies in 1996. As farm subsidies shift from direct payments to crop insurance in the 2012 Farm Bill, it is time to re-link full conservation compliance measures to crop insurance. With a bipartisan floor amendment, the Senate version of the 2012 Farm Bill does just that and now the House needs to follow suit.

Posted in Agriculture0 Comments

House Farm Bill: Continued Subsidies at the Cost of Wildlife

House Farm Bill: Continued Subsidies at the Cost of Wildlife

America’s wildlife benefit from what has been more than $5 billion in annual conservation support through the Farm Bill, but these investments in our natural heritage are threatened by crop insurance subsidies from the same bill that encourage farmers to plow grassland, wetland and forest. While the Senate’s version of the 2012 Farm Bill contains an amendment that requires farmers receiving crop insurance subsidies to take basic conservation measures to protect soil, water and wildlife (provisions known as “conservation compliance”), the draft House Farm Bill does not include conservation compliance. Failure to link conservation compliance to crop insurance subsidies could have major impacts on species like sage grouse.Map of sage grouse range and agricultural expansion

Sage grouse are dependent on sage brush habitat for nesting and food sources and much of this sage brush habitat overlaps with farmland in the western U.S. –  31 percent of sage grouse range is privately owned.

New analysis from the Environmental Working Group shows that increased crop production is leading to grassland (and wetland) loss in parts of the sage grouse range. More than half a million acres of habitat has been plowed under in just three years.

Conservation compliance has been proven to protect clean water, prevent soil erosion and preserve wildlife on millions of acres of America’s farmland. In order to protect vital habitat for sage grouse and other species that depend on grasslands and wetlands, the House should take similar action to the Senate and add conservation compliance requirements back into crop insurance subsidies as the bill moves through the chamber later this week.

Posted in Agriculture, Imperiled Wildlife0 Comments


dotWild is the blog of scientists and policy experts at Defenders of Wildlife, a national, nonprofit membership organization dedicated to the protection of all native animals and plants in their natural communities.

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