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## STATEMENT OF KEN COOK

***President***

***Environmental Working Group***

***Hearing to Review USDA Farm Bill Conservation Programs***

***Before the Committee on Agriculture***

***Subcommittee on Conservation, Credit, Energy, and Research***

***Thursday, April 19, 2007, at 1 pm***

***Submitted for the Record***

Mr. Chairman, distinguished Members of the Subcommittee: my name is Ken
Cook, and I am president of the Environmental Working Group (EWG), a
nonprofit research and advocacy organization based in Washington, DC and
Oakland, California. In the years since the first farm bill I worked on,
as an agriculture policy analyst the Congressional Research Service in
1977, I have had the honor of testifying before this subcommittee on a
number of occasions. I very much appreciate the opportunity to do so
again, today.

My testimony addresses two parts.

\(1\) District-level summary conservation program data for each member
of the subcommittee. This previously unpublished data is derived from
EWG's forthcoming release of subsidy benefits information obtained
through the Freedom of Information Act last December, when USDA released
the database it compiled in response to the congressional mandate in
Section 1614 of the 2002 farm bill.

\(2\) At the request of the subcommittee, I will also address the
innovative Conservation Security Program that was established in the
2002 farm bill, with emphasis on findings of a recent, excellent
evaluation of the CSP prepared by the Soil and Water Conservation
Society and Environmental Defense.

**Importance of conservation programs**. Farm bill conservation programs
and program spending are critically important to the subcommittee's
members, collectively and individually.

Using the new USDA 1614 database of direct payments and attributed
benefits for program years 2003 through 2005, EWG found that over \$1.6
billion in conservation payments (CRP, EQIP, CSP, WRP, GRP, and
WHIP[^1]) have been provided to over 162,000 beneficiaries in the
districts of the 26 members of the House Subcommittee on Conservation.
(See Table below)

Conservation program benefits provided to farmers in the districts of
members of the Subcommittee on Conservation, Credit, Energy and
Research, PY 2003-2005.

  --------------------- --------------------- ---------------- ---------------- ----------------
  **District**          **Conservation        **Conservation   **Conservation   **Conservation
                        Program Benefits      Program          Benefits per     Benefits As
                        (2003-2005)**         Recipients       Beneficiary**    Percent of
                                              (2003-2005)**                     Commodity plus
                                                                                Conservation
                                                                                Benefits
                                                                                (2003-2005)**

  Rep. Jerry Moran      \$296,568,102         31,749           \$9,341          18%
  (KS-1)                                                                        

  Rep. Stephanie        \$223,291,192         20,559           \$10,861         17%
  Herseth Sandlin                                                               
  (SD-AL)                                                                       

  Rep. Steve King       \$179,465,556         18,042           \$9,947          13%
  (IA-5)                                                                        

  Rep. Sam Graves       \$170,897,910         12,545           \$13,623         39%
  (MO-6)                                                                        

  Rep. Marilyn N.       \$170,871,193         7,874            \$21,701         34%
  Musgrave (CO-4)                                                               

  Rep. Jeff Fortenberry \$109,471,201         10,385           \$10,541         14%
  (NE-1)                                                                        

  Rep. Frank D. Lucas   \$105,529,685         10,014           \$10,538         20%
  (OK-3)                                                                        

  Rep. Leonard L.       \$93,400,170          7,996            \$11,681         19%
  Boswell (IA-3)                                                                

  Rep. Timothy J. Walz  \$78,733,878          12,035           \$6,542          8%
  (MN-1)                                                                        

  Rep. Nancy E. Boyda   \$44,966,601          7,072            \$6,358          16%
  (KS-2)                                                                        

  Rep. Terry Everett    \$31,012,641          4,482            \$6,919          16%
  (AL-2)                                                                        

  Rep. John T. Salazar  \$29,329,853          2,167            \$13,535         54%
  (CO-3)                                                                        

  Rep. Tim Walberg      \$27,844,685          3,171            \$8,781          18%
  (MI-7)                                                                        

  Rep. Brad Ellsworth   \$25,633,867          4,268            \$6,006          8%
  (IN-8)                                                                        

  Rep. Steve Kagen      \$11,473,671          3,025            \$3,793          8%
  (WI-8)                                                                        

  Rep. Zachary T. Space \$7,749,129           1,341            \$5,779          11%
  (OH-18)                                                                       

  Rep. Tim Holden       \$7,157,500           848              \$8,440          20%
  (PA-17)                                                                       

  Rep. Mike Rogers      \$5,262,026           807              \$6,520          16%
  (AL-3)                                                                        

  Rep. Henry Cuellar    \$4,088,265           342              \$11,954         11%
  (TX-28)                                                                       

  Rep. Jo Bonner (AL-1) \$3,908,361           872              \$4,482          7%

  Rep. Robin Hayes      \$3,665,685           905              \$4,050          9%
  (NC-8)                                                                        

  Rep. Jean Schmidt     \$3,591,685           546              \$6,578          13%
  (OH-2)                                                                        

  Rep. Kirsten E.       \$3,296,325           410              \$8,040          11%
  Gillibrand (NY-20)                                                            

  Rep. Jim Costa        \$2,789,949           369              \$7,561          1%
  (CA-20)                                                                       

  Rep. Dennis A.        \$2,734,336           313              \$8,736          2%
  Cardoza (CA-18)                                                               

  Rep. David Scott      \$70,243              19               \$3,697          40%
  (GA-13)                                                                       

  **Subcommittee        **\$1,642,803,708**   **162,156**      **\$10,131**     **17%**
  Total**                                                                       
  --------------------- --------------------- ---------------- ---------------- ----------------

Source: Environmental Working Group. Compiled from USDA Section 1614
Data Release, December 2006.

On average, over the three program years, \$10,000 in benefits was
provided per beneficiary. Conservation payments in the subcommittee's
districts averaged 17 percent of the total spending on conservation plus
commodity programs. Every district on the subcommittee received
conservation funds. Any member by member comparison must consider the
size of the state and the number of farmers in each state to put the
data in perspective.

**Distribution of conservation benefits.** For seven members of the
subcommittee, conservation program payments to their districts exceeded
\$100 million over the last three years. In the districts of eight
members, conservation payments ranged between \$11.4 million and \$93.5
million over the period.

**Distribution of conservation program beneficiaries.** In seven of the
subcommittee's districts, more than 10,000 farmers and ranchers received
benefits through conservation programs between 2003 and 2005. For
another nine members, between 1,000 and 10,000 farmers received benefits
in their districts.

**Distribution of conservation benefits per beneficiary.** In eight
subcommittee districts, farmers received, on average, over \$10,000 in
conservation benefits over the three program years. In thirteen
subcommittee districts, farmers received over \$5,000 and under \$10,000
in conservation benefits.

**Distribution of conservation spending as a percent of commodity plus
conservation spending.** To illustrate the importance of conservation
relative to commodity programs, we summed both categories and then
presented conservation funding as a percentage of that total. We found
that for four members of the subcommittee, conservation spending between
2003 and 2005 exceeded 30 percent of the combined commodity and
conservation funds. For fifteen districts, farmers and ranchers received
between 10 percent and 30 percent of their federal support through
conservation programs while 7 members had farmers receiving less than 10
percent of their federal support from conservation programs.

Below we provide a sample narrative for conservation spending in the
districts of the Chairman and the Ranking Member. In addition to
referencing the data contained from the table above, we cite data from a
table showing Unfunded Conservation Requests by State in 2004 (below).
We also provide 52 tables -- two tables for each district represented on
the Subcommittee showing 1) farmer participation in each conservation
program in one table and 2) conservation program ranking against
commodity programs in a second table.

Unfunded Conservation Requests by State, 2004

  ----------------- ----------------------- -----------------------------
  **State Rank**    **State**               **2004 Total NRCS
                                            Conservation Backlog**

  1                 Arkansas                \$253,832,454

  2                 Texas                   \$162,919,270

  3                 Florida                 \$160,944,955

  4                 California              \$143,096,228

  5                 Nebraska                \$139,210,997

  6                 Indiana                 \$131,566,485

  7                 Illinois                \$115,180,386

  8                 Iowa                    \$112,305,471

  9                 Oklahoma                \$98,025,377

  10                Louisiana               \$95,523,177

  11                New York                \$92,535,120

  12                Colorado                \$75,808,617

  13                Minnesota               \$71,739,333

  14                Kansas                  \$70,969,832

  15                Vermont                 \$66,759,932

  16                Missouri                \$63,172,954

  17                South Carolina          \$61,988,880

  18                Montana                 \$58,024,599

  19                Alabama                 \$55,954,634

  20                Mississippi             \$52,035,498

  21                Oregon                  \$51,365,140

  22                Tennessee               \$49,214,986

  23                Kentucky                \$48,833,147

  24                South Dakota            \$46,287,600

  25                North Carolina          \$45,858,375

  26                Washington              \$44,205,467

  27                Maine                   \$43,622,734

  28                Michigan                \$43,063,298

  29                Idaho                   \$41,364,464

  30                Ohio                    \$39,192,545

  31                New Mexico              \$38,971,942

  32                Pennsylvania            \$37,457,519

  33                Utah                    \$33,827,759

  34                Wisconsin               \$31,575,143

  35                Georgia                 \$28,091,435

  36                North Dakota            \$26,596,053

  37                Wyoming                 \$24,966,315

  38                New Jersey              \$24,915,318

  39                Massachusetts           \$24,491,974

  40                Arizona                 \$24,103,523

  41                West Virginia           \$22,701,307

  42                Virginia                \$17,349,645

  43                Connecticut             \$16,205,047

  44                Nevada                  \$12,744,590

  45                Delaware                \$8,079,452

  46                Alaska                  \$7,693,875

  47                Rhode Island            \$7,116,541

  48                New Hampshire           \$5,526,717

  49                Hawaii                  \$5,324,931

  50                Maryland                \$4,539,395

  51                Puerto Rico & VI        \$863,216

  52                Pacific Basin           \$201,103

                    **US Total**            **\$2,937,944,755**
  ----------------- ----------------------- -----------------------------

Source: Environmental Working Group, compiled from 2004 Unfunded
Conservation Applications data, Natural Resources Conservation Service.

**Chairman Tim Holden.** Within the subcommittee, Chairman Holden's
district ranks 17^th^ in conservation benefits received, with \$7
million going to 848 beneficiaries over the last three program years.
From the Chairman's table showing conservation program participation, we
see that farmers in his district were enrolled in four programs over the
last three years: 751 farmers in CRP receiving \$6.4 million, 42 in EQIP
receiving \$489,000, 80 in CSP receiving \$173,000 and one in the GRP
receiving \$1,287.

From the Chairman's table showing conservation programs ranked against
commodity programs, between 2003 and 2005, the CRP was the third most
important farm program in Rep. Holden's district in terms of
expenditure, behind the corn and dairy program, while EQIP ranked sixth
behind soybean subsidies and wheat subsidies. The CSP ranked eighth in
spending importance, behind barley subsidies.

In terms of the conservation backlog problem, Chairman Holden's state,
Pennsylvania ranked 32^nd^ in the nation for the value of unfunded
conservation program applications in FY 2004. That is, Pennsylvania
farmers in 2004 applied for \$37 million in various NRCS-run
conservation programs and had eligible applications but were turned away
due to lack of conservation funds. That's \$37 million that could have
gone to assist in dairy manure management to prevent further nutrient
leaching and runoff to the Chesapeake Bay and to help in various soil
erosion prevention practices like contour tillage, terracing, and
grassed waterways to help farmers prevent loss of valuable topsoil and
sedimentation of the states rivers and tributaries to the Bay.

**Ranking Member Frank Lucas.** Rep. Lucas' district ranked seventh in
conservation dollars amongst districts on the subcommittee. Some 10,014
beneficiaries in Rep. Lucas' district received \$105.5 million in
benefits over the last three program years for conservation practices:
8,619 beneficiaries received \$97 million from CRP; 1,418 received \$5.4
million from EQIP; 266 received \$2 million from CSP; 21 farmers
received \$795,000 from WRP; 34 received \$145,000 from GRP; and 12
received \$36,000 from WHIP.

Four of the six conservation programs operating in Rep. Lucas' district
are amongst the top 10 commodity and conservation programs in the
district. CRP ranks second only to wheat subsidies in program benefits,
while EQIP ranks seventh behind cotton, peanuts, corn, and sorghum. CSP
and WRP rank 9^th^ and 10^th^, respectively, for program funding, behind
dairy subsidies.

At the state level, over \$98 million in 2004 NRCS conservation requests
from Oklahoma farmers went unfulfilled, ranking Oklahoma 9^th^ in the
nation's conservation backlog. That's nearly \$100 million that was
requested by farmers to help with wind erosion problems that remain a
major cause of unsustainable rates of erosion, lowering soil
productivity, increasing the chances for crop failure and increasing air
pollution and sedimentation of the state's streams.

# Unfunded conservation program requests: The Conservation Backlog

The NRCS tracks conservation program applications that have been
received from tens of thousands of farmers and ranchers each year, but
which are turned away for lack of funds. We tallied the value of that
"conservation backlog" for just one year (FY 2004) across all
conservation programs for the states represented by members of this
subcommittee. The total backlog in FY 2004 in just these 18 states was
\$1.3 billion or nearly half the conservation backlog in all 50 states.

# Conservation Security Program

The Conservation Security Program was authorized by the 2002 farm bill
and was the first attempt to take on what I consider one of the toughest
problems in federal agricultural resource policy.

We have long experience in this country of providing technical and
financial assistance to farmers and ranchers to solve specific
agricultural resource problems, from water pollution to wildlife
conservation.

But how can conservation policy fairly, effectively and efficiently
reward the good resource and environmental stewardship so many farmers
and ranchers have already demonstrated? How do we recognize producers
who adopted above- average\--or even state-of-the-art\--conservation and
environmental practices on their own while encouraging them to do even
more?

Put another way, why should we provide taxpayer support, sometimes
significant support, to a farmer or rancher to adopt basic conservation
practices, when their neighbors all around have long since adopted them
on their own, with no help from the federal government?

I am reminded of a conversation I had just about 20 years ago with a
Missouri cow-calf operator who had about 1,000 acres of hay and pasture.
A few months before, Congress had enacted the Conservation Reserve
Program that originated in this subcommittee. I had lobbied for it over
several years. I explained how the government was going to kill two
birds with one stone: we would cost-effectively tackle excessive soil
erosion on tens of millions of acres by paying farmers to plant cropped
land to a protective cover of grass or trees, and by doing so help
control surplus crop production with a *real* conservation program---not
just annual set-asides.

"Let me see if I have this right," he asked. "We've had all these
fellows in northern Missouri plowing up pasture land to get federal crop
subsidies for planting corn. And now we're going to give them fifty buck
an acre to plant it *back* to grass, so that their fields will look
again the way mine have looked all along?"

The two of us looked out over those gorgeous, emerald fields to the
forested knobs beyond.

"You figure that's how this will work, Kenny?"

At that, I suddenly found it easier to look into the beer he'd just
handed me. "I guess so, Uncle Paul."

That would be the late Paul Cook, of Roselle, Missouri, as good a
steward of the land he had inherited from my grandfather---and the 800
acres he added---as you'd ever care to meet.

The truth is, both problems are worth tackling: how to solve
conservation problems that badly need solving, and how to support
conservationists who've already solved those very same problems.

That's how I think of the Conservation Security Program and what it set
out to do. Tough stuff, Mr. Chairman; tough stuff.

Recently, two highly respected organizations with deep experience in
agricultural conservation policy, the Soil and Water Conservation
Society and Environmental Defense, completed a review of the CSP as it
has operated in the past few years. I commend it to the subcommittee as
a fine example of fair, unflinching program evaluation, which is
something of a lost art in this town. My colleagues and I excerpted the
following passages from the SWCS/ED assessment for your consideration.

I look forward to answering any questions you or your subcommittee may
have, Mr. Chairman.

**CSP Faces Serious Challenges**

"CSP was designed to serve 2 purposes: 1) to provide a source of income
to producers and 2) to improve environmental quality and natural
resource condition in agricultural landscapes. These two purposes are
complementary but different. Our assessment suggests that CSP is falling
short of realizing either of its two purposes...Urgent action is needed
to recover the promise of CSP. Major changes must be made to the
program, and a secure funding level must be established if CSP is to
have any hope of realizing its potential." (p. 1)

**Align Vision and Funding**

"It is possible for one program to achieve the two purposes of income
support (rewarding good stewards) and environmental improvement
(providing incentives for producers to take new actions to help the
environment), but not without significant public investment. At least so
far, Congress and the Administration have not been willing to make that
investment; since enactment of the 2002 farm bill, Congress has capped
funding for CSP six times." (p. 1)

**Reward More Than the Status Quo**

"CSP, as currently implemented, presents conservationists with a
dilemma. Taxpayers are largely paying for environmental benefits they
are already receiving. Existing practice payments (4% of payments,
stewardship payments (14% of payments), and all of the enhancement
payments paid through the end of fiscal year 2005 (82% of payments) are
for benchmark, that is, pre-existing practices and activities.
Essentially all of the CSP payments made through the end of fiscal year
2005 and a large majority of total payments anticipated over the life of
2005 CSP contracts, then, are rewarding participants' status quo level
of conservation performance." (p. 2)

**Emphasize Quality Over Quantity**

"CSP, in statute and in implementation, rewards addressing a broad range
of resource concerns. That makes the program more flexible and
recognized the multiple benefits flowing from working land. It also
introduces the danger that quantity -- the number of resource concerns
addressed - outweighs quality -- the comprehensiveness with which an
individual resource concern is addressed. In other words, doing a little
for a lot of resource concerns may result in the same reward as doing a
lot for a few resource concerns even if those few are of the greatest
importance to conserve resources and improve environmental quality in a
particular area. The environmental performance of CSP should be enhanced
by taking the following steps: (1) emphasize management intensity, (2)
focus on resources that matter most, (3) improve quality criteria,...and
(4) lift the cap on technical assistance." (p.2)

# 

[^1]: CRP stands for Conservation Reserve Program, EQIP -- Environmental
    Quality Incentives Program, CSP -- Conservation Security Program,
    WRP -- Wetlands Reserve Program, GRP- Grasslands Reserves Program,
    and WHIP- Wildlife Habitat Incentives Program.