MEMORANDUM

TO: Docket EPA-HQ-OAR-2013-0479

FROM: Deborah A. Reed, Environmental Scientist, OAR/OTAQ/CD

SUBJECT: USDA data used for 2013 U.S. agricultural land determination

DATE: November 13, 2015

As set forth in the preamble to the March 26, 2010 RFS regulations, EPA monitors total 

agricultural land annually to determine if national agricultural land acreage increases above the 2007 

national aggregate baseline of 402 million acres. 

In order to estimate the total amount of agricultural land in the U.S. in 2013, 2014, and 2015,

EPA relied upon data provided by two offices within the U.S. Department of Agriculture (USDA): the 

Farm Service Agency (FSA) and the Natural Resource Conservation Service (NRCS). This data was 

summarized and transmitted to EPA by Dr. Harry Baumes, Director of Energy Policy and New Uses, USDA 

Office of the Chief Economist. The spreadsheet is included here.

Please note that the EPA has made a change to the aggregate compliance methodology based 

on guidance received from USDA. In the March 26, 2010 RFS regulations the aggregate compliance 

methodology provided for the exclusion of acreage enrolled in the Grassland Reserve Program (GRP) 

and the Wetlands Reserve Program (WRP) from the estimated total U.S. agricultural land. However, the 

2014 Farm Bill has terminated the GRP and WRP as of 2013 and USDA established the Agriculture 

Conservation Easement Program (ACEP) with wetlands and land easement components. Both programs 

have similar goals, though they are different in scope and implementation. The ACEP provides financial 

and technical assistance to help conserve agricultural lands and wetlands and their related benefits. 

Under the Agricultural Land Easements component, USDA helps Indian tribes, state and local 

governments and non-governmental organizations protect working agricultural lands and limit nonagricultural uses of the land. Under the Wetlands Reserve Easements component, USDA helps to 

restore, protect and enhance enrolled wetlands. The former WRP was a voluntary program that offered 

landowners the opportunity to protect, restore, and enhance wetlands on their property. The GRP was 

a voluntary conservation program the emphasized support for working grazing operations, 

enhancement of plant and animal biodiversity, and protection of grassland under threat of conversion 

to other uses.

USDA and EPA concur that the ACEP-WRE and ACEP-ALE represent a continuation in basic 

objectives and goals of the original WRP and GRP, although the ACEP-ALE is a bit more expansive that 

the GRP with respect to eligible land. Therefore it was assumed in this rulemaking that acreage enrolled 

in the easement programs would represent a reasonable proxy of WRP and GRP acreage. Both Agencies
have committed to conduct a more detailed analysis of the new programs for the 2017 RFS Annual 

Volume Regulation.

Based on data provided by the FSA and NRCS, we have estimated that U.S. agricultural land 

reached approximately 380 million acres in 2013, and thus did not exceed the 2007 baseline acreage. 

This acreage estimate is based on the same methodology used to set the 2007 baseline acreage for U.S. 

agricultural land in the RFS2 final rulemaking. Specifically, we started with FSA crop history data for

2013, a total estimated acreage of 379,717,296 acres. We then subtracted the amount of land estimated 

to be participating in the Grasslands Reserve Program (GRP) and Wetlands Reserve Program (WRP) by 

the end of Fiscal Year 2013: 144,619 acres, to yield an estimate of approximately 380 million acres of 

U.S. agricultural land in 2013. Note that the GRP and WRP programs were still in place in 2013. 

Similarly, we have estimated that U.S. agricultural land reached approximately 378 million acres 

in 2014, and thus did not exceed the 2007 baseline acreage. This acreage estimate is based on the same 

methodology used to set the 2007 baseline acreage for U.S. agricultural land in the RFS2 final 

rulemaking, with GRP and WRP data substitution as noted above. Specifically, we started with FSA crop 

history data for 2014, from which we derived a total estimated acreage of 377,829,781 acres. We then 

subtracted the amount of land estimated to be participating in the Agriculture Land Easement (ACEPALE) and Wetlands Reserve (ACEP-WRE) by the end of Fiscal Year 2014, 143,834 acres, to yield an 

estimate of approximately 378 million acres of U.S. agricultural land in 2014. The USDA data used to 

make this derivation can be found in the docket to this rule.

Finally, we have estimated that U.S. agricultural land reached approximately 379 million acres in 

2015, and thus did not exceed the 2007 baseline acreage. This acreage estimate is based on the same 

methodology used to set the 2007 baseline acreage for U.S. agricultural land in the RFS2 final 

rulemaking, with GRP and WRP data substitution as noted above. Specifically, we started with FSA crop 

history data for 2015, from which we derived a total estimated acreage of 379,236,620 acres. We then 

subtracted the Agriculture Land Easement (ACEP-ALE) and Wetlands Reserve (ACEP-WRE) enrolled acres 

by the end of Fiscal Year 2015, 84,133 acres, to yield an estimate of approximately 379 million acres of 

U.S. agricultural land in 2015. The USDA data used to make this estimation can be found in the docket to 

this rule.

The 2013, 2014 and 2015 total agricultural land estimates are well below the 2007 baseline of 

402 million acres. Therefore, no further analysis is needed and no additional renewable biomass 

recordkeeping and reporting requirements are triggered for renewable fuel producers using crops and 

crop residues as a fuel feedstock. This result supports historical trends in U.S. land used for agriculture, 

and the EPA assumption that these trends would continue in an overall contraction in agricultural land 

acreage over time. This contraction offsets any increase in agricultural land used to produce crops and 

crop residue as a feedstock for renewable fuel.

Attachment: Data provided by Harry Baumes, OEPNU/OCE
ACRES

2011 2012 2013 2014 2015

Agr Cropland (FSA) 391,389,522 383,864,496 379,717,296 377,829,781 379,236,620

Conservation Reserve Program (Enrolled Acres) 31,124,371 29,525,599 26,838,728 25,448,835 24,180,455

WRP INCREMENTAL 176,245 149625 85,527

WRP Cum Total 2,445,622 2595246.77 2,680,774

ACEP-WRE INCREMENTAL 54941 47235

CUM ACEP-WRE 54941 102176

SPLICED CUMULATIVE WRP&WRE 2,445,622 2595246.77 2,680,774 2,735,715 2,782,950

GRP INCREMENTAL 74121 46968 59092

GRP Cum Total 290062 337030 396121

ACEP-ALE INCREMENTAL 88893 36898

CUM ACEP-ALE 88893 125790

SPLICED CUMULATIVE GRP&ALE 290062 337030 396121 485014 521912