HSCF JOINS OTHER CONSERVATION GROUPS IN SUPPORT OF THE FEDERAL LAND TRANSACTION FACILITATION ACT

HSCF joined other NGO’s and Conservation Organizations requesting David Bernhardt, Secretary of Interior, Department of the Interior, to fully implement the now-permanently reauthorized Federal Land Transaction Facilitation Act (FLTFA). FLTFA is a critical western lands program that will facilitate modified land exchanges and increase public access and recreation, when fully implemented. Included in recommendations for implementation was the request to delegate authority for land acquisition decisions.

FLTFA is a common-sense public lands tool that achieves economic and conservation goals with broad bipartisan support across the West. Originally authorized in 2000, FLTFA expired in 2011 and was permanently reauthorized in 2018 (P.L. 106-248). FLTFA facilitates strategic federal land sales by the Bureau of Land Management (BLM) to provide funding for high-priority land conservation within or adjacent to federal lands in the eleven contiguous western states and Alaska. Under FLTFA, the revenue generated from BLM land sales must be deposited into the Federal Land Disposal Account, as opposed to the U.S. Treasury, to allow BLM, U.S. Forest Service, National Park Service, and U.S. Fish and Wildlife Service to pursue land conservation projects that increase public access for outdoor recreation, hunting, and fishing; conserve wildlife habitat; protect water quality; and preserve historic and cultural resources. Furthermore, BLM will have additional funding to conduct sales and other administrative real estate work, increasing staff capacity. Once fully operational, these FLTFA land sales and acquisitions will again provide a critical tool for consolidating private and public land ownership, allowing for more efficient land management and expanded business operations. Recommendations to Secretary Bernhardt further noted that the BLM, working with its partner agencies, must fully implement the law, beginning with finalizing the Memorandum of Understanding (MOU) between these agencies.

SUPPORT MODERNIZING THE PITTMAN-ROBERTSON FUND FOR TOMORROW’S NEEDS ACT

HSCF joined other NGO’s and Conservation Organizations in providing a letter to Senator John Barrasso, Chairman, Committee on Environment & Public Works and Senator Thomas Carper, Ranking Member, Committee on Environment & Public Works, requesting support of S. 3051, America’s Conservation Enhancement Act.

S. 3051 includes numerous conservation provisions passed y a bipartisan group within the Environment and Public Works Committee. These provisions include:

  • Reauthorization of the North American Wetlands Conservation Act (NAWCA) at $60M annually through Fiscal Year (FY) 2025. Leveraging private matches to federal funds at a rate of 3:1, NAWCA has improved over 30 million acres of wetlands since its enactment, making it one of our nation’s most effective voluntary conservation programs.
  • Establishment of a U.S. Fish & Wildlife Service-led task force to address the spread of Chronic Wasting Disease (CWD). CWD has thus far been detected in 26 states.  Ensuring that states have a coordinated plan to research, surveil and manage the spread of the disease is critical to containment.
  • Codification of the National Fish Habitat Partnership (NFHP). Since 2006, the NFHP has overseen over 840 projects to benefit fish habitat and populations. Codifying the program will serve to ensure future funding for the NFHP.
  • Modernization of the Pittman-Robertson (PR) Fund. S. 3051 would amend the Pittman-Robertson Wildlife Restoration Act to allow states greater flexibility in the use of funds to recruit and retain sportsmen and women. The American model of conservation is dependent upon a strong population of hunters and anglers. It is thereby critical that states are afforded the ability to utilize trust fund dollars to recruit, reactivate, and retain hunters.
  • Reauthorization of the Chesapeake Bay Program at $90M through FY2025, as well as authorization and funding to carry out recommendations put forth in the Chesapeake Clean Water Blueprint.
  • Authorization and $15M in annual funding to support coordinated research and monitoring of binational fisheries within the Great Lakes Basin through FY2025.  

The passage of America’s Conservation Enhancement Act will not only have wide-ranging ecological impacts but will facilitate outdoor recreation on behalf of millions of Americans

Houston Safari Club (HSC) is a 501(c)(4) non-profit organization dedicated to legislative and policy initiatives that may affect the future of hunting. HSC supports initiatives that protect the tradition of hunting and hunters’ rights. We take an active role in efforts to effect policy, protocols and legislation. Our mission is to protect the rights of hunters and the hunting heritage through advocacy, policy and legislation. Houston Safari Club (HSC) is a non-profit organization, exempt from federal income tax, under section 501(c)(4) of the United States Internal Revenue Code. Payments to HSC are not deductible as charitable contributions for federal income tax purposes. Please contact your tax advisor concerning deductibility of any payments as business deductions. HSC EIN: 76-0082197. HSC is an independent organization, is not affiliated with Safari Club International (SCI) or its affiliates and is not a chapter or affiliate of any other organization.

SUPPORT H.R. 3742: RECOVERING AMERICA’S WILDLIFE ACT

The Recovering America’s Wildlife Act has been introduced in the U.S. House by Representatives Dingell (D-MI-12) and Fortenberry (R-NE-01). This bipartisan legislation establishes a 21st Century funding model for the proactive conservation of fish and wildlife. This legislation redirects $1.3 billion annually in existing revenues to state fish and wildlife agencies to implement their science-driven wildlife action plans, and an additional $97.5 million to tribal wildlife managers to conserve species on tribal lands and waters. This funding will ensure those with a proven track record of success in species conservation and recovery can proactively conserve at-risk fish and wildlife in a voluntary, non-regulatory manner. To date, there are 157 cosponsors.

SUPPORT MODERNIZING THE PITTMAN-ROBERTSON FUND FOR TOMORROW’S NEEDS ACT

Another very important bill has been reintroduced in the 116th Congress-the Modernizing the Pittman-Robertson Fund for Tomorrow’s Needs Act. The Pittman-Robertson Act directs excise taxes on firearms, ammunition, and archery equipment to be used for wildlife conservation purposes. Since its origin in 1937, this legislation has contributed nearly $11.5 billion to wildlife conservation. This legislation would provide funding to state wildlife agencies for the recruitment, retention, and reactivation of hunters and recreational shooters (R3) through educational programs.   

SUPPORT S.500, H.R. 1225: RESTORE OUR PARKS (AND PUBLIC LANDS) ACT

Maintaining roads, trails, campsites, parking lots, boat ramps, and other public lands infrastructure makes possible the millions of visits to hunt, fish, scout, hike, climb, and enjoy them. Since much recreation and most hunting and fishing occurs on non-Parks land, we recommend that the legislation also direct a small portion of the funding to maintain infrastructure at National Forests (10% of funds), National Wildlife Refuges (10%), and Bureau of Land Management lands (5%). These multiple use and wildlife-focused lands host more than 261 million visitors annually, in addition to the 331 million visitors to National Park sites. The maintenance backlog on all our public lands should be addressed simultaneously and equitably. To date there are 329 cosponsors.

SUPPORT S.261, H.R. 925: NORTH AMERICAN WETLANDS CONSERVATION EXTENSION ACT

For the past thirty years, NAWCA has produced economic and environmental benefits, while conserving wetlands that support America’s fish and wildlife resources. More than 5,600 conservation partners from small landowners to large corporations have teamed up on 2,644 NAWCA projects to positively affect over 33.4 million acres of habitat. Through the history of the program, NAWCA projects have been implemented in all 50 states. In addition to protecting wildlife habitat, this program improves water quality and generates local revenue by increasing tourism through enhanced outdoor recreation opportunities. This program also creates on average, nearly 7,500 new jobs annually, generating more than $200 million in worker earnings each year. UPDATE: In November, the U.S. House of Representatives passed H.R. 925, the North American Wetlands Conservation Extension Act (NAWCA), on a bipartisan suspension vote. This bill will authorize $60 million annually through Fiscal Year 2024 to conduct on-the-ground wetland conservation projects across North America. H.R. 925 now awaits further action in the U.S. Senate.

OPPOSE H.R. 2245: THE CONSERVING ECOSYSTEMS BY CEASING THE IMPORTATION OF LARGE ANIMALS TROPHIES ACT

HSC was an original signer and has joined forces with 31 other conservation organizations to oppose this piece of legislation. This bill represents an ill-conceived attempt to substitute uninformed prejudices for the management strategies of the wildlife authorities successfully conserving the world’s largest populations of lions, elephants and other African species in their range countries. If implemented, H.R. 2245 would undermine some of the most effective strategies for conserving the world’s wildlife.  

OPPOSE H.R. 4804: TO AMEND THE ENDANGERED SPECIES ACT OF 1973 TO PROHIBIT THE TAKING OF ANY ENDANGERED OR THREATENED SPECIES OF FISH OR WILDLIFE IN THE UNITED STATES AND THE IMPORTATION OF ENDANGERED OR THREATENED SPECIES TROPHIES INTO THE UNITED STATES, AND FOR OTHER PURPOSES.

Introduced by Rep. Ted Lieu (D-CA-33), another blanket-approach attempt to halt hunting based on emotion and not science. Rather than a consideration of scientific and statistical analysis of animals listed under the Endangered Species Act or conducting an evaluation of threatened species that may be eligible for removal from the list, uninformed legislators are attempting to disregard hunting as an effective method of conservation and wildlife management.

HOUSTON SAFARI CLUB ADDRESSES CWD

Houston Safari Club, along with 31 other conservation organizations, delivered a letter to the US House Natural Resources Committee urging Congress to help address Chronic Wasting Disease (CWD). The request was to take action against CWD this year by advancing the following bills out of Committee and to the House floor for further action:

  • H.R. 837 the Chronic Wasting Disease Transmission in Cervidae Study Act, sponsored by Representatives Ralph Abraham (LA) and Marc Veasey (TX). H.R. 837 would help address the issue of a lack of reliable information surrounding CWD. This bill would direct the Secretaries of Agriculture and the Interior to enter into an agreement with the National Academy of Sciences to conduct a study on CWD which will build upon and synthesize prior research on transmission pathways and management strategies.
  • H.R. 1550 the Chronic Wasting Disease Management Act, sponsored by Representatives Ron Kind (WI) and Jim Sensenbrenner (WI). This bill would provide much needed financial resources to state and tribal agencies to enhance surveillance and monitoring efforts, develop and implement management strategies and control methods, and provide funding for additional research on CWD.

Houston Safari Club (HSC) is a 501(c)(4) non-profit organization dedicated to legislative and policy initiatives that may affect the future of hunting. HSC supports initiatives that protect the tradition of hunting and hunters’ rights. We take an active role in efforts to effect policy, protocols and legislation. Our mission is to protect the rights of hunters and the hunting heritage through advocacy, policy and legislation. Houston Safari Club (HSC) is a non-profit organization, exempt from federal income tax, under section 501(c)(4) of the United States Internal Revenue Code. Payments to HSC are not deductible as charitable contributions for federal income tax purposes. Please contact your tax advisor concerning deductibility of any payments as business deductions. HSC EIN: 76-0082197. HSC is an independent organization, is not affiliated with Safari Club International (SCI) or its affiliates and is not a chapter or affiliate of any other organization.

SUPPORT PROP 5! VOTE YES FOR THE NOVEMBER 2019 TEXAS CONSTITUTIONAL AMENDMENT

In November, a Texas constitutional amendment will appear on the ballot. A simple majority vote will appropriate the revenues from sales tax on sporting goods equipment to fund state parks and historical sites. Sen. Lois Kolkhorst of Brenham and Rep. John Cyrier of Bastrop, with the approval of Governor Abbott, led the Texas Legislature to pass bills calling for the constitutional vote. Between 1993 and 2017, the state’s sporting goods sales tax has generated between $60 million and $165 million annually for a total of $2.5 billion. During that time, only 40% percent of the funding found its way into the budgets of the Texas Parks and Wildlife Department or the Texas Historical Commission as intended. Many citizens incorrectly assume the taxes they pay on sporting goods were fully allocated to support parks, not realizing that significant portions of the Sporting Goods Sales Tax are diverted to other purposes. TPWD operates 95 parks and historical sites of its own around the state. The system covers more than 630,000 acres and attracts almost 10 million visitors annually. Its 2019 budget is $86 million, $60 million of which comes from its current share of the sporting goods sales tax. TPWD has been faced with many challenges and needed repairs as a result of severe weather and flooding over the past several years (in the last 10 years, TPWD has experienced more than $100 million in flood damage to park’s facilities around the state), in addition to the expenses required to routinely maintain Texas state parks. If approved, the amendment would authorize 94% of the revenue to TPWD’s parks and historical sites and 6% to sites under the Texas Historical Commission.

SUPPORT H.R. 3742: RECOVERING AMERICA’S WILDLIFE ACT

The Recovering America’s Wildlife Act has been introduced in the U.S. House by Representatives Dingell (D-MI-12) and Fortenberry (R-NE-01). This bipartisan legislation establishes a 21st Century funding model for the proactive conservation of fish and wildlife. This legislation redirects $1.3 billion annually in existing revenues to state fish and wildlife agencies to implement their science-driven wildlife action plans, and an additional $97.5 million to tribal wildlife managers to conserve species on tribal lands and waters. This funding will ensure those with a proven track record of success in species conservation and recovery can proactively conserve at-risk fish and wildlife in a voluntary, non-regulatory manner.  

SUPPORT MODERNIZING THE PITTMAN-ROBERTSON FUND FOR TOMORROW’S NEEDS ACT

Another very important bill has been reintroduced in the 116th Congress-the Modernizing the Pittman-Robertson Fund for Tomorrow’s Needs Act. The Pittman-Robertson Act directs excise taxes on firearms, ammunition, and archery equipment to be used for wildlife conservation purposes. Since its origin in 1937, this legislation has contributed nearly $11.5 billion to wildlife conservation. This legislation would provide funding to state wildlife agencies for the recruitment, retention, and reactivation of hunters and recreational shooters (R3) through educational programs.   

SUPPORT S.500, H.R. 1225: RESTORE OUR PARKS (AND PUBLIC LANDS) ACT

Maintaining roads, trails, campsites, parking lots, boat ramps, and other public lands infrastructure makes possible the millions of visits to hunt, fish, scout, hike, climb, and enjoy them. Since much recreation and most hunting and fishing occurs on non-Parks land, we recommend that the legislation also direct a small portion of the funding to maintain infrastructure at National Forests (10% of funds), National Wildlife Refuges (10%), and Bureau of Land Management lands (5%). These multiple use and wildlife-focused lands host more than 261 million visitors annually, in addition to the 331 million visitors to National Park sites. The maintenance backlog on all our public lands should be addressed simultaneously and equitably.

SUPPORT S.261, H.R. 925: NORTH AMERICAN WETLANDS CONSERVATION EXTENSION ACT

For the past thirty years, NAWCA has produced economic and environmental benefits, while conserving wetlands that support America’s fish and wildlife resources. More than 5,600 conservation partners from small landowners to large corporations have teamed up on 2,644 NAWCA projects to positively affect over 33.4 million acres of habitat. Through the history of the program, NAWCA projects have been implemented in all 50 states. In addition to protecting wildlife habitat, this program improves water quality and generates local revenue by increasing tourism through enhanced outdoor recreation opportunities. This program also creates on average, nearly 7,500 new jobs annually, generating more than $200 million in worker earnings each year.

OPPOSE H.R. 2245: THE CONSERVING ECOSYSTEMS BY CEASING THE IMPORTATION OF LARGE ANIMALS TROPHIES ACT

HSC was an original signer and has joined forces with 31 other conservation organizations to oppose this piece of legislation. This bill represents an ill-conceived attempt to substitute uninformed prejudices for the management strategies of the wildlife authorities successfully conserving the world’s largest populations of lions, elephants and other African species in their range countries. If implemented, H.R. 2245 would undermine some of the most effective strategies for conserving the world’s wildlife.  

OPPOSE H.R. 4804: TO AMEND THE ENDANGERED SPECIES ACT OF 1973 TO PROHIBIT THE TAKING OF ANY ENDANGERED OR THREATENED SPECIES OF FISH OR WILDLIFE IN THE UNITED STATES AND THE IMPORTATION OF ENDANGERED OR THREATENED SPECIES TROPHIES INTO THE UNITED STATES, AND FOR OTHER PURPOSES.

Introduced by Rep. Ted Lieu (D-CA-33), another blanket-approach attempt to halt hunting based on emotion and not science. Rather than a consideration of scientific and statistical analysis of animals listed under the Endangered Species Act or conducting an evaluation of threatened species that may be eligible for removal from the list, uninformed legislators are attempting to disregard hunting as an effective method of conservation and wildlife management.

Houston Safari Club (HSC) is a 501(c)(4) non-profit organization dedicated to legislative and policy initiatives that may affect the future of hunting. HSC supports initiatives that protect the tradition of hunting and hunters’ rights. We take an active role in efforts to effect policy, protocols and legislation. Our mission is to protect the rights of hunters and the hunting heritage through advocacy, policy and legislation. Houston Safari Club (HSC) is a non-profit organization, exempt from federal income tax, under section 501(c)(4) of the United States Internal Revenue Code. Payments to HSC are not deductible as charitable contributions for federal income tax purposes. Please contact your tax advisor concerning deductibility of any payments as business deductions. HSC EIN: 76-0082197. HSC is an independent organization, is not affiliated with Safari Club International (SCI) or its affiliates and is not a chapter or affiliate of any other organization.

October 4, 2019

Dear Mr. Pendley and Chief Christensen:

The undersigned organizations represent millions of hunters, sportsmen and women, and wildlife conservationists who have a long-standing and vested interest in access and opportunities for sportsmen and women on federal public lands.  We are signatories to the Federal Lands Hunting, Fishing and Shooting Sports Roundtable Memorandum of Understanding (MOU) with the Bureau of Land Management (BLM) and the U.S. Forest Service (USFS).  The purpose of the MOU is to build a partnership with the signatories “for planning and implementing mutually beneficial projects and activities related to hunting, fishing, and shooting sports conducted on federal lands.”

We are writing to you as leaders in the implementation of S. 47, the John D. Dingell, Jr. Conservation, Management and Recreation Act (P.L. 116-9). We have identified an issue that could have lasting implications for recreational shooting on BLM and USFS administered lands as a result of the dual enactment earlier this year of S. 47 and S. 94, the Target Practice and Marksmanship Training Support Act (P.L. 116-17). 

Section 4104 of S. 47 provides the Secretaries of the Interior and Agriculture with the authority to lease or permit the use of federal land for a shooting range with certain exceptions.  The exceptions are the leasing or permitting of a shooting range within “1) a component of the National Landscape Conservation System; 2) a component of the National Wilderness Preservation System; 3) any area that is – (A) designated as a wilderness study area; (B) administratively classified as – (i) wilderness-eligible; or (ii) wilderness suitable; or (C) a primitive or semi primitive area; (4) a national monument, national volcanic monument, or national scenic area; or (5) a component of the National Wild and Scenic Rivers System (including areas designated for study for potential addition to the National Wild and Scenic Rivers System).”  The term “shooting range” is not defined and does not exist elsewhere in statute or regulation.

In contrast, S. 94 defines the term “public target range” as a specific location that “1) is identified by a governmental agency for recreational shooting; 2) is open to the public; 3) may be supervised; and 4) may accommodate archery or rifle, pistol, or shotgun shooting.” This definition was specifically designed to assist states in the development of ranges pursuant to the Wildlife Restoration Act (16 U.S.C. 669g and 669h).  We are concerned that in the absence of a definition of “shooting range” in S. 47, the target range definition in S. 94 will be adopted.  Because the target range definition was not designed to be applied to the conduct of recreational shooting on BLM and USFS lands, we wholeheartedly request that a regulatory definition of “shooting range” be written specific to the implementation of S. 47.

it is imperative that certain factors are considered when implementing S. 47 to ensure that the needs of BLM and USFS managers and the public are considered with respect to managing recreational shooting.  For example, there are a total of 28 shooting ranges located on BLM lands throughout the country, with six of these being managed by the agency itself and twenty-one managed under a Recreation and Public Purposes Act (R&PPA) lease. There are no laws or regulations precluding either agency from building infrastructure, such as berms, to support shooting activity separate and apart from the construction of a shooting range.

The ability to build infrastructure that is not as all-inclusive as a traditional shooting range is an important tool for land and visitor use management and should be used to provide managed shooting opportunities for the public. In some cases, it may be useful and appropriate to use these management tools in areas such as national monuments or components of the National Landscape Conservation System. For this reason, we believe it is critical that the target range definition of S. 94 not be used to define the term “shooting range” in S. 47.  Congress had different purposes in enacting these two laws and the regulatory definition for S. 47 should be consistent with and reflect the differences between the underlying statutes.

There are numerous recreational shooting areas on BLM and USFS lands that do not fit the traditional definition or concept of a shooting range. The Federal Lands Hunting and Shooting Sports Roundtable, created by the MOU, identified four distinct types of recreational shooting on BLM and USFS lands that may help guide the development of a definition for “shooting range.”  They are listed in descending order from structured to dispersed recreational shooting venues.

1. DESIGNATED SHOOTING RANGES:

Developed and managed areas designed and operated specifically for recreational shooting. These areas include significantly modified landscapes and infrastructure such as shade structures, benches, a designated firing line, trash containers and restrooms specifically placed to facilitate recreational shooting, firearms training, archery or other associated activities.

2. DESIGNATED SHOOTING AREAS:  

Areas where the land management agency has made some improvements to the area and post and/or advertise them as a site for recreational shooting. They are unsupervised and may have limited infrastructure such as manmade berms, backstops and target holders and trash containers to support target shooting and visitor use.

3. UNDESIGNATED SHOOTING AREAS: 

Areas which frequently attract recreational shooters due to the presence of manmade or natural landscape features that provide shooting opportunities and are easily accessed due to their proximity to roadways and other designated routes that facilitate visitor use.

4. Dispersed recreational shooting:   

Shooting that takes place at undefined locations on public lands with no infrastructure provided to accommodate recreational shooting that occurs consistent with existing regulations found at 43 CFR Sec. 8365.

We are taking the liberty of offering a proposed definition of “shooting range” for the BLM’s and USFS’s consideration.  It is as follows:

  1. A shooting range is a managed location on federal lands set aside for the purposeful discharge of legal firearms including one or more of the following: rifles, pistols, shotguns.  A shooting range may also include archery.
  2. A shooting range must meet the following criteria:
    •  It must be developed, supervised and operated for public recreational shooting.
    • It must be developed, supervised and operated for training and competition.
    • It must be accessible to the public and properly maintained.
  3. Federal agencies providing a shooting range may contract or subcontract with persons or corporations to supervise and operate such areas with the stipulation that they must provide public shooting, competition and training opportunities.

In addition, we recommend that this or a similar definition be applied to projects that were initiated on or after March 12, 2019, the effective date of S. 47. Taking this step will preclude the closure or decommissioning of any existing shooting range or modified landscape that was developed to manage recreational shooting prior to that date should they exist in one of the exceptions outlined in Section 4104 of S. 47.

We believe the proposed definition is consistent with the intent of Congress when passing the S. 47 while, at the same time, providing BLM and the USFS with the tools needed to effectively manage in a manner that meets the public’s needs, including those of America’s sportsmen and women.  We look forward to working with you as you move forward with implementing S. 47. 

Sincerely,

Archery Trade Association
Boone and Crockett Club
California Waterfowl
Congressional Sportsmen’s Foundation
Conservation Force
Council to Advance Hunting and the Shooting Sports
Delta Waterfowl Foundation
Houston Safari Club
Masters of Foxhounds Association
Mule Deer Foundation
National Association of Forest Service Retirees
National Rifle Association
National Shooting Sports Foundation
National Wild Turkey Federation
National Wildlife Federation
Public Lands Foundation
Quality Deer Management Association
Rocky Mountain Elk Foundation
Safari Club International
Sportsmen’s Alliance
Whitetails Unlimited
Wild Sheep Foundation
Wildlife Management Institute
Wildlife Mississippi

Cc: Jim Cason, DOI Associate Deputy Secretary
James Hubbard, USDA Undersecretary for Natural Resources and Environment
Casey Hammond, DOI Acting Assistant Secretary for Land and Minerals Management Sue Spear, Director, USFS Wilderness and Wild and Scenic Rivers                    

American Woodcock Society * Archery Trade Association * Association of Fish and Wildlife Agencies * Boone and Crockett Club * California Waterfowl * Camp Fire Club of America * Congressional Sportsmen’s Foundation * Conservation Force * Council to Advance Hunting and the Shooting Sports * Dallas Safari Club * Delta Waterfowl Foundation * Ducks Unlimited * Houston Safari Club * Izaak Walton League of America *
Masters of Foxhounds Foundation * Mule Deer Foundation * National Association of Forest Service Retirees * National Shooting Sports Foundation * National Wild Turkey Federation * National Wildlife Federation * North American Falconers Association * North American Grouse Partnership * Orion – The Hunter’s Institute * Pheasants Forever * Pope and Young Club * Quail Forever * Quality Deer Management Association * Ruffed Grouse Society * Safari Club International * Texas Wildlife Association * Theodore Roosevelt Conservation Partnership * Whitetails Unlimited * Wild Sheep Foundation * Wildlife Forever * Wildlife Management Institute * Wildlife Mississippi


October 2, 2019

The Honorable Sonny Perdue
Secretary
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, D.C. 20250

Dear Secretary Perdue,
As you know, the Agriculture Improvement Act of 2018 (the 2018 Farm Bill) continues and expands the Conservation Reserve Program (CRP) by increasing the statutory cap to 27 million acres by FY2023, up from the cap of 24 million acres set by the last farm bill. This increase in acreage was considered a major gain for sportsmen and women across the nation, with the potential for increased habitat and improved hunting access. However, as the fall hunting season approaches, we believe it is urgent to express our concerns regarding CRP implementation.

CRP has proven to be one of the most successful conservation programs in American history, providing a wide range of wildlife, water quality, and soil health benefits, as well as being a powerful tool for flood, drought, and wildfire mitigation. Ensuring consistent access to CRP increases farm resiliency while providing the public benefit of habitat restoration, water quality improvement, and sustainable wildlife populations.

Conservation programs like CRP are an integral part of the safety net for rural America, both financially and ecologically, and provide significant economic and societal benefits. This includes providing hunter access for economically significant game species such as pheasants, ducks, mule deer, and other wildlife – access that would decrease significantly with a reduction in CRP acres enrolled. For big game species in particular, CRP can provide vital corridors between large blocks of habitat on federal and private lands.

In addition to opportunities for routine grazing and managed haying, lands enrolled in CRP also provide emergency forage during natural disasters, further demonstrating the value of this program to ranchers and rural communities.

Unfortunately, recent implementation of CRP has hindered efforts to create and restore wildlife habitat and implement water quality and wetland practices on private lands. Despite the statutory cap for FY2019 of 24 million acres, according to the Farm Service Agency’s July 2019 CRP summary, there are only 22.35 million acres enrolled in the program. This shortfall of 1.65 million acres will only be compounded by 15 million acres set to expire between now and September 2023. Without quick, bold action from USDA, this could lead to a devastating loss of habitat for wildlife populations and resulting loss of hunting opportunities. With such a significant number of acres set to expire in the next four years, it is critical that USDA maintain enrollment levels as close to the acreage cap as possible to meet demand and provide maximum benefits, and to avoid overwhelming an already taxed agency and unnecessarily impeding implementation of the program in the future.

While we appreciate USDA holding a continuous CRP signup in FY2019, we are very concerned with the decision to yet again limit the scope of the signup by only offering a smaller number of practices to landowners. This includes not offering State Acres for Wildlife Enhancement (SAFE), upland wildlife borders, and pollinator practices – all highly successful and popular initiatives. The recent signup also removes vital cost-share and incentive payments for the remaining available practices, further decreasing demand from landowners to enroll in the program. These same decisions were made during the FY2018 continuous CRP signup, resulting in the smallest continuous CRP signup in nearly 20 years. To ensure successful implementation of CRP contracts, it is critical that landowners be fairly compensated for installing these high-value practices with adequate cost-share and incentives. By limiting the practices available, removing cost-share and incentives, altering how soil rental rates are calculated, and adding a reduction to soil rental rates beyond what was required in the 2018 Farm Bill, we fear that landowner interest in CRP, as well as the program’s effectiveness, will continue to diminish.

In order maintain landowner interest and hunter opportunities, we strongly urge you to:

• Provide details and ranking criteria for the pending FY2020 General sign-up as soon as possible. We recommend a sign-up period that would run from early December 2019 through February 2020 at a minimum in order to give landowners and USDA county offices time to promote the sign-up period and submit bids.
• Make available to landowners the full suite of practices under continuous CRP, including practices under the highly successful State Acres for Wildlife Enhancement (SAFE), upland wildlife borders, and pollinator initiatives. Ensuring that these practices are available would maximize benefits for wildlife habitat, soil health, and water quality while providing landowners with options when considering what is best for their operations.
• Restore practice and signing incentive payments for continuous CRP contracts, as directed by the 2018 Farm Bill. In addition to statutory language directing USDA to offer practice incentive payments for land enrolled under continuous CRP, the Managers explicitly maintained
“incentives for continuous practices, including signing incentives, incentives to provide additional cost-share, and those related to specific practices…for certain high conservation value practices.”
• Restore cost-share for mid-contract management (MCM) on all future CRP contracts. MCM has been an integral component of CRP since the 2002 Farm Bill and is a critical tool for managing conservation cover to its fullest potential for wildlife, soil health, and water quality. The decision to remove cost-share for MCM under the recent continuous sign-up adds an undue burden to landowners for performing important management activities.

Thank you for your consideration, and we look forward to continuing to work with you and your staff to successfully implement this critical conservation program.

Sincerely,
American Woodcock Society
Archery Trade Association
Association of Fish and Wildlife Agencies
Boone and Crockett Club
California Waterfowl
Camp Fire Club of America
Congressional Sportsmen’s Foundation Conservation Force
Council to Advance Hunting and the Shooting Sports Dallas Safari Club
Delta Waterfowl Foundation
Ducks Unlimited
Houston Safari Club
Izaak Walton League of America
Masters of Foxhounds Foundation
Mule Deer Foundation
National Association of Forest Service Retirees National Shooting Sports Foundation
National Wild Turkey Federation
National Wildlife Federation
North American Falconers Association
North American Grouse Partnership
Orion – The Hunter’s Institute
Pheasants Forever
Pope and Young Club
Quail Forever
Quality Deer Management Association
Ruffed Grouse Society
Safari Club International
Texas Wildlife Association
Theodore Roosevelt Conservation Partnership Whitetails Unlimited
Wild Sheep Foundation
Wildlife Forever
Wildlife Management Institute
Wildlife Mississippi

HSC signs onto two letters in support of Recovering America’s Wildlife Act, Land and Water Conservation Fund, Restore Our Parks Act, North American Wetlands Conservation Act, and Modernizing the Pittman-Robertson Fund for Tomorrow’s Needs Act of 2019. AFWA, CSF, DU, IWLA, NWF, NWTF, PF, QF, TRCP, and WSF are original signatories.

Letter to the House can be read HERE 

Letter to the Senate can be read HERE