WASHINGTON — An option that would significantly reduce area included in the Conservation Reserve Program was strongly advocated by the National Grain and Feed Association in recent comments to the U.S. Department of Agriculture.

The group was responding to a notice published in the Feb. 19 Federal Register, seeking comments about potential changes to the Conservation Reserve Program. The request was submitted following completion of a Draft Supplemental Environmental Impact Statement examining environmental consequences of changes to the program.

Changes to the C.R.P. are authorized under the Food, Conservation and Energy Act of 2008.

Of three policy options presented in the notice, the National Grain and Feed Association favors one that would reduce the area in the C.R.P. to 24 million acres from the 32 million acre cap. Within that option, the N.G.F.A. urged the Department to allocate more than the 4 million acres to targeted signups of the most environmentally sensitive land using buffer strips, grassed waterways and other conservation methods.

In its comments, the N.G.F.A. called for “much-needed fundamental reform of the C.R.P.” The group said it was “flawed, erroneous and short-sighted” to assess the C.R.P.’s environmental benefits “in isolation and in a vacuum” without also factoring benefits from other U.S.D.A. conservation programs, modern agricultural tillage practices and conservation requirements imposed under U.S.D.A. farm programs.

Putting the program into perspective, the N.G.F.A. described the C.R.P. as the nation’s fourth largest U.S. “crop” in acreage terms. The 32 million acres in the C.R.P. lag only corn, at 86.5 million acres in 2009; soybeans, 77.5 million; and wheat, at 59.1 million. Planted area does not exceed 10 million acres for any other major crop (though 60 million acres of hay are harvested each year).

“If U.S. agriculture is to achieve economic growth, which in turn contributes to job creation and revitalization of rural communities, it is imperative that the C.R.P. be right-sized and reformed,” said Kendell W. Keith, president of the N.G.F.A. “The idling of productive land resources cuts off the economic multiplier inherent in crop, livestock and poultry production, thereby costing jobs and suffocating economic vitality in rural communities. Further, it risks compromising the United States’ ability to provide abundant, affordable and cost-competitive food, animal feed, exports and biofuels.”

The N.G.F.A. said the two other policy options offered in the proposal each calls for enrolling 32 million acres in the C.R.P., the maximum allowed by Congress under the 2008 farmer law during the 2010-12 period.

“The N.G.F.A. continues to believe a more focused C.R.P. targeted on the most environmentally sensitive lands can be a positive contributor to the long-term success of U.S. agriculture while providing environmental benefits,” the association said.

Several industry groups have sought changes in the C.R.P., without success, for many years. The N.G.F.A. restated its belief in additional reforms, including provision for additional flexibility for acres to exit the C.R.P. before contract expiration if economic conditions warrant and with the consent of the producer/land owner and the U.S.D.A.

“Under this concept, the most environmentally sensitive land enrolled in the C.R.P. would remain ineligible for early contract termination,” the N.G.F.A. said. “But producers would have the flexibility to take advantage of new market opportunities without being saddled with economically punitive penalties for removing tillable, environmentally sustainable acres when market demand signals a compelling need for additional crop production. Currently, C.R.P. rules impose economically prohibitive and insurmountable barriers for landowners attempting to restore to crop production tillable land that can be farmed in environmentally sustainable ways.”

The N.G.F.A. also suggested that once C.R.P. acres are exited or expire, base-acre histories would be fully restored, allowing growers to benefit from farm programs. Another N.G.F.A. suggestion was for early preparation of C.R.P. land near contract expiration or nearing eligibility for early contract termination.

“U.S. agriculture needs a C.R.P. that is balanced and effective, recognizes the totality of conservation benefits accrued through a wide range of other U.S.D.A. conservation programs (including those focused on working farmlands), takes into account the conservation practice requirements imposed under federal farm programs, and does not operate at cross-purposes with a healthy commercial U.S. agricultural sector that is so vital to rural development, job creation and economic growth,” the N.G.F.A. said.