National Association of Conservation Districts

Comments

Dear Ms. Harper:

The National Association of Conservation Districts (NACD) is pleased to submit comments on behalf of the nation’s 3,000 conservation districts relative to the U.S. Forest Service Open Space Conservation Strategy and Implementation Plan.

Across the United States, nearly 3000 conservation districts are helping local people to conserve land, water, forests, wildlife and related natural resources. Established under state law, conservation districts are local units of government charged with carrying out conservation programs at the local level. We share a single mission: to coordinate assistance from all available sources -- public and private, local, state and federal -- in an effort to develop locally driven solutions to natural resource concerns. Working directly with more than 2.3 million cooperating land managers nationwide, their efforts touch more than 778 million acres of private land.

In response to Federal Register Docket 06-9688, NACD offers the following comments :

Protecting Against Land Fragmentation and Loss of Open Space

Through partnerships, the Forest Service can help private landowners protect their land from fragmentation and conversion to alternate uses. The Forest Service should strengthen partnerships with other agencies within the USDA, such as the NRCS and FSA, who currently administer conservation programs that encourage management activities that foster open space characteristics on private lands and promote strong conservation ethics among participants.

Similar to many Federal agencies, the Forest Service lacks a Federal work force delivery system to channel both technical and financial assistance to landowners. Because allocation of land use and management of private land are local decisions, partnering with Conservation Districts in addition to existing efforts with the State Foresters is encouraged.

Conservation districts are part of a delivery system that provides information and technical and financial assistance to private landowners and operators and private organizations and businesses, in coordination with government entities. Their work has provided the American public with unparalleled benefits in the form of more productive soils, cleaner water, purer air and more bountiful fish and wildlife habitat.

NACD strongly believes that a producer must have an economically viable operation to be able to make an investment in conservation practices on their land. The biggest threat to maintaining open space is land fragmentation. When large landowners are forced to sell due to development pressures and declining market opportunities, the ecosystem services such as clean air, clean water, wildlife habitat, and sustainable forest products are removed from the land when replaced by urban development. The Forest Service should work to encourage new markets for woody materials as well as encourage easement programs and other alternatives to at-risk landowners.

In many western states, the Forest Service supports livestock grazing on National Forest System lands (National Forests and Grasslands). Many western cattle ranchers depend on Federal grazing permits for the livelihood of their operation. Through management of both public and private lands, these ranches provide certain services to the American taxpayer such as open space, clean air and water, wildfire prevention, as well as supporting the economic infrastructure of this nation’s rural communities. Continuation of the Federal grazing permit program is vital to the long term sustainability of these operations and open space conservation.

The Forest Service should consider expanding research efforts to identify forces that act as disincentives of family forest ownership. Additional research is needed to clearly identify factors such as the effect of estate taxes on family forests, development pressures, declining forest health and ecological values, and effects of other federal state and local policies contributing to the increased rate of land sales. This type of data would be useful for local land planners, current, and future landowners to better understand long term ownership objectives and management strategies.

Assisting Private Landowners in Sustainable Management Practices and Mitigating Impacts of New and Existing Development

The Forest Service Urban and Community Forestry should be strengthened to help mitigate the impacts of existing and new developments. In urban settings, trees mitigate temperature extremes, air pollution and flooding. Without them, communities spend millions of dollars in heating, cooling and storm-water management costs while the quality of air, soil and waterways declines. Conservation districts, which historically have been active in soil and water conservation on farmlands and forests, are increasingly involved in resource management issues in urban and suburban areas. Again, partnerships should be encouraged to assist in the delivery of technical assistance to urban, small-acreage landowners.

The Backyard Woods program has been developed through a partnership with the Forest Service, National Arbor Day Foundation, and National Association of Conservation Districts. To help leverage the success of this program, the Forest Service should consider coordination of this program with NRCS and their "Backyards Conservation" efforts. Future programs and educational materials like Backyard Woods can be very useful in helping suburban landowners develop management plans that result in wildfire protection, increased wildlife habitat, and clean water.

The National Association of Conservation Districts appreciates the opportunity to provide comments on the Forest Service Open Space Conservation Strategy and Implementation Plan. We look forward to fostering future partnerships with the Forest Service to promote conservation of our nation’s forests, grasslands, and natural resources.

Sincerely,

Bill Wilson
President



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