Mark W. Berkland
Director
Conservation Operations Division
Natural Resources Conservation Service

Dear Mr. Berkland,

This letter is being written to comment on the new national Conservation Security Program. It is being written on behalf of the Iowa Prairie Network. The Iowa Prairie Network is a statewide organization of Iowans whose mission is to learn about, teach about, enjoy, and protect Iowa's prairie heritage.

We are very pleased that "prairie land" and "rangeland" are specifically included as eligible lands within the Conservation Security Program. This inclusion is welcome and is very important for addressing national resource concerns.

Native prairies are vital resources for livestock grazing and outdoor recreation. Prairies are also very effective at protecting soil and water resources and sequestering carbon. Their remarkable soil structure provides important agricultural research information.

Unfortunately, native prairies and grasslands continue to degrade and disappear across the United States. Grassland-dependent birds are the fastest-declining group of North American birds, and many prairie plants and animals are federally-listed, state-listed, or approaching listed status. Private landowners are the key to stopping this resource loss, since most prairies are privately owned.

Prairie lands have not fared well under previous Farm Bills, which have strongly encouraged their conversion to rowcrop production. And while some Farm Bill conservation programs, such as WHIP, have helped to restore native prairies, the Conservation Reserve Program has inadvertently encouraged native prairie destruction by requiring tree plantings on riparian marginal pastures and by allowing enrollment of prairie areas plowed up within the last three years.

The Conservation Security Program offers a new opportunity to encourage and reward the conservation of prairie lands by private landowners. To ensure that prairies will meet the CSP goal of non-degradation and will fare well under the CSP, the following measures are needed:

1. CSP rules and practices need to be targeted to the resource needs of specific ecological regions, which often encompass parts of several states. The country should be divided into appropriate ecological regions, using one of the federal agency ecological classification systems already in place. For each ecological region, natural resource needs and priorities should be identified on the national level. Then the same process should take place within each state, with further refinement of concerns and priorities on the local level.

Within ecological regions identified as prairie regions, emphasis should be placed on protecting and enhancing existing native prairies. Rules should ensure that woody plantings are encouraged only on woodland soils.

2. CSP rules should recognize that according to current research, carbon sequestration is a function of grasslands as well as trees, and that carbon sequestration on prairie soils is best accomplished through prairie plants. The CSP should recognize and protect the carbon-sequestering functions of native prairies and prairie plantings.

3. CSP rules should incorporate the knowledge that more than one resource function can and should be provided by a given piece of working land. Well-managed native prairie pastures, for example, can provide habitat for prairie plants and animals as well as sustainable grazing, while also protecting water and soil and sequestering carbon. CSP rules need to encourage working lands to be managed for multiple resource benefits.

At a minimum, emphasis on a single resource function should not result in degradation of other resource functions. For example, landowners should not be paid to destroy native prairie pastures with tree plantings in the name of carbon sequestration. It is particularly important for CSP rules to value the wildlife habitat and biodiversity resource functions of native prairies, and prevent the degradation of those functions, since those functions are already in serious national jeopardy.

4. CSP rules should incorporate the knowledge that some natural resource functions are much more uncommon and difficult to replace than others. For example, a never-plowed native prairie pasture with a diversity of plant species is very difficult to replace, in terms of resource functions and structure. It cannot be replaced by a Conservation Reserve Program planting. Landowners should be especially encouraged to achieve non-degradation goals on land containing resource functions that are difficult to replace, such as areas that contains a diversity of native species, areas that contain rare species, and areas (such as native tallgrass prairie remnants) that are uncommon in and of themselves.

5. CSP rules should incorporate the recognition that a bundle of practices may be needed to achieve non-degradation goals on a given piece of land. To prevent degradation of a prairie pasture, for example, it may be necessary to modify grazing pressure, apply periodic burning, and institute active control of invasive trees, shrubs, and exotic species. To the extent that several practices are needed to address "conservation concerns" in a given ecological region, and to achieve the goal of non-degradation for important natural resources, as specified by Congress, all those practices should be eligible for the CSP.

6. CSP evaluation measures should include evaluations of how well the CSP is working to encourage the protection and good management of prairie lands, whether CSP rules are effectively preventing the subsidizing of woody plantings on prairies, how well CSP management practices are preventing the degradation of native prairies, and whether the overall goal of non-degradation is being achieved for prairie land and rangeland enrolled in the CSP.

Thank you for considering these comments.

Inger Lamb
President
Iowa Prairie Network

PO Box 572

Nevada, IA

50201