The Buffalo River Stewardship Foundation would like to express our support for the goals of the NRCS Watershed Plan. Our comments concentrate on these areas:
• The purpose of maintaining water quality should be more explicitly stated;
• NRCS funds should be focused on actions which achieve the Plan’s purpose;
• Economic recreational value (versus financial value) should be the basis for calculations.
The purpose of the NRCS Watershed Plan is to protect water quality in the Buffalo River and to promote agricultural practices in the Buffalo Watershed which achieve that goal. That purpose is mentioned in passing in the Plan, but we suggest that it be explicitly used as the means to determine policy in the written Plan and in its implementation.1 We suggest further that the Plan explicitly state that the NRCS will undertake no action which would harm water quality in the Buffalo River, and that the NRCS will discontinue any actions taken under this Plan which are demonstrated to impair water quality in the Buffalo River.2
We assume that the Plan’s purpose implies these actions:
• No land in riparian corridors shall be cleared for pasture;
• No land clearing will be done on steep slopes (over 15%).3
We assume that the NRCS will encourage these practices to maintain water quality:
• Improved methods for treating animal waste to minimize fecal contamination;
• Establish cattle watering ponds to avoid grazing in or near tributaries;
• Replace cold-weather grasses (fescue) with warm-weather grasses (bermuda) in order to minimize cattle manure direct deposit resulting from fescue toxicosis;
• Establish practices for chicken litter application which minimize runoff;
• Encourage the use of other “Best Management Practices.”4
We would prefer to see the list of actions as an explicit part of the Plan’s purpose, and to see the purpose permeate thinking about policies resulting from this Plan.5
The following list indicates where the BRSF sees disagreement between the purpose of the NRCS Plan and the actions recommended.
Forested riparian corridors for buffering runoff
• NRCS proposes “establishment of 34 miles of buffer or filter strip.” Grass cannot adequately serve as a buffer or filter.6
• A grass buffer strip will not succeed at the stated purpose of “controlling erosion, filtering sediment, and nutrients, [and] products of animal waste.” BRSF suggests permanent vegetation consisting of trees or heavy brush.7 & 9
Modeling the width of 100-foot wide buffer strips
• We question the NRCS computer model’s conclusion: “on a 3% slope, a 45 foot grassed buffer would achieve 74.9% reduction” in manure transport. It seems NRCS ran the model for cattle manure only, but applies the effectiveness figure to all other forms of runoff. The 74.9% reduction figure seems high for other forms of runoff and should not be used as a basis for a decision to use 45 foot strips and to use grasses. 10
• Even if the 74.9% figure is correct for manure runoff, the NRCS should attempt to achieve a greater reduction in manure runoff. NRCS indicates that manure is the source of 89% of all fecal contamination, so reducing more manure runoff would have the greatest effect in decreasing fecal content in the river. 11
Maintaining forested acreage on steep slopes
• NRCS “considers slopes over 15% to have serious resource concerns.” We suggest the more explicit: “Slopes over 15% shall not be cleared for pasture, and the NRCS will assist in reforesting land with slopes over 15% which has already been cleared.” 12
If commenters may vote for one alternative or another, the BRSF expresses its strong support for Alternative 3.14 The particular reasons are:
• The Plan says that “about 200 acres of pasture will revert to riparian and 500 acres of poor pasture will be put to trees. An additional 13,000 acres of warm season grasses will be seeded.” These measures will greatly improve water quality.
• The Plan says that 500 acres of pine trees will be planted in gullies, and all buffer strips will be widened to 100 feet. We support those additions to Alternative 2. We also support the proposed installation of 230 livestock watering facilities.
The BRSF would like to see more of the NRCS funds used for conservation easements. The current Plan budgets only 11% of the available funds for easements; we would like to see 50%. Conservation easements which would establish 100-foot wide forested riparian corridors seem to us the best means of minimizing runoff into tributaries. We support the NRCS conservation easement plan and wish to see it expanded. We offer our financial support below.15
The BRSF is concerned that funding might be used to expand pastureland to areas which would impair water quality (especially riparian corridors and steep sloped land). Such pasture expansion would be counter to the purpose of the Watershed Plan and should not be funded. Creating new pastures can damage the river if managed improperly.
The Plan states that poor pasture management causes manure to enter tributaries, mostly because “pastures are commonly overgrazed with concentrated abusive grazing along riparian areas.” The BRSF agrees with this conclusion and would prefer to see all NRCS funds used to improve pasture management techniques, and to convert damaged pasture back to forest, rather than to create more pasture. We are concerned that NRCS funds will result in freeing up other funds which would increase cattle population and deforestation for pastures elsewhere in the watershed.17
The BRSF is also concerned that providing NRCS funds to owners of damaged land will reward those owners for poor management in the past. Landowners would know that they could degrade their land and be bailed out by the federal government later. The BRSF would prefer to see NRCS funds go to “good stewards” of the land, who have taken good care to manage their pastures well, but need funding to implement the best management practices.18 Most landowners in the Buffalo watershed are good stewards, and NRCS funds which benefit them would benefit the river as well. We point out that rehabilitation of damaged land is much more expensive than preventing degradation of land that has been maintained fairly well.
The Plan states “annual recreation visitor days with a total value of $2,600,000.” This figure represents the net financial income due to recreational use of the study area. The financial income is only one component of the economic value of recreation on the Buffalo River. People value their recreational activities more than they pay for in cash, and we estimate the “non-financial recreational value” at about ten times the financial recreational value. People also value the existence of clean water in the Buffalo River, and we estimate the “existence value” at about one-and-a-half times the financial value.19 These estimates are substantiated in the BRSF Socioeconomic report cited in the NRCS Plan.
Applying those ratios to the NRCS financial figure of $2,600,000 results in a non-financial recreation value of $25,200,000 and an existence value of $4,000,000 for the study area. The total economic benefit resulting from visitor recreation is therefore $31,800,000. We would like to see the full economic value of recreation described somewhere in the Plan.
The BRSF would like to stress the points where we agree strongly with the NRCS Watershed Plan.
• The Plan states that “Approximately 89% of the fecal coliform ... are from agricultural sources.” The Plan states that 0.8% of bacteria loading comes from human recreational activities. At the NRCS meeting on this Plan, these figures were disputed, and a questioner stated that human recreation was the prime source of bacteria. All evidence available to the BRSF indicates that the NRCS figures are correct: the primary source of fecal coliform in the Buffalo River is cattle grazing, and human recreational activities contribute only a very small percentage.
• NRCS states that “Projected trends in water quality indicate impaired water quality caused by nonpoint source pollution from animal waste will result in a projected $593,000 loss of annual recreation benefits (tourism) within the Buffalo River National Park.” The BRSF re-emphasizes that improper treatment of animal waste causes financial losses, not just environmental damage.
• The Plan reads “The NRCS does not participate in clearing land which is unsuitable or difficult to manage as pasture or unsuitable for uses other than forest.” The BRSF agrees wholeheartedly with that statement, and points out its implications:
• Pastures in riparian corridors are difficult to manage and should be forested;
• Steep slopes are unsuitable for uses other than forest.
• The NRCS Plan quotes former Governor Orval Faubus, “The Buffalo River is one of the greatest examples of the majesty of God’s Creation.” The BRSF agrees and hopes that it is kept in mind when making policy concerning pollution runoff entering the river.
The BRSF would like to participate in the “conservation easement” program where a 25% “sponsor contribution” is required.20 We repeat our offer from the April NRCS meeting, requesting notification of pending conservation easements so we may consider participating. We would consider any NRCS easements which fulfill the purpose and methods described above.
The BRSF would also consider participating financially in implementation of Best Management Practices, if the NRCS ends up contributing less than 100% of the costs of those programs as well. Other programs we would consider are:
• Switch over from fescue grass to bermuda grass (warm-weather re-seeding);
• Reforesting pastures on steep slopes, gullies or sinkholes;
• Funding technical assistance for swine CAFOs to meet waste management plans;
• Funding proper management to use animal waste (as fertilizer) properly;
• Exploring innovative technology to deal with animal waste;
• Funding other “Best Management Practices.”
The BRSF would provide technical support for these programs, may provide volunteer membership services for assistance in implementation, and would consider contributing financially to BMP programs in the future. We would appreciate the opportunity to learn from the expertise of farmers and the NRCS in matters of Best Management Practices.
Finally, the BRSF would like to extend an offer to the NRCS to participate in the Buffalo National River Watershed Council.21 The Watershed Council fosters cooperation and coordination of all relevant agencies in the Buffalo watershed. The Council includes representatives of government agencies plus representatives of private groups and individuals. The Watershed Council is an integral part of an effective overall management plan, and hence fits well with the goals of the NRCS Plan. A successful Watershed Council would enhance management of resources both for the NRCS and for the Buffalo watershed as a whole.
Jesse Gordon is the Director of Economics for the BRSF. He holds a degree in Environmental and Development Policy from Harvard University.
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