March 14, 2009

Easement Programs Division
Grassland Reserve Program Comments
USDA Natural Resources Conservation Service
P.O. Box 2890, Room 6819-S,
Washington, DC  20013
Fax:  (202) 720-9689
Email:  grp2008@wdc.usda.gov

RE:  COMMENTS ON GRASSLANDS RESERVE PROGRAM 

Dear NRCS Easement Programs Division,

Wild Farm Alliance promotes a healthy, viable agriculture that protects and restores wild Nature.  Besides providing educational materials and addressing policy issues on a national level, we work with farmers installing conservation practices in California's Central Coast region.  The following comments relate to the WRP as described in the Interim Final Rule:  

*  Limit Wind and Solar Power.  Since energy development can have adverse effects on biodiversity, we concur with NRCS about limiting wind power development on GRP easements to on farm use only.  Additionally, we suggest that solar energy development be treated the same way.    

*  Native Grasslands Prioritization.  We recommend that native grasslands are given the highest priority for program eligibility.  

*  Comprehensive Wildlife Conservation Strategy.  We suggest that NRCS use the Comprehensive Wildlife Conservation Strategies developed for each state in establishing priorities for the Grassland Reserve Program.   

*  Biological Diversity Definition.  We suggest NRCS use the following:  The variety and variability among living organisms native to the ecological subregion and ecological complex.  
  

Sincerely,

/Jo Ann Baumgartner/
Jo Ann Baumgartner
Director