Carlsbad Soil & Water Conservation District 
3219 S. Canal, Carlsbad, N.M. 88220 Phone: 505-628-1532 Fax: 505-885-5386 
January 12,2009 
Conservation Technical Assistance Programs Division 
US Department of Agriculture 
Natural Resource Conservation Service 
1400 Independence Avenue, SW 
Room 6015-S 
Washington, DC 20250-2890 
RE: Docket Number NRCS-IFR-080 10 
To Whom It May Concern: 
The Carlsbad Soil and Water Conservation District (SWCD) appreciate the opportunity to 
comment on the State Technical Committee regulation that was published in the Federal Register 
on November 25, 2008. Carlsbad SWCD is one of 47 conservation districts within the State of 
New Mexico. Established under state law, conservation districts are local units of state 
government charged with carrying out programs for the protection and management of natural 
resources at the local level. Conservation districts work with federal, state, and other local 
agencies to provide programs and technical assistance to landowners and other partners to 
address natural resource issues. 
State Conservation District Associations participate in the State Technical Committee as outlined 
in the law and the Federal Register Proposal and we look forward to continuing that working 
relationship at the state level. We understand that the State Technical Committee may operate 
slightly differently in each state, and has been very successful in New Mexico. Good 
communication between the State Conservationist, State Technical Committee, and Local Work 
Groups is essential. The Local Work Group provides recommendations to the State 
Conservationist and the priorities or practices are presented to the State Technical Committee. 
We believe that this communication is essential to the recommendation process and the value of 
the work of the Local Work Groups and the State Technical Committee. 
The Local Work Group processes have been used for Conservation Title programs since the 
1996 Farm Bill and have been implemented in varying degrees. The process of locally 
identieing important resource issues and addressing them with federal, state, local, and private 
resources has been going on since the formation of districts. The programs provided by the 
Conservation Title and the local work group process is a backbone of locally led conservation. 
With the new Farm Bill provisions, what in the past have been two groups - the Local Work 
Group and the Stakeholder Input Group can be combined into one Local Work Group, convened 
by the local conservation districts, including all government officials and local stakeholders. 

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Working together to assure that the technical solutions used to resolve resource concerns actually 
work in the area and providing localized options are critical components of achieving the full 
conservation impacts and environmental benefits. SoRware and national policies must provide 
enough flexibility and transparency to allow for options to be available based on local needs 
while assuring that program and hnding accountability is maintained. 
Carlsbad SWCD recommends that local conservation districts convene Local Work Groups. 
NRCS has established this process through past guidance and we feel it should continue under 
these new authorities and regulations. Conservation Districts have a history of convening Local 
Work Groups annually and undertaking the locally led planning process in their communities. 
The changes in the 2008 Farm Bill combine these two processes into one effort and local 
conservation districts are uniquely positioned to undertake the process of bringing everyone 
together to provide input. 
As to the recommendation on the publication of meeting notices and agendas for the Local Work 
Group and the State Technical Committee there are a variety of options that can be utilized at 
both the state and local level, depending upon availability. Our recommendations include: 
Local or state newspaper as appropriate 
Websites of NRCS, State Associations, and Conservation Districts 
Broadcast on local Farm Radio or other local news outlets 
Email past attendees and those that have expressed interest to the State Conservationist 
Publication in commodity, conservation, environmental or other community or state 
newsletters/magazines 
Regarding the interaction of the Local Work Group with the State Technical Committee and with 
NRCS, we do not feel it is appropriate to expect the State Conservationist to be present at all 
Local Work Group meetings. We believe that NRCS should be represented by NRCS line 
officers, the District Conservationist at a minimum and the Area Conservationist if possible. As 
subcommittees of the State Technical Committee, the Local Work Groups (as written in the 
Federal Regzster notice) would provide a report to the State Conservationist and a summary of 
all Local Work Group meetings would be presented during the State Technical Committee. 
Regarding the report of the Local Work Group, we recommend that the Conservation District, as 
the convener of the Local Work Group provide a report to the District Conservationist, the State 
Conservationist, and the State Technical Committee. 
Additionally, there needs to be communication from the State Conservationist regarding the 
priorities established by the Local Work Group and the report submitted. If recommendations 
from the Local Work Group are not incorporated into the USDA program delivery system, the 
NRCS line oficers including the District Conservationist, the Area Conservationist, or the State 
Conservationist, should inform the members of the Local Work Group as to the reasoning behind 
the decision. We believe that proper communication in this area will also help to address 
provisions in the 2008 Farm Bill regarding the State Technical Committee review of whether 
Local Work Groups are addressing the priorities established by the State Technical Committee. 

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If the Local Work Group priorities and the State Technical Committee recommendations are 
substantially different, there must be communication from the State Technical Committee and 
the State Conservationist as to the reasoning for their decision. 
The Carlsbad SWCD appreciates the opportunity to provide input on this regulation and would 
be happy to address any questions. 
Ridley Gardner, Chairman 
RG:jb