MISSOURI DEPARTMENT OF CONSERVATION 
Headquarters 
2901 West Truman Boulevard, P,O. Box 180, Jefferson City, Missouri 65102-0180 
Telephone: (573) 751-4115, Missouri Relay Center: 1-800-735-2966 (TTY) 
JOHN D. HOSKINS, Director
COMMISSION
DON R. JOHNSON, Festus 
CHIP McGEEHAN, Marshfield 
LOWELL MOHLER, Jefferson City 
BECKY L. PLATTNER, Grand Pass 

January 23,2009  


Conservation Technical Assistance Programs Division 
US Department of Agriculture 
Natural Resources conservation Service 
Room 6015-S 
1400 Independence Avenue, S. W. 
Washington, DC 20250-2890 

Dear Director: 
The Missouri Department of Conservation is a state agency responsible for the management of fish, 
forest and wildlife resources in the state of Missouri. The Department provides technical assistance to 
USDA-NRCS for the implementation of Farm Bill conservation programs. We offer the following 
comments for Docket Number NRCS-IFR-08010, State Technical Committee, posted in the Federal 
Register: 

1) Rule page 71524, Summary of Provisions: "NRCS invites comments regarding the 
interaction of Local Working Groups with State Technical Committees and wlth NRCS at 
both the local and State levels. The NRCS also invites comments regarding the State 
Technical Committee review of whether Local Working Groups are addressing the priorities 
established by the State Technical Committee." 

We agree with requiring a review of Local Working Group priorities to ensure that state priorities are 
being addressed. 

We also agree with the rule in 610.25 (b) requiring Local Working Groups to be composed of a cross 
section of conservation and agriculture interests to best insure'that ALL conservation issues are 
addressed. 

Not all local working groups in our state are currently composed of such a cross section, resulting in a 
lack of due consideration for all resources in some counties. Such a requirement can build good will 
among participants and assist in addressing issues before they need regulatory intervention. 

2) In 610.22 state technical committee membership (a)@), the statement that agricultural 
producers need to have some level of consenration expertise was removed. 

Recommendation: 
Revise 610.22 (a)(8) as follows: "State Technical Committees shall include agricultural 
producers with demonstrable expertise working with Farm Bill conservation programs, . .. ." 
This language is consistent with other elements of the same section and needed to aid in 
committee deliberations. 

3) In 610.22 state technical committee membership (b) 
Recommendation: 
Suggest adding USFWS as an example. Their participation is needed on regular basis to 
ensure that agriculture and conservation interests are informed about potential issues with 
federal listed species. In addition, several USFWS private land programs are complementary 
of USDA programs. 

4) In 610.22(d) "Decisions of the State Consetvallionist concerning membership an the 
committee are final and not appealable to any other individual or group within USDA." 
Recommendation: 
This statement should be further clarified by inserting the word 'individual' before the word 
'membership' as it currently gives the impression that it pertains to'the entire membership of 
the committee. This will be difficult for a State Conservationist because membership is fluid 
with new farrnerslranchers, new landowners, new industries and agribusiness interests, as 
well as new wildlife and conservation groups emerging. 

5) 610.24 responsibilities of state technical committees- within (c) "state technical committee 
shall review whether local working groups are addressing state priorities." 
Recommendation: 
Add "the State Conservationist shall address the concerns of the State Technical Committee" 
to ensure that follow up is always conducted. 

6) 610.24 Responsibilities of State Technical Committees (a) 
Recommendation: 
Add the following to the list of recommendations to be addressed by the State Technical 
Committee: 
Conservation practices and practice standards 
State-specific program policies 

7) In 610.25 subcommittees and local working groups (a) 
Recommendation: 
To ensure that all state and local technical working group members have the opportunity to 
participate, if desired, we suggest adding a statement requiring the State Conservationist to 
open the invitation to participate in subcommittees to the entire State Technical Committee. 
The Missouri Department of Conservation appreciates the opportunity for comment. If you require 
additional information, please contact Private Land Programs Supervisor, Bill White at 573-522-4115, 
Ext. 3512. 

Sincerely, 

/S/

JOHN D. HOSKINS
DIRECTOR

c: Private Land Programs Supervisor Bill White