1 01/22/2009 TIN 20:07 FAX 605 895 9424 BANKWEST INS PRESHO South Dakota Association of Conservation Districts PO Box 275 1 16 N Euclid Avenue Pierre, SD 67501 -0275 E-mail: sdacd.rnail@sdconseivation.org January 22,2009 Conservation Technical Assistance Programs Division US Department of Ag~iculture Natural Resources Conscrvation Service 1400 Independence Avenue, S W Room 601 5-5 Washington, DC 20250-2890 Fax: (202) 720-2998 RE; Docket Numbcr NRCS-IFR-080 The South Dakota Association of Conservati on Districts appreciates f he opportunity to com,ment on t11c State Technical Committee draft regu'lation published in the :Federal Register on November 25,2008. The Association and its 69 conservation district members actively participate in South Dakota's State Technical Cornmi.ttee as outlined in the Federal Register. We look forward. to continuing what we feel is a successful process in South Dakota. Our process may be different slightly different than the processin other states but it is successful. We especially appreciate the use of subcommittees witlzin the State Technical Committee to address specific programs. The subcommittees are diligent about fully addressing thc issues related to a specific program and then reporting back to the full State Tecluxical Committee the results of their discussion and their recommendations for further action. The State Technical Committee and the program-specific subcommittees take seriously the re~ommendations and suggestions offered by the Local Work 01/22/2009 THCT 20:08 FAX 605 895 9424 BANRWEST INS PRESHO Our local work groups operate on the conservation districl level and then come together on a watershed basis to share their priorities and recommendations. This has worked cxtrcmcly well and we hope can continue in the future. As to the recommen.dations on the publication of meeting notices and agendas for the Local Work Groups and State Technical Committees, we use a variety of options on both the state and local level, as appropriate. We use local, regional and state newspapers; NRCS, conservation, and stakeholder websites; mass-e-mails to those who have expressed an interest or attended previous meetings; local radio andlor television public service announcements; and inclusion in commodity, conservation, environmental or community print or electronic media rekases. We recomnend these methods continue to be available. Regarding the interaction of the Local Work Group with the State Technical Committee and with WCS, we do not feel it appropriate to expect the State Conservationist to be present at all Tdocal Work Group meetings. We believe NRCS should be represented by NRCS line officers, the District Conservationist at a minimum. As subcommittees of the State Technical Committee, the heal Work Groups (as written in the Federal Register notice) would provide a report to the State Conservationist and a summary of all Local Work Group meetings would be presented during the Statc Technical Committee. The written report should be prepared by the consmation district who convened the Local Work Group. If the conservation, district did not convene the Local work Group, rhe State Conservationist's designee should prepare the written report. The State Conservationist needs to dialogue with the Local Work Group regarding the Local Work Group's priorities and recommendations. We believe the Local Work Group should receive fcedback both if their recommendations are accepted and if they are not incorporated into USDA's program delivery system. Positivc and negative feedback can substantiate and encourage the Local Work Groups to continue developing local soIuEions to natural resources issues. Locally led conservation works well with open and frank two-way communication, not in a vacuum of information. Thank you for the opportunity to provide input on this regulation. We are available to answer any specific question. Sincerely, LL Jbh i n Symens, President South Dakota Association of Conservaiion Districts PO Box 275 Pierre, South Dakota 57501-0275 Phone; 605-895-4099 Fax; 605-895-9424 www.sdconse~ation.or~