Kershaw Conservation District 
1126 Little St. - Camden, SC 29020 - (803) 432-2576 - Fax (803) 432-5931 

February 25,2009 

Financial Assistance Programs Division 
Natural Resources Conservation Service 
Wildlife Habitat Incentive Program Committee 
P.O. Box 2890, Room 5237-S 
Washington, D.C. 20013 

Re: Comments regarding Wildlife Habitat Incentive Program proposed changes 

NRCS has developed the Plan of Operation for the Wildlife Habitat Incentive Program 
(WHIP) since its inception. This has resulted in improved wildlife habitat for at-risk 
species and benefited many other species. There has been ample and determined support 
of the WHIP program by many cooperators throughout South Carolina as well as other 
states. 

The Kershaw Conservation District objects to adding another layer to an already 
extensive list of requirements to WHIP applications. Specifically, the Operation and  
Maintenance Agreement, (O&M) being required prior to funding a contract developed 
by a NRCS Conservationist (unless the O&M is a generalized statement) could be a form 
that is signed during the signing of the initial contract to insure that all parties understand 
the purpose and goal of this plan. 

Today, WHIP plans require the following: Application (1200) and Appendix, AGI (926), 
AD 1026-Highly Erodible/Wetland ID, CPA 026, Direct Deposit 1199, Entity 901, 
Habitat Type Index-HTI, Environmental Evaluation 52, Win-PST, RUSLE, Ranking 
sheet, Pesticide labels, Wildlife Habitat Job sheets, Agronomy Job sheets, Prescribed 
burning plans, Soils Map, Soils Description, Aerial Photography, Proof of Ownership, 
Annual Status Review 13, Assistance Notes, Conservation Plan of Operation, WHIP 
Contract prior to funding. 

A detailed individualized O&M that has to address the installation and maintenance of 
each conservation practice in each field, and approved by specialist in that area of 
expertise (Wildlife Biologist, Fisheries Biologist, Forester, Agronomist, Endangered 
Species, Cultural Resources, Engineer, Soil Scientist, etc.) will result in at least 1 year 
and as much as 4 years for approval. Such delays will frustrate the cooperators who are 
initially enthusiastic about the good program that has successfully made an impact on the 
various species targeted. We believe that the WHIP program sufficiently addresses these 
various areas of concern and encourages maximum use of the program. 


What is the cost benefit ratio? The cost of administration to get one acre of native grass 
established far exceeds the actual expense at the farm. The Kershaw Conservation 
District objects to the addition of more bureaucracy that will only serve negatively to 
thwart the cooperator interest in a very positive and workable program. The additional 
frustration to our partners in protecting and enhancing wildlife habitat will, in our 
experienced opinion, significantly reduce the number of willing participants. We believe 
that we have management requirements presently in place to assure a quality program in 
the field and that the oversight in the present program is sufficient. 

/Jeff L. Clark, Jr./
Jeff L. Clark, Jr.  
Chairman 
Kershaw Conservation District