MURPHY, THOMPSON, ARNOLD, SKINNER & CASTLEBERRY 
                        ATTORNEYS AT LAW  

W.D. Murphy, Jr.		P.O.Box 2595			REGION BANK BUILDING
(1912-1987)			Batesville, AR 72503-2595	1141 E. Main, Suite 300
Tom Thompson		Telephone: (870)793-3821	Fax (870)793-3815
Blair Arnold
I.T. Skinner
Casey Castleberry
  
				February 19, 2009  

 
RECElVED FEB 25, 2009  

Easements Programs Division 
Natural Resources Conservation Service 
Wetlands Reserve Program Comments 
P 0. Box 2890 
Room 6819-S 
Washington, D.C. 20013
 
RE: Docket No. NRCS-IFR-08013 

To Whom It May Concern:
 
If the object of this program is to enroll as much eligible land as possible, I fail to understand why there is a change in land owning requirement from one year to seven years. I had previously placed three farms in the WRP Program, and have not tried to resell any of them. 

I would speculate the purpose of this change is to keep speculators from participating in the program, but you are putting in a real disincentive for non­speculators to participate in the program as well, and after all I would assume the purpose is to enroll land not to deprive those who want to speculate out of making a profit. We are a capitalist country. 

There is a farm I could buy right now, but I am hesitant to do so with a seven year requirement. 

In another case, I had a client whose father defrauded her out of a farm that she should have inherited many years ago. As a result of the lawsuit, she just received a deed back for it in June, 2008. Even though she should have owned this farm all along, she would have to wait to try to enroll the farm in the program until June, 2015 rather than June, 2009. I doubt if she is inclined to wait that long, but she would otherwise place the farm in the program. 


MURPHY, THOMPSON, ARNOLD, SKINNER & CASTLEBERRY 
P O. Box 2595 Batesville, Arkansas 72503-2595

 
Thank you for your consideration.
 
Yours very truly, 
Blair Arnold