Jim Redmond asked that I forward his comments to this list. I agree with most of Jim's comments (below) and appreciate his thoughtful letter. There needs to be an overall long-range plan of protection for the Loess Hills to reduce the threats and fragmentation. I think the 12 special landscape areas identified in Alternative 4 should be protected and could be priorities, but that our vision should not be limited to those areas. I also agree there should be statewide representation on the board (beyond the 7 counties), and that there should be technical and scientific advisors. You could send your comments through today -- as long as they are dated today. Jane Clark Here is my response to the draft study. I have also included an electronic copy of the executive summary if you want to send that to friends. The comments are due by Sept. 4 (NOT SEPT 5)and can be emailed to [log in to unmask] Having talked with someone on the study team, I began to realize the feasibility will get stuck every time on the entire landform. So I come out in favor of #4 and try to provide some insights about the shortcomings of local governments. I am sending this to the Iowa listserv with the simple message: Ask the National Park Service to recommend management alternative #4 and to make sure the joint powers board be representative of more than the seven counties. Other Iowans deserve a place on this board. Jim Ms Sue Jennings, Coordinator Loess Hills Special Resource Study, National Park Service 1709 Jackson St. Omaha, Nebraska 68102 While I want to compliment the study team on the quality of their report, I want therm to reconsider their final recommendation. Although I have researched the Loess Hills for years, I was impressed with the comprehensive information gathered by the study team. We are dealing with a complex issue here, but we should never lose sight of our goal, the preservation of the ecosystem/landform of the Loess Hills of Western Iowa. The team found that the Loess Hills would be a significant and suitable addition to the National Park System. Only on the question of feasibility did the team run into the difficult questions of how and who. How would such a park be managed? Who could move the process along so a Park could be formed? I think you need to look more carefully at the answers, the management alternatives. Alternatives 1, 2, and 5 put too much emphasis on the potential for local government units to plan for and preserve the hills. As much information as there is in the report, I am struck by the omissions. First, since the study recommends a great future effort on the part of the local governments, where is a record of what these governments have done in the past? Look at the history and the law. How many laws are on the books in these counties that control any activity detrimental to the hills? Very few! How many dollars have actually been spent by these governmental units in the last decade to preserve the hills? Very few! Having served the past two years on a Planning and Zoning Committee for the City of Sioux City, I can confidently say we talk a good game in public but other priorities are funded and legislated. Even with all the desire to protect the hills, we are still struggling to pass a grading ordinance in the city. On p. 35 the report notes about $1 million being allocated to land protection AND economic development, but compare that to the several millions a single county is willing to spend on blacktopping a gravel road or any of the other roadway projects in the region. Second, where is a chart or table to describe the degradation that has been occurring? On pages 45 to 48 you accurately describe these threats. However, you need to add a sense of time to this description. Even as efforts have been made to preserve the hills in the last fifteen years, more degradation has occurred sometimes through economic prosperity and government programs. On page C-39 you cite Grant and note that tree cover increased 66% between 1953 and 1981. Check with Jim Stroh, former biology professor at Morningside College for more recent figures on how tree cover is increasing in certain portions of the hills already under public protection. The conclusion that needed to be reached is that local governments do not have the will or the resources to preserve or manage this nationally and globally significant ecosystem/landform. Local governments have to be joined by state and federal agencies and resources in order to reverse the degradation of the hills. I guess Alternative # 4 comes closest to the combination of local, state, and federal efforts needed. However, why would a comprehensive plan for the Special Landscape Areas preclude the development of a Comprehensive Plan for other areas and why is federal acquisition of land so verboten? One county or city could pass ordinances more easily if agreement (via a comprehensive plan) existed about the importance of the landform/ecosystem. Two complementary plans would not create the complexity present today with so many agencies dealing with portions of the puzzle. The federal government is dispensing huge road funds and other monies to the state of Iowa. Why can't federal money be allocated for the purchase of key parcels from willing sellers (as in some state programs, REAP for example). Some states may have problems of huge parcels of federal lands but Iowa is at the opposite extreme with few federal holdings. Effigy Mounds reflects the public interest and appreciation of such acquisition. Why can't federal monies be used to help local governments plan and implement protective programs? One of the most obvious fallacies of the report occurs on page 49 of the draft. In determining that it is not feasible to add the Hills to the National Park System, cost per acre of farmland in the counties was used. The Hills should never have been farmed or grazed; nor should farmland prices be used to determine the cost per acre of these lands. What are the market values of parcels that are too rugged to be used for agriculture? Use those figures instead of trying to calculate from an agricultural market basis. The study team should focus more attention on Alternative 4. The Special Landform Areas would not face the same managerial problems that led to the conclusion that the entire area is not a feasible addition to the Park System. Intensive study of the twelve Special Landform Areas could lead to a reconsideration of National Park or National Monument status. I am sure the study team did not notice, but the picture on the cover misses key discoveries of the study. Don Poggensee has often photographed the Loess Hills beautifully, but your team chose a picture that focuses on the farmland in the floodplain and on totally wooded hills. Those farms are not part of the formation, nor would protection of the hills entail purchase of true farmland. As a farmer friend told me: Agriculture would not be in the difficulty it is today if we discouraged farming in marginal areas. The Loess Hills of Western Iowa epitomize a marginal area that should not be used for agriculture. That woody cover is ruining the prairies and those trees are protected by a general ignorance of the threats posed by trees. Even the State of Iowa has an initiative to plant a forest in the hills when they should be striving to preserve the original ecosystem. Please pick a more appropriate picture for the cover of your report. On p. 49, the report states: "The diversity and extent of resource threats further complicate the ability of the NPS to successfully manage the region as a single unit." While the National Park Service recognizes the extent of these threats, I plead with you to help us turn back these threats in some sizable portions of the hills, specifically the twelve Special Landform Areas. Any board created to compose a master plan or apply for national reserve or national monument status must be based not on the seven counties, but on a state and federal partnership with local governments. Balance the Joint Powers Board with local, state, and federal voices. Dr. James Redmond Conservation Chair Northwest Iowa Sierra Club 3700 Jackson St. Sioux City, Iowa 51104 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - For SC email list T-and-C, send: GET TERMS-AND-CONDITIONS.CURRENT to [log in to unmask]