This email was submitted to this list by Jim Redmond. Jane, 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] I read your email after I had composed my comments. 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 will also send 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 Executive Summary The Loess Hills of western Iowa are a distinctive topographic region encompassing more than 640,000 acres and extending for nearly 200 miles in a narrow band that parallels the Missouri River valley. Here, exceptionally thick deposits of windblown silt form a region of unique hill forms that have been described as "the best example of loess topography not only in the Central Lowlands, but in the United States" (National Park Service 1985). The striking terrain is an outstanding example of landscapes formed by two fundamental geological processes-- the action of wind and the erosive sculpture of water. The intricately dissected region is characterized by distinctive shapes: narrow corrugated ridges with alternating peaks and saddles; numerous steep side slopes and branching spurs, often featuring natural benches known as "catsteps"; and precipitous bluffs, some with sheer, nearly vertical faces rising from the adjoining Missouri River floodplain. The geologic significance of the Loess Hills has been recognized for well over a hundred years, and the biological significance for nearly as long. The area's rich archeological and historical resources, combined with the extensive prairie ecosystems, contribute to the landform region's exceptional value. In 1999, Congress directed the National Park Service to conduct a special resource study to evaluate the Loess Hills of Iowa for possible designation as a unit of the National Park System. The study includes a natural and cultural resources overview that describes the study area, and evaluates the national significance of the Loess Hills as well as the suitability and feasibility of including this entire landform region as a unit of the National Park System. In accordance with this legislative direction, the National Park Service has provided management recommendations for the long-term preservation of the Loess Hills of westem Iowa in this study document. The National Park Service recognizes that there is a strong desire by many people and organizations to preserve the scenic and natural values of the area. Already, a number of promising efforts to protect and interpret the Loess Hills have been initiated by state, local, and private entities. These entities include seven local County Conservation Boards, Golden Hills Resource Conservation and Development, Loess Hills Alliance, Western Iowa Tourism Region, Western Hills Area Education Agency, Iowa Department of Natural Resources, Loess Hills National Scenic Byway Council, Iowa Natural Heritage Foundation, Loess Hills Preservation Society, and The Nature Conservancy. Additionally, the Environmental Protection Agency, U.S. Fish and Wildlife Service, U.S. Geological Survey, and the Natural Resource Conservation Service serve as federal partners in several efforts currently underway to study and protect the Loess Hills. Based on the application of National Park Service criteria, the National Park Service concludes that the Loess Hills landform region contains resources of national significance. It also finds that the Loess Hills would be a suitable addition to the National Park System. However, the ownership pattern, size, multiple jurisdictions, threats, and lack of comprehensive planning make designation as a unit of the National Park Service not feasible. Five management frameworks for the long-term preservation of the Loess Hills are identified and evaluated in this special resource study. One management concept provides for the continuation of local management at the city and/or county level (no change), while another calls for a more holistic approach to managing the region through the formation of a Joint Powers Board. The Joint Powers Board could be composed of representatives from each county containing a portion of the landform region. Neither of these concepts includes federal designation. The other two alternatives include National Park Service involvement designating either portions of, or the entire region as a National Reserve, an affiliated area the National Park Service. Each management option considers land protection programs already available in the Loess Hills, comments received from landowners and citizens living within the study area, as well as comments from the general public. Together, these four alternatives, while having various degrees of federal, state and local involvement, remain sensitive to private landowner concerns and complement existing conservation efforts of state, local, and private entities. In evaluating the management alternatives, the National Park Service recognized the value having strong, locally-based support and commitment to preserving the Loess Hills landform region. The National Park Service also recognized that the agency could provide support to local efforts to protect the significant resources of the Loess Hills and could help ensure that these resources are preserved for generations to come. The recommended management strategy for the Loess Hills landform region is a blend o four management alternatives previously discussed. This combination relies upon local planning efforts and the voluntary formation of a Joint Powers Board. Upon completion of a Comprehensive Plan that meets National Park Service criteria, the Loess Hills of westen Iowa, or selected segments of the Loess Hills, could be designated as a National Reserve by request of the Joint Powers Board and the Governor of Iowa. This strategy provides for initiative that originates at the local level and allows for state and federal assistance. This recommendation recognizes the national significance of the Loess Hills, encourages and enables local units of government to develop measures to protect the resources of the Loess Hills. The recommendation also provides for federal participation in the preservation of Loess Hills at a level of involvement supported by local units of government and citizens of the region. Additionally, the study team recommends the following studies: An evaluation of the Glenwood Archeological Locality and the Jones Creek Watershed properties for possible National Historic Landmark designation. An evaluation of any or all of the 12 Special Landscape Areas identified by this study (Appendix D) for National Natural Landmark designation. An ethnographic resources study to include a cultural affiliation component and a cultural properties survey that identifies places in the Loess Hills that are important to the Cultural traditions and beliefs of native peoples who have an historical association with the Loess Hills.