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.