August 28, 2008

Attn. Eleanor Rollings

Special Assistant to the Under Secretary for Research, Education, and Extension

USDA

Jamie L. Whitten Building

1400 Independence Avenue SW

Washington, DC 20250

Eleanor.rollings@usda.gov

202-720-1542

Dear Eleanor Rollings,

Please find enclosed comments on the USDA Strategic Plan for Climate Change Science from the Soil and Water Conservation Society (SWCS). SWCS is a nonprofit scientific and education organization that serves as an advocate for natural resource professionals and for science-based conservation policy. SWCS fosters the science and art of soil, water, and environmental management on working lands to achieve sustainability. SWCS members promote and practice an ethic that recognizes the interdependence of people and their environment.

SWCS has been an active leader in advancing the understanding of climate change and soil and water conservation. In 2003, SWCS issued a report entitled Conservation Implications of Climate Change: Soil Erosion and Runoff from Cropland (available here: /en/publications/conservation_implications_of_climate_change/).

In 2006, SWCS, with funding from the Walter and Duncan Gordon Foundation and Natural Resources Canada in Canada and from the Joyce Foundation and the Natural Resources Conservation Service (NRCS) in the United States, held a workshop of experts from the United States and Canada to make a joint evaluation of impacts of climate change, particularly heavy rain events on soil erosion and sediment and pollutant transport from agricultural lands in the Great Lakes basin.

In 2007, issued a report a report documenting the findings of the workshop entitled Planning for Extremes. (available here: /en/publications/planning_for_extremes/). The following comments and recommendations, taken from the report, are provided here to the USDA as input to the Strategic Plan for Climate Change Science:

There is growing evidence that the climate of the Great Lakes region is changing in ways that are likely to increase nonpoint source pollution from agricultural watersheds. Climate models suggest these changes are likely to continue to potentially intensify in the future.

Demand for food, fiber, land and water are increasing with population, and the emphasis on increasing production of energy from biomass will dramatically intensify the demands placed on soil, water, and agricultural resources. More intensive and effective conservation efforts are already needed to ensure that we meet these increased demands while sustaining our natural resources and ecosystems. Climate change will multiply the challenges conservationists face. Current conservation efforts are not keeping up with increasing pressure on agricultural watersheds. Climate change could spark a downward spiral caused by self-reinforcing changes in soil erosion, hydrologic cycles, and aquatic ecosystems. Risks are likely to increase from climatic, demographic and food and energy production stresses, making the status quo level of conservation on agricultural landscapes progressively less protective.

SWCS recommends the following priorities for immediate action:

1.   Focus more attention in planning and program implementation processes on currently well-understood practices that reduce damage from concentrated flow.

2.   Focus more attention in planning and program implementation processes on protecting or repairing stream and riparian corridors.

3.   Use current models and monitoring systems to identify high-risk and high-value tributary watersheds that would benefit from focused conservation efforts.

4.   Update climatic parameters used in conservation tools and planning approaches to include the most recent data and ensure that routine and periodic updates are completed in the future.

The single most important barrier to more effective use of current tools and conservation systems is a technical support and assistance network that is weak and growing weaker. Inadequate technical support and assistance networks will cause lasting damage to our efforts to respond to current challenges, let alone the growing challenge created by climate change. There is a genuine need for better monitoring systems. Managing risks of severe storms requires monitoring systems that can detect such events in the context of long-term time series and document their effects at appropriate temporal spatial scales. A research and development effort should be mounted to develop and deploy affordable monitoring systems and technologies to establish and maintain a regional data warehouse that will provide conservationists with the information needed for effective adaptive management.

Overall, better tools, technology and policy are needed for managing risk. The need for an explicitly risk-based approach to planning is made more urgent by the increased probability of more frequent and more severe storm events. Planning tools designed to develop recommendations for conservation efforts at field, farm, and watershed scales should be developed that are capable of predicting and reporting the probability of damage from a particular storm event as well as from annual precipitation. All factors in a changing climate must be considered when doing risk-based assessments, planning and implementation.

Managing risk at the watershed or landscape scale is the only way to deal with the off-site effects in agricultural watersheds. Improved technology provides the ability to target conservation efforts at the most vulnerable parts of the landscape during the most vulnerable times of the year. Maximizing the communication value of new targeting tools and models will help citizens better understand the causes and effects of environmental problems in their watersheds and make decisions based on the social and environmental implications of the consequences of severe storms and of alternative risk management options. The advantages of focusing conservation efforts through community-driven projects at the watershed scale are compelling. Steady funding and support is needed for sustaining community-driven watershed projects.

In conclusion, advances need to be made in programs and policies to support risk-based assessment, planning, and implementation of conservation efforts to improve the health of watersheds. Public policy must ensure a long-term commitment of people and resources to community-driven projects at the watershed scale. Sustained effort and support must be available to build the local infrastructure—leadership, technical support and monitoring systems- essential to making effective adaptive management possible. An opportunity to develop regulatory systems that are innovative and well suited for agriculture is great. Performance standards should be set at the farm and watershed level. Regulations should be based on performance rather than practice standards. Regulations should clearly tell producers what they need to accomplish, but producers and their technical advisors should have the flexibility to determine how to accomplish it. Innovative approaches that apply performance standards at the watershed rather than the farm scale hold great promise for producing greater results with lesser burdens. Producers, managers, and/or landowners should be encouraged to work collaboratively to achieve the goals for the watershed. Performance standards at the watershed level would also reward targeting effort at the most critical portions of the watershed and make possible market-based approaches to meeting regulatory goals.

Thank you for the opportunity to provide comments on the USDA Strategic Plan for Climate Change Science.

Sincerely,

Peggie James

President

Soil and Water Conservation Society