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December 23, 2005

Secretary of Agriculture Michael Johanns

Farm Bill

1400 Independence Avenue, SW.

Washington, DC 20250-3355

Re: The achievement of conservation and environmental goals in the 2007
Farm Bill

Dear Secretary Johanns:

On behalf of The Wilderness Society, a national non-profit organization
dedicated to protecting America's wildlands and wildlife, I would like
to offer the following comments on mechanisms to achieve conservation
and environmental goals in the 2007 Farm Bill.

America's farm and forest lands are being paved over and fragmented at
an alarming rate as a result of poorly-planned suburban sprawl.
According to a recent study reported in the December issue of
*Ecological Applications*, low density development, or sprawl, has now
consumed one-quarter of the contiguous U.S. These trends are expected to
continue, as documented in the recent USDA Forest Service report,
"Forests on the edge", which projected that over 40 million acres of
private forests are likely to experience significant increases in
housing density in the next three decades.

As farms and forests are converted to development, the many ecological,
social and economic benefits that these lands provide, including clean
air and water, agricultural and forest products, flood control, carbon
sequestration, habit for wildlife, outdoor recreation and scenic beauty,
are lost or significantly impaired.

USDA Conservation and Forestry programs are critical tools to conserve
threatened farm and forest lands, and to assist private landowners in
better managing their lands for these ecological, social and economic
values.

As the need for USDA Conservation and Forestry programs has never been
greater in light of these development pressures, we believe that these
programs can and must be made more effective to achieve conservation and
environmental goals in the following ways:

1.  **Funding to USDA Conservation and Forestry programs should be
    doubled in the next Farm Bill**. The demand for many existing
    programs already well exceeds available funding. In 2004, the total
    backlog for USDA conservation programs was nearly \$3 billion. With
    increasing land values and development pressures, more funding is
    needed across the board for these vital programs.

2.  **More mechanisms and funding are needed to purchase conservation
    easements on threatened farm and forest lands**. [The Forest Legacy
    program]{.underline} has been an extremely effective tool for
    conserving important private forests and maintaining traditional
    forest uses and values, but available funding is well short of
    identified demand from participating states, which is more than
    \$300 million annually, with more states enrolling in the program.
    [The proposed Suburban and Community Forestry and Open Space
    Program]{.underline} would provide an important complement to the
    Forest Legacy program, to assist state and local governments and
    private land trusts in conserving suburban forests threatened by
    sprawl. [The Farm and Ranchland Protection Program
    (FRPP)]{.underline} is an essential tool to assist states and local
    partners in conserving threatened farmlands. In 2004, there was over
    \$100 million in unfunded applications for FRPP funds.

3.  **USDA Conservation and Forestry programs should be better targeted
    to protect threatened watersheds and landscapes**. The "Forests on
    the edge" report identified twenty-six watersheds that could
    experience increased housing density on more than 20% of their area,
    causing tremendous impacts to water quality and other ecological
    values. USDA Conservation and Forestry programs should emphasize and
    be better coordinated within critical and threatened watersheds and
    landscapes to achieve the greatest impact.

4.  **USDA Conservation and Forestry programs should do more to protect
    clean air, clean water quality and at-risk species**, **and to meet
    clear environmental performance standards.** Expand
    [WHIP]{.underline} and increase the program's focus on at-risk
    species. Reform all conservation programs to provide higher
    cost-share rates and/or incentive payments for practices that result
    in clear environmental benefits and maintain them over time.

5.  **The next Farm Bill should give equal attention to both forests and
    farms**. Given the threats to and values of private forests
    documented in the "Forests on the edge" report, a comprehensive
    Forestry Title should be included in the next Farm bill, with
    increased funding to forest conservation and landowner assistance
    programs, and creation of new tools, such as the proposed Suburban
    and Community Forestry and Open Space Program. In addition, forest
    lands and landowners should have greater access to existing
    agricultural conservation programs, such as [EQIP]{.underline}.

6.  **The next Farm Bill should do more to revitalize rural economies**.
    Increased support is needed for economic diversification through new
    technologies and improved marketing of agricultural and forest
    products, and investment in telecommunications infrastructure to
    support the creative economy. Within Forest Service State & Private
    Forestry, [Economic Action Programs]{.underline} help rural
    communities and businesses dependent on forest resources to become
    sustainable and self sufficient. These programs should be expanded,
    not subsumed under general rural development assistance, as
    expertise with forest-based development nation-wide can help
    communities learn from each others' experiences.

Thank you for the opportunity to share our views with you on these
important issues. We look forward to working with the Administration and
Congress to ensure that environmental and conservation goals are
achieved through the 2007 Farm Bill.

Sincerely,

Thomas A. Gilbert

Director, Eastern Forest Conservation

The Wilderness Society

5 Spruce Farm

741 Grenoble Rd.

Jamison, PA 18929