Letter to Natural Resources Conservation Service Regarding
Conservation Security Program

March 2, 2004-Filed Electronically to david.mckay@usda.gov

Conservation Operations Division
Attn: Conservation Security Program
Natural Resources Conservation Service
U.S. Department of Agriculture
P.O. Box 2890
Washington, DC 20013-2890

RE: Comments, Implementation of Conservation Security Program

The undersigned are pleased to submit comments to the Natural Resources Conservation Service (NRCS), U.S. Department of Agriculture on the notice of proposed rulemaking concerning implementation of the Conservation Security Program (CSP).

Bees, butterflies and other pollinator species play a critically important role in American agriculture, in producing a healthy and affordable food supply, and in sustaining ecosystem health. Animal pollinators play a pivotal part in the production of an estimated one out of every three bites of food that humans eat and in the reproduction of at least 80 percent of flowering plants. The commodities produced with the help of animal pollinators generate significant income for agricultural producers. It is thus in the strong economic interest of both agricultural producers and the American consumer to help ensure a healthy, sustainable pollinator population.

Recognizing the importance of pollinators, the Boards on Life Sciences and Agriculture and Natural Resources of the National Academy of Sciences (NAS) will jointly convene an inventory and status assessment of North American pollinators, once necessary funding has been secured. This information can be used to make an assessment of the state of pollinators and what might be done to sustain their health.

The CSP offers an exceptional opportunity to reward private landowners and operators by adding revenue to their economic bottom line for conservation practices on working lands. With traditional pollinator species for commercial crops at risk, national conservation security and food security objectives become one and the same when the CSP rewards producers for voluntary pollinator-friendly practices.

Pollinator stewardship, protection and habitat conservation should appropriately considered throughout the process of implementing the CSP and maximizing its potential benefits for conservation and producers-when conducting the inventory of a farm or ranch operation to identify resource concerns and the extent of conservation treatment already in place; in evaluating "significant resource concerns," particularly at the state and local level; in rewarding farmers and ranchers through CSP payments for conservation practices; and by providing appropriate technical and cost-share assistance to farmers and ranchers who desire to install or enhance pollinator-friendly practices.

Respectfully Submitted,