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conservation practice standards

What Is Known About TWS Comments on NRCS’s 2021 Conservation Practice Standards Proposal

NRCS opened comments on 23 conservation practice standards in 2021. The available official record does not establish what The Wildlife Society recommended.

By Bettesworth Construction Team Updated 2 min read

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The available official record confirms that the Natural Resources Conservation Service (NRCS) opened a 2021 public-comment process on revisions to 23 national conservation practice standards, but it does not establish what The Wildlife Society (TWS) said. Without a TWS-authored submission or docket entry identifying TWS as the commenter, no specific recommendation or position can be attributed to the society.

What NRCS proposed in 2021

NRCS announced the proposal on March 8, 2021, and published its Federal Register notice the following day. The agency invited comments on revisions to 23 standards in its National Handbook of Conservation Practices. The notice tied public review to Section 343 of the Federal Agriculture Improvement and Reform Act of 1996 for standards used to carry out highly erodible land and wetland provisions. State conservationists that adopted a practice would incorporate it into the state’s electronic Field Office Technical Guide.

NRCS’s announcement highlighted examples of the proposed changes: allowing vented fords as an alternative under Stream Crossing; adding Wastewater Treatment—Milk House for greywater from cleaning milking equipment; revising Energy Efficient Agricultural Operation; and adding flexibility to Dry Hydrant. These examples do not describe every standard included in the proposal. The Federal Register notice lists the standards covered.

What can be verified about TWS’s comments

The materials available here do not include a TWS comment letter or a docket record that identifies The Wildlife Society as a commenter. As a result, TWS’s position on the proposed revisions is not established here. It would be inaccurate to say that TWS endorsed, opposed, or recommended particular changes based on NRCS’s proposal or another organization’s filing.

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NRCS attributed a statement about the purpose of revisions to then Acting NRCS Chief Terry Cosby, not to TWS. Cosby said the agency wanted standards relevant to local agricultural, forestry, and natural-resource needs and intended to use the best technology while addressing producers’ needs and the resources on their land. That is NRCS’s stated rationale, not evidence of TWS’s view.

Comment deadline and broader review context

NRCS initially set April 8, 2021, as the comment deadline, then reopened and extended the period to April 22, 2021. That deadline is historical; it is not an open comment period. NRCS’s March 2021 announcement also said the 2018 Farm Bill required review of all 169 existing national conservation practices, and reported that 57 standards had been updated after public review in 2020.

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How to use a conservation practice standard

A national conservation practice standard explains why and where a practice is applied and sets minimum planning criteria for achieving its purpose. NRCS cautions that the national standard alone should not be used to plan, design, or install a practice: state adaptations may impose more restrictive state or local criteria.

  1. Find the applicable practice and state in the NRCS Conservation Practice Standards Information page.
  2. Consult the relevant state Field Office Technical Guide for the adapted standard and implementation criteria.
  3. If the state standard is unavailable, contact the state office or a local USDA Service Center for direction.

NRCS also makes related materials available, including practice overviews, physical-effects documents, implementation requirements, and network diagrams. These materials support interpretation, but state and local criteria remain important to actual planning and installation.

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