UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C.  20460

                          September S, 1978
                                                              THE ADMINISTRATOR
SUBJECT:  EPA Policy
          To Protect Environmentally Signlficsnt Agricultural  Lands

TO     :  Assistant Administrators
          Regional Administrators
          Office Directors
PURPOSE

     The purpose of this statement is to astafcnisn  EPA  policy  t.^at will
recognize the -cod production and environmental value of agricultural
lands and theMecassity to protect "hem wherever imoactea  DV Agency
programs,  Thi; policy is intencsfl to guide Agency  actions, regulations,
program guidarce and ~scnr">cal assistance *o rsducs ,or  nitreats adverse
impacts, and to encourage farmland srotar.ticn efforts v/nicn are consistar
with environmental quality goals,

RATIONALE

     Conversion and less of agricultural land, particularly prir.a f.«n~
lands to exoanding uroan uses, has significantly ai-ninisnea tna Nicion's
cropland base, and affects environ-ental quality,   X'ith lass  "prrre1'
quality agricultural land available, greater reliance on marginally
productive farmland will occur, resultinq in greater soil  a*"osicn,
increased fertilizer requiregents, ^na increased environ;,lental damage.
Conversion of agricultural land also reduces our future food orccucticn
capability, tne viability of farming units, and causes  adverse secondary
economic impacts on farming entarorise in Tiany metroool i tan srsas.

-------
     Loss of agricultural  land diminishes  environmental quality by
reducing the beneficial  role which the  land  itself can play.  Agri-
cultural land reduces runoff by absorbing  precipitation, aids in re-
plenishing groundwater supplies, buffers environmentally.sensitive areas
from encroaching development, and serves in  waStewater treatment through
land treatment processes.   These environmental  benefits are predicated
on best management practices.  Other benefits  of retaining agricultural
land in or near urbanizing areas are the value of convenient sources of
food production in proximity to consumer markets enabling reduced con-
sumption of scarce fossil  fuels for transportation, which in turn will
assist in protecting ambient air quality,  and  the open space, recrea-
tional, and aesthetic setting these lands  may  provide for fuller enjoy-
ment of cleaned waters.

     Protecting agricultural land to maintain  environmental quality also
is based on sound planning.practice which  reduces sprawl development and
its' associated social, economic,, and environmental costs.  Retaining
agricultural land can be a significant  element of an environmental man-
agement strategy, and is consistent with the President's Initiatives to
limit urban sprawl.

     In a recent report, the U.S. Soil  Conservation Service pointed out
that 79.2 million acres  have been converted  from cropland since 1967.
While additional acreage has b»en converted  to crooland during the same
period, the net loss to  cropland has been  30.5 million acres, leaving
about 400 million acres  in the nation's cropland base.  Of the nearly
17 million acres converted to urban development, reservoirs, and other
built-up uses (often with  federal assistance), mere than 8 million acres
was of prime quality.  The^e losses to  the cropland basa are absolute,
yet they also have a qualitative aspect.   To maintain crop production,
land of lower quality is brought into cultivation requiring greater
input of crop production technology, with  its  potential negative impact
on environmental quality.  In 1976, the  Council  on Environmental Quality
recognized these conditions and directed that  federal agencies evaluate
the impacts of their actions on prime and  unique farmlands in NEPA
reviews and environmental  impact assessments.

     Urban encroachment, unique economic problems faced by farmers, and
the impact of federal programs all influence the conversion of agricul-
tral land.  The impacts  which result from  federal grants-in-aid for com-
munity infrastructure and  new development  are  significant in the conver-
sion process.  Decisions on federal grants for sewsrs, highways, and
other'capital improvements do not adequately reccgnrize that agricultural
lands are a finite productive and environmental resrource which is cumu-
latively and irretreivably diminished as a result o?f  federal actions.

-------
      Some EPA  programs  impact  on  farm management  practices,  economically
 affsct farming operations,  and  can  inadvertently  cause  conversion  of
 agricultural land  to  other  uses.  Cumulatively, there  like-ly are signif-
 icant EPA'program  impacts which induce  land use changes:  unplanned urban
.development, remove  land from  agricultural production  and reduce our
 ability to maintain  environmental quality.

      A recently issued  policy  on  land treatment of municipal  wastewat^r
 underscores our Agency's reliance on a  variety of agricultural  lands  in
 proximity to urbanized  areas to enable  the option of wastewater manage-
 ment and beneficial  utilization of  municipal wastes  1n  agriculture to
 continue in the future.  The land treatment systems  fostered by this
 policy involve'the use  of plants and the soil to  remove unutilized
 wastes from wastewaters.  The  recovery  and beneficial  reuse  of  waste-
 water and its  nutrient  resources through land treatment can  contribute
 to the productivity  of  farmlands.   Thus, land treatment can  enhance
 production, and the  availability of agricultural  land  in  urbanizing
 areas can enable land treatment to  continue as a  viable waste manage-
 ment approach.

      The Agency currently has  no overall policy which  assures that its
 actions, regulations, and programs  reinforce the  retention and  protection
 of environmentally significant  agricultural land.  Since  agricultural
 land itself can play  an important role  in maintaining  environmental
 quality, it is in  EPA's interest to treat it as an environmental re-
 source, and to discourage its  conversion to other non-agricultural uses.

      EPA is in a strategic  position to  assist in  the protection of the
 Nation's vital  agricultural land resources.  It must,  therefore, seek
 to minimize the impact  of its  programs  which may  induce conversion of
 agricultural land  unless the proposed activity serves an  essential public
 need,

 DEFINING ENVIRONMENTALLY SIGNIFICANT AGRICULTURAL UAMD

      Soil  capability  for food  and fiber production,,  together with  manage-
 ment and technology  are among  the major factors governing the potential
 of land productivity.   The  importance of agricultural  land from an
 environmental  perspective>  in  addition  to these factors,  is  determined
 by its capability  to  contribute to  maintaining or improving  environ-
 mental quality.  Thus,  the  ability  of agricultural land to directly or
 strategically  aid  in  maintaining environmental quality  determines  its
 significance.

-------
     For purposes of this policy,  agricultural  land types defined in
1, 2, ^3, and 4 are those set forth by the U.S.  Department of Agriculture
in 7 CFR Part 657.  Their environmental  significance is based on their
own merits for productive capability and general  environmental  resource
value.  Agricultural land types defined  in 5,  6,  and 7 are these iden-
tified for their specific environmental  value.   Their environmental
significance is based on their role in an EPA-required environmental
plan or management strategy.  Under these definitions, prime fctrinlands
are to be considered as having the greatest environmental significance.

     Environmentally Significant Agricultural  Lands include:

     1.   Prime farmland is  land that has the  best combination  of
     physical and cnemical  characteristics for producing food,  feed,
     forage, fiber, and oilseed crops, and is  also available for
     these use? (the land could be cropland, pastureland, rangeland,
     forest land; or other  land,.but not developed land or under
     water). -It has the soil  quality, growing  season, and moisture
     supply needed to economically produce sustained high yields of
     crops when treated and  managed.

     2.   Unj gue fannland is land  other  than prime farmland that is
     used for the production of specific high  value food and fiber
     crops.   It has the special ccmbination of  soil quality, location,
     growing season, and moisture  supply needed to economically pro-
     duce sustained high quality and/or  high yields of a specific
     crop when treated  and managed according to acceptable farming
     methods.

     3.   Additional farm!and_of .statawjde -importance is, in addition
     to prime and unique farmlanas, significant for the production of
     food, feed, fiber, forage, ornamental, and oilseed crops.   Cri-
     teria for defining and  delineating  this land is to be determined
     by the appropriate State  agency or  agencies-

     4.   Additional farmland  of local Importance, is not identified
     as having national or  statewide importance.   In some local areas,
     however, it is economically important and environmentally  sound
     for certain additional  farmlands for the  proouction of food,
     feed, fiber, forage, ornamental, and oilseed crops.  Where
     appropriate, these lands  may  be identified by the local agencies
     concerned.

-------
      5.  Farmlands In or contiguous to Envlronrngn tally Sensitive Areas
     { ESA 'si , such as f 1 oodp'lains ,  wetlands, aquifer recharge zones , or
     natural scientific study areas ; these farmlands play a crucial
     environmental buffer rcla to prevent development from encroaching
     on ESA's, thereby protecting their capability to remain environ-
     mentally productive *nd stable,
     6.   Faplands o^ jvaste_^                     which may serve
     in the land treatment pr~ocess~r"be"~used'""fdr" composting activities,
     or for controlled beneficial  application of sewage sludges or other
     wastes.

     7.   Farmlands with significarvt Capital  investments in Best
     Management Practl ces j bHP ' s ) ,  wnicn serve as elements of an
     ~a rea"" s ( or st a te ' s } s oi 1  eras i on and non-point source pollution
   .  control  plans.

BASIS FOR ACTION
                                                       >
     The basis for Agency action  to protect environmentally significant
agricultural  land is found in several policy directives and statutes:

     EPA final regulations implementing the requirements of the National
Environmental Policy Act in 40 CFR  Part 6 direct the Agency to specifically
identify impacts affecting prime  agricultural land or agricultural
operations on such land.  A Council on Environmental Quality  Memorandum
for Agency Heads (dated Aucust 30,  1976) seeks to assure that prime
farmlands" are not irreversibly converted to other usas as a result of
federal program impacts.

     Impacts resulting from programs administered under the following
statutes can directly or indirectly influence agri cultural lands or
farming operations:

     The Clean Water Act provides  for waste treatment works and water
     quality planning which impact on agricultural lands.  It also
     requires that comprehensive  pollution control programs give due
     regard to agriculture activities.

     The Clean Air Act Amendments  focus on air resources and consider
     public welfare impacts such  as effects on soils, water, crops,
     and vegetation,

-------
     The Resource Conservation and Recovery Act calls for criteria and
     guidelines to ensure that solid and hazardous waste disposal activ-
     ities do not create adverse health or environmental effects, in-
     cluding those which may affect agricultural activities.

     The Safe Drinking Water Act enables the designation of areas con-
     taining sole source aquifers which are likely to contain agricul-
     tural lands performing groundwater recharge and natural cleansing
     functions for those aquifers.

     The Federal Insecticide, Fungicide, and Rodenticide Act enables
     the Administrator to reclassify or suspend the registration of
     a pesticide.   This may lead to changes in crop patterns and
     ultimately to conversion of prime farmland to other uses.

POLICY

     It is EPA's policy to protect, through the administration and
implementation of its programs and regulations, the Nation's environmen-
tally significant agricultural land from irreversible conversion to uses
which result in its loss as an environmental or essential food production
resource.

IMPLEMENTATION
     EPA will apply this policy to the full  extent of its authorities in
implementing Agency actions.   Each major Agency Office and Region will
review its programs and modify its policies  and operations as necessary
to carry out the actions required in this policy.  Headquarters Offices
and Regions shall designate staff responsible for seeing that required
actions are carried out.

     Responsibility for implementing this policy rests with each Agency
program and Regional Office,   Responsibility for monitoring the imple-
mentation of this policy rests with the Office of Federal Activities,
which will report its progress and recommend adjustments prior to the
next issuance of the annual EPA Policy Guidance.

ACTION REQUIRED

     Assistant Administrators and Regional Administrators shall ensure
that their actions and those  of their staffs clearly advocate protection

-------
of agricultural  lands.   Protection  of  environmentally significant
agricultural  lands  shall  be  carried out  in  the  following Agency actions:

     a.    A consideration of impacts on  agricultural  land shall be
     incorporated within  the process of  developing  new or revised
     Agency regulations,  standards,  or guidance.

     b.    Specific  project decisions involved in  the  planning,  design,
     and construction  of  sewer  interceptors  and treatment facilities
     shall consider farmland protection.  Consistent  with Agency cost-
     effectiveness  guidelines,  interceptors  and collection systems
     should be located  on agricultural land  only  if necessary to elimi-
     nate existing  discharges and serve  existing  habitation.

     c.    Agency permit actions which  are subject to  MEPA review shall
     ensure that the proposed activity will  not cause conversion of
     environtncntally significant, agricultural land.  The permit process
     shall consider farmland protection  alternatives, and ensure that
     the least damaging environmental  alternative is  implemented.

     d.    Primary and  secondary impacts  on  agricultural  land  shall be
     determined, and mitigation measures recommended  in environmental
     assessments and reviews of environmental impact  statements of EPA
     decisions,  and reviews  of  actions proposed by  other federal agencies,

     e.    The regional  or local significance and  economic value of farm-
     lands to communities shall be  considered in  Agency enforcement actions

     f.    Future environmental  consequences, trends,  and applications
     of the environmental roles of  agricultural land  shall be studied
     and research needs identified.

     g.    A public  awareness, program which  recognizes the environmental
     value of agricultural land and  its  role as an  environmental resource
     shall be pursued.

     h.    Agency technical assistance  activities  i*n the development
     of air quality, water quality,  and  solid waste plans shall sup-
     port and encourage State and local  government  agricultural land
     protection  programs. Significant farmlands  recognized in  these
     programs shall be  incorporated into Agency-required environmental
     plans and implementation approaches, wnenever  appropriate.

-------
                              8
i.   Agricultural land protection efforts of states, local
governments, or other federal  programs snail be supported
through intergovernmental  coordination and EPA project re-
views.  Opportunities for review and comment on proposed
EPA actions which impact on agricultural  land shall be
afforded.

j.   Future EPA Policy Guidance shall  reflect this policy
of protecting environmentally significant agricultural' land.
                              Dot
Costle

-------
            QUESTIONS AND ANSWERS  -  AGRICULTURAL PROTECTION POLICY
 1.   What will this policy do?

A.   It will  require EPA Regional Administrators and orogram officials to
     consider the impacts of their activities and ruleoiaking (for example,
     in deciding the location of an interceptor sewer) and ensure that the
     effects  of those actions minimize the loss of productive farmlands.


2.   Why is it needed?

A.   Unfortunately, for soma time Federal programs have unintentionally caused
     a loss of valuable farmland.  Recently Secretary of Agriculture Bergland
     put it this way:  "We have been losing a million acres of cropland a year
     for the  last 30 years.  During the 50's we lost land to the interstate
     highway  system.  In the 60's we lost land to suburban sprawl.  In the 70's
     we're losing land to sewage treatment facilities.  All of which require
     flat farmland."  EPA wants to make sure that its programs have a minimal
     impact on agricultural land loss.  That is what the Council of Environmental
     Quality  wants us to do, that is what American fanners, and the State
     Agricultural Departments want us to do, and that is what we want to do.


3,   What does the policy mean for the" farmer?

A.   It should provide some assistance to the fanner in hanging on to his property,
     It does  not dictate how a farmer can or can't use his land.  It means there
     will be  less pressure coming from the EPA — in terms of grants for treatment
     plant construction — that could provide the spark for other residential or
     commercial development.
            *

4.   Is the loss of agricultural land really a problem?

A.   Yes.  Roughly 31 million acres of farmland have baen lost to development
     and other uses during the past decade.   Qf this, 17 million acres have been
     eaten up by urban growth; 8 million has been converted to reservoirs,
     ponds and other water bodies and the remaining is no longer being fanned
     for various reasons,


5.   Will the policy result in new regulations?

A.   riot likely.  But it is likely that rules now in effect or under development
     increasingly will  be administered in ways that don't contribute to the
     problem of farmland loss.

-------
 6.    What  is  the  status of this policy as opposed to a regulation or law?
      Will  it  be changed from time to time?

 A.    This  policy  itself does not have the force of law.  However, EPA will make
      every effort to uphold the policy in carrying out activities, such as regu-
      lation development and grant approvals.  The policy is backed up the National
      Environmental Policy Act.  While the basic framework of the policy is not
      expected to  change, it will be further developed and refined as we gain
      experience through its implementation.


 7.    Is it a  "no  growth" policy?

 A-    Definitely not.  EPA air and water pollution control programs are designed
      to accommodate projected growth.  This policy is no exception.


 8.    Can the  policy stop EPA from doing certain things?

 A.    It will  affect how we do certain things.  For example if we're facing a
      decision on  approving an interceptor sewer to be built in a rural area
      or one already inhabited, this farmlands policy favors consideration of
      alternatives which would limit the "spread" of urbanization unless there's
      soroe  overriding consideration that makes this impossible or environmentally
      unsound.
                              /

 9.   Are State and local governments acting to preserve farmland?

A.   New Jersey and Suffolk County, New York are experimenting with public
     purchases of development rights from farmers that allow them to continue
     using  the land for agricultural or other purposes but not to sell or
     lease  it for development.  Massachusetts has passed a law adopting this
     approach, and California is considering it.  Oregon has a comprehensive
     program  based on statewide planning goals and local zoning.  Many other
     States attempt to preserve farmland by using "differential tax assessments"
     that price farmland for its food production value as opposed to its value
     for urban development.


10.  What causes the loss of agricultural  land? •

A.   Urban  encroachment, unique economic problems faced by farmers, and the
     impact of federal  programs  all influence the conversion of agricultural
     land.   The impacts which result from federal grants-in-aid for community
     infrastructure and new development are significant in the conversion orocess.

-------
     Decisions on federal grants for sewers, highways, and other capital improvements
     do not adequately recognize that agricultural lands are a finite productive and
     environmental resource which is cumulatively and irretreivably diminished as a-
     resylt of federal actions.  Some EPA programs impact on farm management prac-
     tices, economically affect farming operations, and; can inadvertently cause
     conversion of agricultural land to other uses.


11.  Why is farmland enviroreisentally important?

A,   Farmlands play an envirorenentally active role as open space to:

          absorb and filter snow and rainfall to maintain clean underground
          water supplies;

          serve as wildlife habitat ands In some cases, preserve wetlands
          essential to the reproduction of certain fish and other aquatic
          life;

          can provide a way of disposing sewage sludge to condition soil
          and fertilize crops;

          provide a country experience for harried city dwellers.


12.  Do you have examples on how, EPA programs impact on agricultural lands!

          through decisions on the location of sewage treatment plants
          and interceptor sewers that may make uninhabited areas attractive
          for development,

          through decisions as to where new sources of "industrial air
          pollution may build (significant deterioration policy),-

          through decisions on the siting of solid waste landfills,

          through reviews of environmental impact statements of other
          federal agencies activities that affect farmland (highways,
          dams, etc,}


13,  What is the relationship between the agricultural lands policy and the 20S
     program?

A.   The relationship is indirect.  By protecting prime farmlands there will be
     less need to raly on marginally productive farmland which often results
     in greater soil erosion, increased environmental damage and increased
     energy intensive fertilizers.

-------
14.  What is the relationship between the agricultural lands policy and the
     201 program?

A:   EPA will review municipal waste treatment grants carefully to mitigate,
     as far as possible, construction activities on significant agricultural
     lands.  Tha Regional Administrators and their staffs will be required to
     carry out their 201 actions in accord with the EPA agricultural lands
     policy,


15.  How is agricultural land conversion caused by EPA programs?

A:   Our investigations of case examples have confirmed the logic and causal
     relationship of EPA program impacts on farmland loss.  However* currently
     available EPA data does not illustrate the full degree of program impacts
     on farmlands.  The Soil Conservation Service points out that some 79.9
     million acres have been converted from cropland since 1967 — a relatively
     short period of time.  Of the nearly 17 million acres converted to urban
     development, reservoirs, and other built-up uses, more than 8 million
     acres was of prime quality.  Where EPA programs help support development
     infrastructure, such as sewer construction grants, they serve to stimulate
     farmland conversion.  As such, farmland loss attributed to urbanization
     or the "threat" of impending urbanization can be seen as the result of our
     impact on this problem.

     EPA is one of several federal  agencies (including EDA, FmHA, DOT, and HUD)
     that provide financial assistance which induces urban development.  In
     addition to reducing the adverse impacts of our programs, careful compre-
     hensive planning at local levels can reduce farmland conversions.

-------
     BACKGROUND PAPER IN SUPPORT OF AN EPA POLICY TO PROTECT
          ENVIRONMENTALLY SIGNIFICANT AGRICULTURAL LANDS
                             CONTENTS

1.    Introduction and Statement of the Issue.	.. .1
2.    Environmental  Consequences of Agricultural  Land Conversion	2
3.    The Environmental  Case for Protecting Agricultural  Land	,..,.6
4,    Basis for EPA Concern	,	,	9
3.    Trends in Agricultural Land Conversion	12
6.    Environmental  Variables in Agricultural  Production	19
7,    Defining Environmentally Significant Agricultural  Land	,..21
8.    Why Farmlands  Are Lost	........24
9.    State-of-the-Art Approaches for Farmland Retention	28
10.  EPA Program Impacts on Agricultural Land.	31
     Footnotes
     Tabs 1 - 12
                                   Prepared by the Office of Land Use Coordination
                                   United States Environmental Protection Agency
                                   Washington, D.C.  20460
                                   Revised:  August 25, 1978
*Ncta:  This background paper is an in-house EPA document subject to
        revision before being published and made generally available.

-------
                 LIST OF TABS FOR BACKGROUND DOCUMENT
1.    Abstracted texts of Administrator Costle's speeches referring to
     farmland retention.
2.    Letter of Massachusetts State Officials on interaction of sewage
     treatment and agricultural land use.
3.    Portion of Denver Regional Overview £IS Statement
4.    USDA policy memorandum on Prime Farmland, Range, and Forest Land
5.    Farmland Benefits outlined in State of Maryland Report.
6.    CEQ Memorandum on Analysis of Impacts on Prime and Unique Farmland
7,    Reprint of 7 CFR, Part 657 - Prime and Unique Farmlands Definitions
8.    Article by Robert A, Norton on Value of Unique Farmlands
9.    Newsclip of case example of Farmland Retention Efforts
10.  Text of Massachusetts Law on Agricultural Land Development Rights
     Purchase and California proposal for Farmland Retention
11.  Considerations for Farmland Retention Strategies at State and
     Local Government levels.
12.  Newsclip describing the Jeffords Bill, H.R, 11122

-------
1.    INTRODUCTION AND STATEMENT OF THE ISSUE

     Administrator Cos tie's remarks before the Massachusetts Farm Tour
     on August 25, 1977, and before the Annual Convention of the sNational
     Association of Conservation Districts on February 6, 1978, stressed
     the need to examine relationships between EPA Programs and the
     Protection of Farmlands,   (See Tab 1).  In his words, "Because of
     our sensitivity to the need for preserving our (prime) farmlands
     and keeping them in production, I have directed that EPA examine
     the effects of each and every one of its own programs and regula-
     tions on the retention of agricultural lands,,..  And, I've direc-
     ted that we develop an overall policy statement on the preservation
     of these (environmentally significant) agricultural lands to give
     general guidance for the implementation of EPA programs."

     A recent exchange of letters among state officials in EPA's Regions
     (See Tab 2 and Tab  3) similarly characterizes these issues.   The
     U.S. Deoartment of Agriculture has also articulated a policy exores-
     sion on this issue (Sea Tab 4).

     From this charge, an Agency-wide working group engaged to contribute
     information on impacts and review the oroblems and opportunities
     facing EPA on this issue.  This background paper serves several
     purposes:  as an educational device for understanding relationships
     between farmlands and environmental quality; as a basis for iden-
     tifying the impacts of EPA programs on farmlands; and as a vehicle
     for supporting an Agency policy proposal.

          ISSUE

          Well-managed agricultural lands oftsn olay environ-
          mentally beneficial  roles by providing assimilative
          capacity, serving as buffer zones, and offering rela-
          tive environmental stability whan compared to urban
          or developed land uses.  EPA programs are designed
          to improve environmental quality but may induce land
          use change and development, and remove agricultural
          land from production.  These losses of agricultural
          land use reduce our ability to maintain environmental
          quality, yet the Agency currently has no overall
          policy which assures that its actions, regulations,
          and programs reinforce the retention and protection
          of environmentally significant agricultural lands.

-------
2.    ENVIRONMENTAL CONSEQUENCES OF AGRICULTURAL LAND CONVERSION

     Conversion of prime farmlands to urban uses induces  a shift to
     farming on less desirable land or more intensive use of existing
     farmland.    This shift would lead to a greater reliance on  environ-
     mental  manipulation, which, given current levels of  technology,
     would tend to require additional land management and conservation
     practices.

     In addition to the outright loss of high quality land as an
     agricultural and environmental  resource, other consequences of
     prime farmland conversion which raise environmental  concerns are
     the shift to less productive (non-prime) lands, and  the implicit
     requirement for greater application of technology and environ-
     mental  manipulation to achieve high levels of productivity  on
     less-productive lands.

     Conversion of prime agricultural LAND to other (urban) uses often
     leads to these consequences;2

     A.   Since over 90% of the highest quality land is currently in
     production, land shifted out of agriculture is irretrievably lost
     from the agricultural land resource base.   This loss of "open
     space"  land also depletes a region's assimilative capacity.  Such
     losses  are significant as more and more urbanized areas are covered
     with impermeable surfaces, and more public investments are  raade  to
     accommodate the adverse environmental effects of urbanization,

     8.   Urban sprawl, skip development, and fragmenting farms  into
     5 to 50-acre parcels has both direct and indirect affects on
     agricultural production.  There may be speculative idling of crop-
     land, isolation of farming enterprises, increasing land values and
     production constraints arising from regulations on odors, waste
     disposal and other land-use incompatibilities.

     C.   Often, agricultural land in floodplain areas is shifted to
     industrial or commerical development.  Pressure is then created
     for public investment to provide flood protection, where such
     investments was not previously required.

     D.   Shifting agricultural activities to less productive (r.on-prime)
     lands leads indirectly to these results:

          1)   "under-utilized land" being held in a natural or
          undisturbed state is reduced.  Such land provides one  of
          the very limited opportunities for natural ecosystems  to
          develop, and for natural diversity to be maintained.

-------
     2)    Use of non-prime land and marginal  land implies the use
     of land which has steeper slopes and poor soil  quality.   Such
     lands are more vulnerable to soil erosion from either wind or
     runoff.

     Sediments carried by water runoff clearly represent the "dominant
     form of soil  loss in the Unitad States,  delivering approximately
     4 billion tons/year of sediment to waterways in the 48 contingu-
     ous states".3  Three-quarters of these sediments come from agri-
     cultural lands-  Soil erosion also has a detrimental effect on
     reservoirs, rivers, and lakes.  About 1  billion of the 4 billion
     tons of water borne sediments end up in  the ocean, and the re-
     maining 3 billion tons settle in reservoirs, river and lakes.*
     One-quarter of the total sediments come  from sources other than
     agriculture,  such as construction and logging.   About 450 million
     cubic yards (344 million cubic meters) of sediment are dredged
     from U.S. rivers and harbors annually at a cost of about S250
     million.5  Sedimentation materially reduces the useful life of
     reservoirs, and costs the nation about $30 million annually,6
     These and other sediment damages are estimated to cost the
     United States about $500 million annually.7

     Soil sediments, the associated nutrients (for example, nitrogen,
     phosphorus, and potassium), and pesticides have an ecological
     impact upon stream fauna and flora.  The added nutrients rray
     increase aquatic productivity resulting in eutrophication; in
     contrast, when suspended sediments are present they reduce light
     penetration,  which reduces the productivity of aquatic ecosystems.
     Fish food may then be lass abundant.

     Wind erosion  of soil is generally considered to be less severe
     than water erosion, but may be significant in specific regions
     of the United States.  It is estimated that 850 million tons
     of soil per year were moved by the wind in the western region
     of the United States alone.  For the United States as a whole,
     it has been estimated that about one-quarter of the total
     erosion that occurs is due to the wind.S

E.   Use of marginal farmlands and attempts to maintain high crop
yields which causes greater reliance on artificial and technological
manipulation also  results in environmental consequences;

-------
     1}   There is a greater dependency on soil conservation
     measures to maintain agricultural productivity and environ-
     mental stability.  At the same time, increased burdens and
     costs are placed on the farmers who undertake soil conser-
     vation measures, reducing the likelihood that they will be
     done effectively and completely.

     Various methods are used for soil conservation.  Contour
     planting is probably the most common and can be extremely
     effective.  However, it results in a 5 to 7 percent increase
     in both farming time and fuel use."

     2)   With low soil capability, increased applications of
     fertilizer would be needed to maintain yields.  Inevitably,
     increased amounts of nutrients are fixed to soil particles
     carried into streams in the more erodible soils of marginal
     farmlands.

Additionally, farmland conservation results in secondary environmental
effects.  The conversion of prime farmlands to urban uses implies the
provision of urban services (e.g.j sewer lines). Unless these increments
of change are carefully managed, poorly planned and staged development
could lead to adverse environmental effects as well as an inefficient
infrastructure and tax base from which to provide needed public
services.

These consequences, the secondary environmental effects they imply,
along with the specific environmental effects of increased runoff
and erosion and transport of particulates, the likely increase in
applications of pesticides and fertilizers in some areas5 reduction
of aquifer recharge capability, and the subsequent energy/pollution
effects, all suggest that shifts in agricultural land uses are en-
vironmentally significant.
                 /

Historically, most land-use decisions have been made by open pricing
in the market place.  On this basis, land for agriculture can seldom
compete when the land is in demand for non-agricultural use.  The
market place has not put a value on farmland's contribution to main-
taining environmental quality.  Future actions will need to ensure
that the long-term environmental interest of the public is given due
consideration in agricultural land use decisions.

-------
More than even before, the conversion of high quality farmlands to
urbanized uses escalates the relative cost of new agricultural develop-
ment by placing greater reliance on fertilizers and technology.  The
continuing cycle of agricultural land conversion and development of
alternative Gotten less productive and environmentally fragile} lands
will be costly for the farmer, for the consumer, and for the environ-
ment-

-------
3,    THE ENVIRONMENTAL CASE FOR PROTECTINS AGRICULTURAL LAND

     In addition to food and fiber production, agricultural  lands  of
     all types     (prime,  unique, etc.)  play an important environ-
     mental  role,   the open space afforded fay farms  acts to ameliorate
     local  fnicroclimate conditions.  Farmlands absorb precipitation,
     thereby replenishing the groundwatsr supply and reducing the
     amount of runoff during periods of Nigh water.   Insulation of
     environmentally sensitive areas such as wetlands and floodplains
     from incompatible uses is another function served by farmlands.
     Agricultural  land may also serve as  a repository for sludge and
     other wastes  or be an appropriate application for spray irrigation.
     While there are costs  to farmers in  terms of productivity and crop
     quality,  farmland open space acts beneficially  as a sink for  such
     air pollutants as ozone, sulfur dioxide and fugitive dust.

     It should be  emphasized that these environmental benefits of  farm-
     lands are predicated on good farm management and soil conservation
     practices.   In light of this, a strong rationale for maintenance  of
     farmland  is found in the open space  and environmental benefit inherent
     in cropland,  woodland, and pasture.   Some of these more readily iden-
     tifiable  benefits include: 12

     A.   Watershed protection can be an  essential attribute of
     well-managed  farms.  Water availability will become an in-
     creasingly important issue in most regions as the population
     expands and per capita use increases.  Open lands, such as
     farms,  help maintain local water supplies by absorbing pre-
     cipitation and transferring it to the groundwater system,
     protect the hydrologic integrity of  watersheds  through the
     control of storm water run-off and sediment damage, protect
     aquifer recharge areas, and provide  buffers for water supply
     and other natural areas.

     8.   Insulation of environmentally sensitive areas such as
     wetlands  and floodplains are an important open  space function
     of farms,  Many states and counties  are now adopting regula-
     tions to protect these valuable resources and nearly all of
     the protective measures list agriculture as a compatible use,'^
     As long as the farms remain, these areas are protected and
     provide environmental  benefits at no direct cost to the public.

     C.   Wildlife habitat is commonly associated with farmland
     and particularly deer, grouse, quail, pheasant, rabbit and a
     variety of non-game species equally important to the web of
     nature.

-------
0.   The value of agricultural land for waste treatment
is increasing, and will likely become wore important as the
population increases, as treatment plants become more expensive
and difficult to locate, and as the public more readily accepts
the idea of land treatment of municipal sewage.  While there
are several health-related questions, concerning the heavy
metal content of sludge that must be answered before broad-
scale application will be permitted on cropland, the future
potential seems high and could evolve into a major benefit-
assuming there are farmlands remaining near cities to receive
the treatment.

E,   Aesthetic relief from the pressures and living conditions
of urban areas;  pleasure driving still remains a popular form
of outdoor relaxation.

F.   Many areas of scenic or cultural  value, such as unique
landscape or geologic forms, vistas or historic sites, can
be preserved with agricultural land,

G.   Farmland-serves as a geographic buffer between expanding
jurisdictions, punctuating urbanized areas and affording an
opportunity to structure urban development, thereby reducing
and controlling urban sprawl.

H.   The pollution absorption capacity of farmland open space
traps air pollutants such as ozone and sulfur dioxide.  For
example, typical polluted air containing 150 parts per billion
(ppb) ozone would be filtered by a forest of trees 15 feet tall
so that air reaching the forest floor would contain only 30 ppb,
Expressed differently, one acre of woodlot vegetation will trap
the ozone from eight automobiles, or the carbon dioxide from
fifty.  Studies of the ability of vegetation to trap spores of
various fungi show that vegetation is also a very effective
filter for particulate matter.'*

I.   The value of farmland as a form of "landbank" for future
operations is yet another rationale for retention.  Not only
as an approach for waste disposal, but possibly as the site
for a new college or health center.  Although this view is
not consistent with other rationale that call for the permanent
retention of farmland, it does, at a minimum, keep a number of
development options open that might otherwise be foreclosed
through premature conversion of agricultural lands.

-------
Some significant secondary benefits (having environmental im-
plications) resulting from prime farmland preservation include:


A.   Provision of fresh, high quality food at reasonable
cost located close to the consumer, reducing transportation
and energy costs;

B.   Providing productive, tax-paying, privately maintained
agricultural open space with its environmental  benefits, in-
cluding rural aesthetics and enhanced air and water quality;

C.   Contributing to a stable economy by providing job oppor-
tunities, income, a market for farm production, and general
regional self-sufficiency,

0.   Safeguarding reserve food production capacity to meet the
future needs of our population;

E.   Preservation of the farming "'way of life"  with its
unique cherished values as part of diversified  metropolitan
areas;

F.   Contributing to the Nation's balance of payments by
providing food and fiber for export;

G.   Protecting potential mineral resources from being
prematurely exempted;

Several states have recognized these environmental values in
reports or Legislative Actions (See Tab  5),  While each State
or region has unique political and economic circumstances, each
shares the common concern for the loss of productive agricultural
land, and with it, the benefits described above.

-------
4,   BASIS FOR EPA CONCERN

     Agency concern for protection of farmlands is based in the following
     policy directives and statutes:

     a.   EPA's final regulations implementing the requirements of
          NEPA in 40 CFR Part 6 published on April 14, 1975, direct
          the Regional Administrator to "assure that an EIS will be
          prepared on a treatment works facilities plan, 208 plan
          or other appropriate water quality management plan when....
          implementation of the treatment works or plan may directly
          cause or induce changes that	adversely affect significant
          amounts of prime agricultural land or agricultural ooerations
          on this land,"

     b.   A CEQ memorandum for Agency heads, dated August 30, 1975,
          on "Analysis of Impacts on Prime and Unique Farmland in
          Environmental Impact Statements" (See Tab 5 for text); this
          memo seeks to	" assure that such farmlands are not irre-
          versibly converted to other uses unless other national in-
          terests override the importance of preservation or otherwise
          outweigh the environmental benefits derived from their pro-
          tection,"  "	Federal agencies should attempt to determine
          the existence of prime and unique farmlands in the areas of
          impact analyzed in environmental imoact statements prepared
          in compliance with Section 102(25(c) of NEPA."

     c.   The following sections of the Clean Water Act apply:

          i    Section 102{a) requires the Administrator to develop
               comprehensive pollution control programs which give
               due regard to activities such as agriculture.

          ii   Section 201(d) states that the "Administrator shall
               encourage waste treatment management which results
               in the construction of revenue producing facilities
               providing for—(1) the recycling of potential sewage
               pollutants through the production of agriculture,
               silvaculture or aquaculture products or any combination
               thereof-,

          iii  Section 201(f) states that the Administrator shall
               encourage waste treatment management which combines
               "open space"....with such management.

-------
                    10
iv   Section 2Q8(b} says that areawide treatment manage-
     ment plans shall include "a process to (i) identify,
     if appropriate, agriculturally and silviculturally
     related non-point sources of pollution, including
     return flows from irrigated agriculture, and their
     cumulative effects, runoff from manure disposal
     areas, and from land used for livestock and crop
     production, and (ii) set forth procedures and methods
     (including land use requirements) to control the ex-
     tent feasible such sources;"

v    Section 212(2}{A} defines treatment works to include
     "....site acquisition of the land that will be used
     as an integral part of the treatment process (includ-
     ing land use for the storage of treated wastswater in
     land treatment systems prior to land application).,,,"

vi   Section 304(f) states that the Administrator shall
     issue "(1) guidelines for identifying and evaluating
     the nature and extent of non-point sources of oollu-
     tants, and (2) processes, procedures, and methods to
     control pollution resulting from (a) agricultural
     activities, including runoff from fields and crop and
     forest lands;".

The following sections of the Clean Air Act Amendments apply:

i    Section 101(b) states that the purposes of this
     title are to protect and enhance the quality of
     the Nation's air resources so as to promote the
     public health and welfare and productive capacity
     of its population.  Wei fare as defined in Section
     3Q2(h) includes "effects on soils, water, crops,
     vegetation...."

ii   Section 160 identifies purposes of the Act..."to
     preserve, protect, and enhance air quality in.,,,
     areas of special natural or regional natural...,
     value".

iii  Section 316(b) enables the Administrator to "with-
     hold, condition, or restrict".,..construction of
     treatment works which may cause or contribute to
     an increase in emissions of any air pollutant.

-------
e.   The following sections of the Resource Conservation  amT^ecovery
     Act apply:

     i    Section 1002{b}{2) states that disposal of solid
          waste and hazardous waste in or on the land with-
          out careful planning and management can present a
          danger to human health and the environment;"

     ii   Section 1008(a){3) calls for solid waste management
          guidelines which "provide criteria....and define
          practices" for disposing of solid waste in landfills.

     iii  Section 4004(2) requires criteria for sanitary land-
          fills which insure there is	"no reasonable proba-
          bility of adverse effects on health or the environ-
          ment (through the food chain) from disposal of solid
          waste at such facilities".

     iv   Section S002(g) calls for a comprehensive study on
          sludge, including the analysis of	,(1) alternative
          methods for the use of sludge, including agricultural
          applications,..,"

f.   The following section of the Safe Drinking Water Act apply:

     i    Section 1424(b) states that:  "the Administrator may
          so designate an area within a State if he finds that
          the area has one aquifer which is the sole or principle
          drinking water source for the area and which, if con-
          taminated, would create a significant hazard to public
          health.'"

g.   The following sections of Federal Insecticide, Fungicide, and
     Rodenticide Act apply:

     i    Section 3(b}(2) states that "if the Administrator deter-
          mines that a change in the classification of any use of
          a pesticide from general use to restricted use is neces-
          sary to prevent unreasonable adverse  effects on the en-
          vironment, he shall notify the registrant	"

     ii   Section 5(e) states that "the Administrator may revoke
          any experimental use permit, at any time.,,,"

     iii  Section 6(c)(l) states that "if the Administrator deter-
          mines that action is necessary to prevent an imminent
          hazard...,he may suspend the registration of the pesti-
          cide immediately."

-------
                              12
5,    TRENDS IN AGRICULTURAL LAND CONVERSION

     Changes from agricultural lands to other uses, particularly prime
     farmlands to expanding urban uses, have received considerable
     attention in recent years.   Several racent CEQ Annual Reports
     have expressed concern about the environmental consequences of
     these trends J5

     The Soil  Conservation Service (SCS) has recently completed a study
     of non-federal  land that provides up-to-date statistical  data at
     national  and regional levels on (1) land use changes and trends,
     (2) the potential  for converting land in other use to cropland,
     (3) the extent of  land that can be readily converted, and (4) the
     problems  related to developing this land for crop production.  Some
     of its major findings are described below,

     A.   Significant changes in land use have taken place on American's
          non-federal lands between 1967 and 1975.   About 17 million
          acres have been converted to urban and built-up areas, and
          about 7 million acres  have been inundated by water.   During
          that 8-year period, nearly 2.1 [nillion acres were converted
          to urban and  built-up  areas each year.  About 30 percent of
          the  land converted to  urban and' built-up  areas each  year comes
          from cropland.

     B.   Cropland actually farmed declined from 431 million to 400
          million acres.  This decline occurred in  3 of the 10 farm
          production regions.  The exceptions were  the Delta states
          region, where there was a slight increase in cropland acre-
          age, and the  Mountain  region, where the acreage remained
          about the same.  Forest land declined from 445 million to
          375  million acres.  The major decline occurred in the Mountain
          region.  Pastursland and range!and increased significantly,
          from 507 million to 571 million acres. Sains occurred in
          every region.  Land in other uses also increased from 57
          to 70 million acres.

     C.   A "reserve" of about 111 million acrss now in pasture and
          range, forest, or other land uses have high or medium po-
          tential for conversion to cropland.  Of this land, 35 million
          acres can be  converted to cropland simply by beginning till-
          age.  The remaining 76 million acres have impediments that
          will require  additional expense and effort to convert them to
          cropland.   Examples of these impediments  are high density
          forest, seasonal high  water table, or high erosion hazard.

-------
     Changes in land use at the national level indicate that about
     79.2 million acres have gone out of cropland since 1967, and
     48.7 million acres have been converted to cropland during the
     same period.  The net loss to cropland has been 30.5 million
     acres, leaving a total of 400.4 million acres in cropland.

D.   Of the nearly 17 million acres converted to urban and built-up
     areas during the 8-year period, about 60 percent was land in
     capability Classes I - III'7  Of the nearly 7 million acres
     converted to water during the same period, about 40 percent
     was land in capability Classes I-III.  The flow of these land
     use conversions is illustrated in Figure 1 on the following
     page.

     Nearly 30 percent of the land converted to urban and built-up
     areas each year comes from cropland, indicating a cropland loss
     of about 0.6 million acres each year.  About 10 percent of the
     land converted to water areas each year comes from cropland,
     Most comes from land in other uses.  The conversion to urban and
     built-up areas and water is occurring at a greater rate than
     previously estimated.

An important question to be addressed in determining the signifi-
cance of prime farmland conversion is:  How much (uncultivated)
land has the potential for conversion to cropland and with what
degree of effort and investment?  The SCS study points out some
of the problems associated with converting pastureland and range-
land, forest land, and land in other use to cropland.

A.   Of a total of nearly 1 billion acres of non-cropland in the
     United States, only about 111 million acres have high and
     medium potential for conversion to cropland.  The production
     by farm production region is shown in Figure 2.  In 1967 there
     were 266 million acres of non-cropland in Classes I - III
     which have been called potential cropland.  Much of this land
     may have the physical capability, but location, ownership, or
     other factors make it unavailable for crop production.

8.   One hundred eleven million acres of land with high and medium
     potential for conversion to cropland as of 1975 is shown in
     Figure 3.  If new cropland is needed, most would be drawn from
     land in pasture and range.  For all practical purposes, the
     present forest land and'land in other use would yield insignifi-
     cant amounts of new land for cropping.

-------
                               14
                                                           FOREST LAND
                                                              1967-445
                                                              1975-375
CROPLAND
  1967-431
  1975-400
                                        1967-57
                                        1975-70
                     PASTURELAND & RANGELAND
                               1967-SQ7
                               1975-571
       '  •• 1967 acnsage
	— 1975 acreage
  FIGURE  1:
                                 4 —^ Acres diangcd to inoth*r land use
                                ifc    idl« iand, rurai rssiderica, etc,
                                A    Water & urtsan buiit-up since 1967
                    Land ia« caivafstons between 1967 and 1975 (fr»(lion acres).
          (SOURCE:  POTENTIAL CROPLAND STUDY,  SCS,  USDA)

-------
                             15
           TABLE!—Undusa by faun production rtgion—1958, 1967, and 1975
                            [thousand acres ]

1958
Cropland Pasture and range ftxest Qtner land
1967 1975 1358 5967 1975 1958 19S7 1975 1953 1967 1375
Northeaai ....
Lake stales . . .
Com Belt
Northern Plains. .
Appalachian , .
Souifieast . . .
DtHia states
Southern Plains. .
Mountain 	
Pacific ,
AK, HI, PR. VI .
20,907
14.387
94.720
93,895
27,362
20.385
20,719
56,251
42,^39
25.776
338
31.169
46,538
92,427
94,138
23,406
19.238
19,145
48,023
4Q.S23
25.337
1,063
17,344
44,194
96.729
30,754
20,303
16,519
20.239
41.062
40.333
21.92S
$69
7.991
3.811
21,935
33,902
15.657
13.930
9,331
109,447
132.533
31.130
543
5,334
7,914
23,492
31.553
18,412
13,553
12.166
119.437
138,533
33.306
1.383
7.345
7,989
39,252
85,043
21.874
13,810
12.475
139.227
308, 65S
37.998
2.220
S5.313
43,474
28.073
3.372
64.014
70,392
48,559
33.737
42.185
46,547
3.079
75,170
46.024
23,502
2.336
55,230
73,293
47 199
31,056
35.813
43,029
3,300
52,955
42.519
25,516
1.511
53,066
SS.235
44,401
16.S65
14,559
-35,403
2.533
7,832
9,101
8.533
2.4S7
6.148
8.313
4.724
2,94$
8,680
7.528
772
5,318 9,065
7.44311,876
6.212 7.502
3,323 4.132
4,060 3,410
5,325 5.006
4,115 4,585
2.651 1,782
9.545 9. 345
7,002 10.915
1,667 2.232
FIGURE 2:
         (SOURCE;
  production regions in tfw-Umwd SbMW.

POTENTIAL  CROPLAND STUDY, SCS/USDA)

-------
                    T»aui 2,—Land capability ctass oi tna 1975 craoiand acrssga by
                                   /aim orocKJCtioft region
                                      i million awes 1
r*3fnT QIQC3UCtTonT C&SSSS
ragion !-
Norths
Lane 3
Corn =
NortHs
i;t
|St 	 	 . 14
tsies . . . . 	 35
]e,t 	 3{

)
3
5
Aapaiachian 	 1 a
Soutneaa. 	 is
Data statas. . ... <9
Sowrs
\dount;
Pacific
AK HI
nso
1000
aoo
600
400
209

tn Rains. . 3J
iin - 3C
	 t"
PR. V) . . , (
~~" 1967
—
286
Wft^^^^i.
Wl^^^SSS^-
I
r
w




Class Classes
iV V-VHI
2.0 1.3
3-7 1.5
4.7 1.6
9.Q 4,2
1.4 1.3
2.7 ,S :
3 .9 :
3.4 1.3
73 2.3
4.3 1.0
.1 2


73S
fteSiisilg^e
^SSf^Jlp^K*
^^i'j^?^^^^.^^;^..-
^•'"^'^^'cVuV-^'K-'-'^-l'^n.^-1'
                                      I to 111
                                                           tV to Vttl
                   1200
                   1000
                    300

                i
                S   aoo
                    400
                   aoo
                                       1975
                                                             90S
                                                           Lowor^trc
FIGURE  3:
                   Total noniederat land in usas otner *nan qropiana in '967 ay capacility class

                                  ay potanttai (dr conwarsion in 1975.
                          SOURCE:   POTENTIAL  CROPLAND STUDY

-------
                         17
C.   Of the 78.3 million acres of land with high potential for
     conversion to cropland, 34.9 million acres have no problems
     and conversion can be accomplished by simply beginning till-
     age.  The remaining 43.4 million acres have one or more
     problems that must be considered before conversion to crop-
     land.  For example, 14.1 million acres have a wind and water
     erosion hazard that will require installation of conservation
     practices.  Such practices are, however, relatively Inexpensive
     and can be installed by individual landowners.

D.   Although nearly 33 million acres have medium potential for
     conversion to cropland.  Most of it will require significant
     investments if converted to cropland.

E,   About 905 million acres have low or zero potential for con-
     version to cropland.   Some of this land is committed to non-
     cropland use (220 million acres), has a high erosion hazard
     (224 million acres),  or supports a high density forast (179
     million acres).   About 20 percent of the low and zero potential
     land is in capability Classes I - III, but problems with con-
     version are such that it is unlikely that this high-quality
     land will  be used for cropland.

Overall, farmland conversion trends have resulted in a cropland
base of 400 million acres  in 1975,  There were 111 million acres
with high and medium potential for conversion to crooland, of
which only 34.9 million acres can be converted without the appli-
cation of significant conservation practices.

Although the total  cropland in the United States remains about
the same as it was  in 1967, there is a continuing shift^S  of land
going in and out of production.  When new land with a potential
for conversion to cropland is brought into production, nearly
two-thirds of it will have conservation problems that must be
addressed.  Shifts  of 1967 cropland to urban and built-up by
1975 suggest that the investment in conservation has been lost
on much of the 17 million acres converted to that use.  This
may also be true for another 24 million acres being held for
future urban use.

The availability of land that can be converted to cropland and
the rate of land lost to irreversible uses suggest that the scarcity
of land and the pressures  on existing cropland will be greatest
in the Northeast, Appalachian, Pacific, and Lake state regions.

-------
                         18
The reasons that suitable land hasn't been converted to cropland
In the 150 to 200 years of cropland development Include:  Fragmented owner-
ship, size and location of an area, and commitment to other  uses
set the pace of conversion.  For instance, more than 24 million
acres of land ara now held for urban and built-up use.   At least
one-half of this acreage is of good quality, but because it  is
isolated by urban development, zoned for development, or not
economically feasible to crop, it remains underused.

In conclusion, increasing national  and world needs for agricultural
products indicate that cropland will be used more intensively and
that other land, some of it marginal, will be converted to crop-
land.  Urban development is taking  place on some of the Nation's
best cropland but energy and environmental requirements may  limit
the use of the marginal land for cropping.  Together, these
factors will affect our future cropland base, our potential  for
growing food and fiber, and the overall significance of agricultural
lands as an environmental resource.

-------
                                19
6.   ENVIRONMENTAL VARIABLES IN AGRICULTURAL PRODUCTION

     Many variables enter into and affect agricultural  activities in
     our country.   Some can be thought of as "internal" variables
     which directly affect the biological process of the food or fiber
     production.  Examples of these "internal" variables might include
     the quality of soil, tilling methods and fertilizer used, amounts
     of available water, etc.  Other variable, can be considered exo-
     genous and outside the bounds of the biological  production process,
     but cause direct and secondary effects which result in changes
     in agricultural activities.   Examples of such "external" variables
     include foreign food demands, expanding U.S. population, urban
     development pressures, price supports, transportation and market-
     ing effects, etc.

     In an effort to illustrate agricultural activity as a set of inter-
     related components, a simplified operating formula'^  is presented,
     Reducing the basic relationships to their simplest terms, it can  be
     said that agricultural production (P) is a function of climate  (C)
     (in all its aspects), plus various forms of environmental manipula-
     tion through technology (I), consumption of energy (t), and invest
     ment (I) of capital and labor by the former, together multiplied  by
     the amount and quality of the land (1), under cultivation.  Hence,
     P is a function of L (C + T + E + I),

     For production to remain constant in this formula, a decline in
     the amount and quality of land, (within limits), can easily be
     balanced by improvements in climate and technology.  This has been
     the case up to now.  If, however, climate is unfavorable there  is
     no improvement in technology, or energy efficiency, (or if there
     is even a degree of unpredictability}, then land of high capability
     must be cropped, or land of lower capability must be improved with
     conservation measures if a given level of production is to be main-
     tained.

     Uncertain weather patterns, competition for water and air, effects
     of pollution (e.g., acid rain and salinity), increasing costs and
     scarcities of fertilizers, fuels and other supplies, and environ-
     mental management constraints on farming practices have all affected
     production.  It is becoming apparent that if high levels of pro-
     ductivity are to be maintained, and if yields per acre are not  in-
     creasing, then land supply itself becomes the critical  variable..

-------
                           20
A shift in the supply of prime farmlands to marginally produc-
tive lands could lead to a greater reliance on environmental
manipulation through technology, which in turn will  place greater
demands on energy supply and environmental  modification of land.
Increasing the use of and dependency on lower-capability crop-
lands, despite careful management practices, has nearly always
led to environmental degradation.

Thus, an adjustment in the variables of this formula will pose
trade-offs between agricultural productivity, our national economy,
the economy of agricultural support industries, and  environmental
quality.  At a time when world food supplies appear  to be more
important than ever before, the United States^could  actually be
diminishing its productive farmland reserves.    Environmental
significance stands as one of several  important roles along with
food production and the economy, played by farmlands in the pro-
duction cycle.

-------
                               21
7.    DEFINING ENYIRORMEHTAU.Y SIGNI-FISAHT AGRICULTURAL  LAND

     From an agricultural  perspective, soil  capability  emerges  as  the
     most important characterization of farmland types.  Categories
     of "prime" ana "unique"2'  connote productive capacity,  while
     categories of "state-wide" and "local importance"  connote  an
     economic and land value role which supports agricultural activi-
     ties in a community.

     From an environmental  perspective, all  farmland is important  in
     serving as a natural  filter and buffer role, and farming on prime
     lands enables high production to be achieved with  relatively  low
     environmental damage.22  Likewise, certain farmlands, by virtue
     of their location in  urbanizing areas,  their particular  soil
     structure, and their  strategic proximity to environmentally sensi-
     tive areas, facilitate non-structural solutions for environmental
     management.

     In order to provide a basis for understanding the  environmental
     significance and importance of farmlands, several  categorical
     definitions are set forth below,  (See  Tab  7  for  detailed
     definitions of types  A - 0).

     A.   Prime farm!and is land that has the best combination  of
     physical and chemical  characteristics for producing food,  feed,
     forage, fiber, and oilseed crops, and is also available  for these
     uses (the land could  be cropland, pasture!and, rangeland,  forest
     land, or other land,  but not built-up land or water).   It  has the
     soil quality, growing season, and moisture supply  needed to
     economically produce  sustained high yields of crops when treated
     and managed, including water management, according to acceptable
     farming methods.  In  general, prime farmlands have an adequate
     and dependable water supply from precipitation or  irrigation, a
     favorable temperature and growing season, acceptable acidity  or
     alkalinity, acceptable salt and sodium content, and few  or no
     rocks.  They are permeable to water and air.  Prime farmlands are
     not excessively erodible or saturated with water for a  long period
     of time, and they either do not flood frequently or are  protected
     from flooding.

     B.   Unique farmland  is land other than prime farmland  that is
     used for the production of specific high value food and  fiber
     crops.  It has the special combination of soil quality,  location,

-------
                           22
 growing  season,  and moisture supply needed to economically produce
 sustained  high waulity  and/or high yields of a specific crop when
 treated  and managed according to acceptable farming methods.  Ex-
 amples of  such crops are citrus, tree nuts, olives, cranberries,
 fruits,  and vegetables,

 C.   Additional  Farmland of Statewide Importance is, in addition
 to  prime and  unique farmlands, of statewide importance for the
 production of food, feed, fiber, forage, and oilseed crops.  Cri-
 teria for  defining and  delineating this land are to be determined
 by  the appropriate State agency or agencies.  Generally, Additional
 Farmlands  of  Statewide  Importance include those that are nearly
 prime farmland and that economically produce high yields of crops
 when treated  and managed according to acceptable farming methods.
 Some may produce as high a yield as prime farmlands if conditions
 are favorable.   In some States, additional farmlands of statewide
 importance may include  tracts of land that have been designated
 for agriculture  by State law.  (See Tab 8 for an illustration of
 unique farmlands).
 0.   Additional  Farmland of Local Importance are not identified as
 having national  or statewide importance.!7T some local areas,
 however, it is economically important and environmentally sound
 for certain additional  farmlands for the production of food, feed,
 fiber,-forage, and oilseed crops.  Where appropriate, these lands
 are to be  identified by the local agencies concerned.  Additional
 Farmlands  of  Local Importance may include tracts of land that have
 been designated  for agriculture by local ordinance.

 £.   Farmlands in or Contiguous  to^jnvir_onmentallySensitive Areas
 (ESA'sT,  such  as  floodpTains,  wetlands,  aquifeF7ecnarge  zones,  or
natural  scientific  study areas;  these  farmlands  play  a  crucial
environmental  buffer role  to  prevent development encroachment on
ESA's  thereby  aiding in maintaining  their  capability  to remain
environmentally  productive  and stable.

-------
                              23
F.   Farmlands of Waste Utilization Importance which may serve in the
land treatment process, be used for composting activities or
for controlled beneficial application of sewage sludges or other
wastes.

G.   FarmlI andsjnth__Sj.gnifi.cant Capi tal Investments in Best
Managenientr PT'actTces"(BMP'sj, which serve as elements of an area's
(or"state's) soil erosion and non-point source pollution control
plans.

While the categorical term "prime land" means the best productive
land, it is not the only category of environmental significance.
Categories of prime and unique farmlands connote productive capa-
city, and farmlands of state-wide and local importance connote
economic and land value.  The relative environmental value of
farmland in an urbanizing metropolitan area is also significant,
especially as it becomes a smaller fraction of the toral land use.
All farmland is important, however, in serving assimilative
functions which aid in maintaining environmental quality.

-------
                                24
8.   WHY FARMLANDS ARE LOST

     Comfining urbanization to limited areas might appear to preserve
     agricultural land fry avoiding dispersion and sprawl, but history
     shows us that cropland is twice as likely as non-cropland to be
     urbanized.  For several reasons, cities have tended to grow in
     precisely those areas wfiere some of the best farmlands occur.
     Throughout the world, civilizations have tended to develop in
     river basins, where rich, deep soils, level topography, and ample
     water were available.    Urban centers developed close to farm
     populations, and, as they expanded, tended to cover level, well-
     drained land.  Most major cities are located on major waterways
     that provided water for municipal use and transportation, as well
     as a disposal system for sewage and industrial  wastes.  Highways
     and railroads within and between urban areas also generally fol-
     lowed the flat river basins which contain some  of the best agri-
     cultural land.  Thus, our evolutionary patterns of urban growth
     tended to have built-in land use conflicts which fostered con-
     version of our best farmlands.

     Many factors can lead to premature conversion of farmland.  One
     set of factors surrounds the use of federal grants-in-aid which
     provide financial assistance for community infrastructure and
     new development.  All too often these capital improvements (which
     guide future growth) are planned and built on the assumption that
     farmlands are not the highest and best use.   In other words,
     federal infrastructure grants for sewers, highways, and other
     capital improvements do not recognize that farmlands are a finite
     agricultural and environmental resource which is absolutely, cumu-
     latively, and irretreivably diminished as a result of .federal actions.

     Another set of factors has to do with the unique economic problems
     faced by fanners on the urban-rural fringe.  As urbanization pressures
     emerge, the cost of land begins to rise, often  pushed upward by
     speculation.  The dilemma is that good farmland is also good for urban
     development.  As the cost of adjacent land increases, so do property
     taxes and estate and inheritance taxes.  Soon the urban development value
     outweighs the productive resource value of the  land.  Thus} the
     farmer-owner is burdened with taxes which often bear no relationship
     to the profitability of fhis agricultural enterprise, and is induced
     to profit from changes in land value.

     A third set of factors24 has to do with encroachment of urban-
     oriented uses and their impacts on agricultural activities:
     pilfering and needless destruction of crops and farm equipment

-------
                           25
by people, increased traffic making it difficult and dangerous to
drive farm machinery on the roads, and complaints from neighbors
concerning the application of manure, fertilizer, and pesticides,
In some cases* as suburbanites gain political power, their com-
plaints have been enacted into ordinances which restrict normal
farming practices.  Further, farmers are often assessed for new
water and sewer lines which run through their property, even though
they don't use them.

All these factors change the individual farmer's view of the future,
and once he is convinced that his area will eventually be urbanized,
he stops investing in improvements to his farm.  An "impermanence
syndrome'     sets in and a transition from farming activities is
almost assured.  This phenomenon may precede a change in land use
by as much as 20 years.  Figure 4 illustrates the range of farmers'
responses to urbanization.

As urban pressures begin to weigh on agricultural operations, a
chain of events is set in motion.  Rising taxes and development
pressure begin to take their toll on neighboring farms; as the
number of farms begins to decline, the important support industries,
such as feed and grain dealers, farm equipment outlets, ate,, begin
to leave the area because there simply isn't enough business; in
dairy areas the milk processors often begin to leave for more pro-
ductive "milk sheds" that can continue to provide adequate sources
of raw milk.  In time, farm labor becomes more expensive and scarce
as higher paying jobs "in the city" come within reasonable commuting
distance for the rural labor force; the farmer slowly feels his
political strength drain away as country and local governments
become dominated by suburban, non-farm residents who often begin
passing "nuisance" ordinances which keep slow moving vehicles (such
as tractors) off local roads during certain hours of the day, or
"health ordinances" which prevent the spread of manure during certain
weather conditions.

Eventually, farmers often begin to make management decisions based
on the opinion that they will not realize a return on further
investment in farming.  Conservation improvements such as terracing
and soil conditioning which are environmentally beneficial tend to
be neglected.  Consequently, no new investments in improved and more
efficient farm equipment are made, nor is available land purchased
for expanded operations.  Typically,-the farmer's profit margin
begins to shrink.  For example, feed and grain often becomes more
expensive because remaining suppliers have to travel further for
delivery and no longer deal in cost-saving volumes, and farm cofimod-
ities must be shipped to more distant processors—a direct cost to

-------
                                                      Figure   4:

                        FARMERS'  RESPONSES TO  URBANIZATION  IN  THE CONTEXT  OF

                                  OTHER  EXOGENOUS FORCES  AND  CONSTRAINTS

                            SOURCE:   SAVING THE  GARDEN, CQUGHUM,,_ET.  AL. ,  PAGE  75
             EXOGENOUS FORCES
             AND CONSTRAINTS
                                       SPILLOVER
                                        EFFECTS
                                                             CHANCES IN
                                                                1 ATTITUDES
CHANCES  IH LANDSCAPE
AND FAftHING ACTIVITY
•rl I-
u u
    e
   ' o
       Urbanifcfltlbn and  j

                     on |
          population
Soil characteristics
Land surface focra
Climatic  variation
Etc.
                      shift in
           In Iran true tut a
•o o
C 1*.
Oi'H
a ^
»J •-«
       u.-vu] .11,inn of ajjr icul tur*
       I'axal i"(i
        Jtu!  .•w,n;[ :,111 () p:icLuiri:.
       fu.
                            Regulation of farming
                            Incceasutl taxation
                            Pollution d(image
                            Duatructlon of crops
                            Etc,
                in demand
          agricultural products
                                                                                 SWOttOHE
                                                             Speculation  in  land
                                                             Uls liwciKBiiot  iu  iJrras
                                                             1>1 s>:jiifji^tMiiiJUt  u£ youagtr
                                                               fjcintrs
                                                             €U.iii|;t' in f ntmc-i'S ' sttiL\>a
                                                             Uiffcttnttat  ability to copu
                                                                                             Conversion of land
            [Large f>o
          -"1  of, Ijn
                                                                                                                      portion
                                                                                                                        d
                                                                                                   in  crop and
                                                                                                   ns
                                                                                                  of relatively
                                                                                             Changes  in crop and
                                                                                               patterns
                                                                                             Uct 1 1 euiL'nr of icelatl
                                                                                                   in farm
                                                                                            Exfj;inr-t on o£  farming onto
                                                                                             pr<-*utouaty  unfarraed land

-------
                           27
the fanner.  This is ironic, since many fanners in these situations
have marketing advantages of being in close proximity to consumers,
and have an option to grow crops such as vegetables for local  high-
value markets.

For those who wish to remain in farming, the choices come down to
hanging on for as long as possible and then selling to the highest
bidder, usually a developer, or selling out and moving the operation
to an area that has a stronger agricultural community.

The underlying point to these illustrations is that once the im-
permanence syndrome takes effect within an agricultural communitys
it becomes a self-fulfilling prophecy.  A county which has a number
of farms may point with pride to the active, producing areas but
those who farm the land may be preparing for what they view as
inevitable abandonment of fanning.  Those that do remain most often
farm as a hobby.  Young people interested in fanning simply can't
buy in unless they are prepared to make a several hundred thousand
dollar investment.

Under these constraints, farming as an industry can't survive in
the area, leaving scattered remnants of hobby farming or estates
which may or may not remain open land over time.  A "critical
mass" of farming activities must be maintained in order to keep
an agriculture functioning viable in a community.

-------
                                 28
9.   STATE-OF-THE-ART APPROACHES FOR FARMLAND RETENTION
                                                        ?fi
     A wide variety of approaches for farmland retention   have been
     tried and discussed extensively.  This is a reflection of the
     many-faceted nature of the problem, the differing characteristics
     of agriculture, urban development, and political  attitudes in
     various regions, and of the relatively short time during which
     the loss of agricultural  land in the urban-rural  fringe has been
     recognized as an important public issue.  This diversity is further
     compounded by the variable involvement of different levels of gov-
     ernment {e.g., federal, state,  and local) and the agricultural,
     environmental, and infrastructure-development programs directed to
     the individual farmer.   The loss of agricultural  land is influenced
     by the marketplace as well as by the complex pattern of programs
     which sometimes induce farmland conversion (e.g., federal grants
     for sewer interceptors or highways) or sometimes  foster farmland
     retention (e.g., state development rights purchase legislation).

     The intention here is to  identify current approaches for farmland
     retention, their role in  mitigating the environmental effects of
     farmland conversion, their general effectiveness, and the apparent
     void created by a lack of applicable tools at the federal level
     to address the problem.

     The major approaches to farmland retention may be classified as
     either "Direct" or "Indirect" methods.''  Direct  methods are those
     which directly control  what the land can be used  for, either by
     the purchases of rights in land or through the regulatory power
     of government.  Indirect  methods are focused primarily on allevi-
     ating the problem of the  farmer caused by nearly  urbanization,

     One example of a "Direct  Method" uses market interventions such as
     the purchase of development rights in land by a public body, leaving
     the private owner the right to  use his land for agriculture and
     other uses but not to develop it, the right to keep others off it,
     the right to sell or lease it,  and the responsibility to pay real
     estate taxes on it.   Important  demonstration projects using this
     method are now being conducted  by
     Suffolk County, New York  {see Tab 9 for newsclips of these case
     examples).  Massachusetts has just passed a law implementing this
     approach and the California legislature has recently considered a
     similar proposal (see Tab 10 for 'description of these lav/).  Be-
     cause of the public cost  involved, however, it may be possible to
     apply such methods to only a limited portion of endangered farmland.

-------
                           29
"Indirect Methods" of farmland retention include taxes and other
measures which help the farmer to continue to farm or which re-
duce the profit incentive of the speculator or developer.  Tax
concessions are the most widely adopted of these measures.  Dif-
ferential assessment of real estate for property tax purposes has
been instituted by some 42 states.    Under it, farmland is assessed
at its value as a factor in agricultural production rather than at
its market value for urban development, which in urban-rural fringe
areas tends to be much higher.

Tax concessions and agricultural districting can protect the farmer
from many but not all of the problems caused by nearby urbanization,
They make it easier for him to continue farming, but do not prevent
him from developing his land.  It seems safe to say that to retain
farmland both direct and indirect measures will be necessary:  In-
direct measures to insure that farming is economically viable, and
direct measures to prevent farm owners from selling to developers to
reap financial gain much faster than they could by continued farming.

A third ingredient must also be considered as a "measure" of influ-
ence on farmland retention:  The impact of federal program policies
and decisions, which affect farmland conversion and are not easily
controllable by Direct or Indirect Measures.  Neither direct measures
alone nor indirect measures alone are likely to be effective in re-
taining farmland for a significant period of time.

Historically, efforts have-.been devoted to  pursuade
farmer through indirect measures, but to shy away from restricting
the possibility of development (direct measures).  As a result,
states often favor some form of differential assessment.  An advan-
tageous Federal estate tax is enjoyed by all farmers in the United
States, and participation in New York's Agricultural Districting
Program has been high, but only a handful of states have instituted
any kind of direct measure to retain farmland under pressure of
urbanization.

Several emerging trends    in agricultural open space-land use policy
in this country will affect the future ability to employ various
"measures":

     o    There is increasing recognition of the need to control
     the forces stimulating urban/suburban expansion.  Effective
     growth management programs may help reduce urban/suburban
     pressures on the rural landscape and thereby increase the
     effectiveness of well designed farmland retention programs.

-------
                            30
      o     As  is  true  in  the  case  of  general  land-use  management
      programs,  the  role  of the  state in  agricultural  and  open-
      space land-use planning and  policy  has  increased.  An
      increased  state  role  will  stimulate local  governments  to
      increase their land-use management  capabilities.

      o     Public policy  makers  are more  aware of the  need to
      exploit  the interdependence   among different land-use
      control  techniques.

      o     The issue of what  is  "fair"  compensation for  regulation-
      induced  reductions  in property  value will  become more  important.
      As  the need for  accommodation of the legitimate  interests of
      both  government  and private  landowners  becomes increasingly
      evident, the search for programs  based  on  compromise will
      intensify.

      o     The virtues  of incremental ism  in  land resource  protection
      programs are becoming more widely appreciated.
The conclusion drawn from the effectiveness of current efforts is
that marketplace intervention techniques alone will  not halt the
conversion of prime and environmentally significant farmlands.  An
outline of important considerations for farmland retention strategies
at the State and local government level is listed in Tab 11.  While
hope is held out for .approaches like the one in Suffolk County,
New York, or though enactment31  of the Jeffords Bill  (see Tab 12)
at a national level, other avenues must be sought at each government
level concerned with maintaining the environmental  value of farmlands.

-------
                                31
10.   EPA PROGRAM IMPACTS ON AGRICULTURAL LAND

     In an attempt to assess the potential  positive or adverse impacts
     of EPA programs on agricultural  lands, several factors which ulti-
     mately affect environmental quality are drawn from the previous
     discussion; first, those factors which directly (or indirectly)
     induce conversion of agricultural land to another use; second,
     those factors which might cause  increased costs of fanning activi-
     ties leading to premature conversion,  third, those factors which
     might affect farmland productivity leading to premature conversion,
     fourth, those factors which might affect and/or complicate agricul-
     tural practices, and f_ifth_» those factors which affect the farming
     way of life or the scaTe~~of farming activity leading to premature
     conversion.
                        32
     EPA program impacts   affecting  each of these factors are outlined
     be!ow:

     A.   Program Impacts Which Hay Induce  Change ina Farmland Usj

               Air Programs:  Air Quality Standards in Non-attainment
          Areas may limit location of new industries, reduce urban
          development density, lead to a lower density distribution of
          growth, and conversion of farmlands on metropolitan fringes.
          Agency decisions affecting  air quality plans may encourage
          the dispersal of air pollution sources, or may unwittingly
          encourage secondary urban development in agricultural areas.
          Agricultural lands classified under PSD could be protected
          with a higher degree of air quality.

               Water Quality Planning:  Land Use Elements of 208 plans
          could affect land uses on farms as well as land adjacent to
          farmlands, inducing conversion;

               Facilities Planning:  Induces land use change directly
          by providing reserve sewage capacity, and may increase land
          values for agricultural  lands as  a secondary effect; land
          treatment systems for municipal wastewater could aid in re-
          taining farmlands where in  proximity to urban areas.

               Water Supply:  Sole source aquifer identification and
          designation could give greater consideration to retention
          of farmlands within the aquifer recharge zone.  Competition
          between urbanizing areas and agricultural uses for limited
          water supplies can induce farmland conversion.

-------
                      32
     Solid Waste:  Site selection factors for landfills
could fnduce farmland conversion; Application of high
cadmium municipal sludges, or other heavy metal-laden
sludges, could "permanently" remove farmlands from food
production.

     Toxic Substances:  Program decisions may cause changes
in pesticides which could change crops grown in certain
areas, or the "feasibility" of growing certain crops in
certain areas, leading to a conversion of farmland.

     NEPA Review:  NEPA reviews and environmental  assess-
ments could lead to grant conditioning which could affect
agricultural land use changes.  NEPA review activities may
substantially modify the outcome of other program and
project decisions, particularly facilities planning and
water quality planning.

IncreasedFarming Costs

     Air Programs:  Fuel changes for improving air quality
made in response to an SIP would be passed on to farmers
and could increase operating costs;

     Water Quality Planning:  Best Management Practices
(SMP's) required to implement a 208 plan may increase
capital or operating costs in the short run, but serve to
protect the land base which permits profitable agricultural
use in the long run.  BMP's prevent or abate pollution,
having a positive economic benefit for surrounding communi-
ties.  Also, BMP's such as no-till or minimum tillage serve
to reduce farming costs.

     Facilities Planning:  Installation of a facilities
treatment plant or interceptors in or near farmlands usually
imposes assessment increases for farmers.

     Water Supply:  In scarce water regions where potable
water is used for agricultural irrigation, expansion of
community water supply facilities and service imposes greater
competition for water and can lead to increased farming costs.

     Solid Waste:  Land application of sludge (if readily
available and if risks are removed) could be economically
beneficial;

-------
                      33
     Toxic Substances:  While yields are increased, use of
pesticides generally increases costs; additional controls
add to these costs;

     Integrated Pest Management (IPM) could lead to reduced
costs for crop production, and therefore, net fanning income*,

     NEPA Review:  Mitigation measures may affect costs.

Effects on Farm]and Productiyity

     Air Programs:  Aimed at reduction of acid rain and
oxidants, generally limiting the adverse effects of pollu-
tants on crops, and improving productivity;

     Hater Quality Planning:  Aimed at reducing soil  erosion
and salinity thus improving productivity;

     Facilities Planning:  Sludge application and spray
irrigation could increase productivity, but potential
danger of heavy ratals build up and up-take exists;

     Water Supply:  Agency policies on the supply of irri-
gation water would affect productivity;

     Solid Waste:  Control of landfill sites should prevent
soil contamination, and protect productivity;

     Toxic Substances:  Controls should prolong soil
productivity;

     NEPA Review:  Mitigation measures may affect productivity,

Effects on Agr|cuVtu_ra1 Practices

     Air Programs:  Possible effects from fugitive dust
controls;

     Water Quality Planning:  BMP's can call for a change
in agricultural practices, structural controls, relocation
of production units, or even land use change; NPDES permit
program may have similar impacts.  Non-point source controls
will result in reduction of agricultural-related pollutants,
(sediment, nutrients, pesticides, salts, etc.);

-------
                           34
          Facilities Planning:   May indues greater lancfspreading,
     wastewater reclamation and reduced demand for Irrigation
     water;
          Water Supply:   No apparent impact;
          Solid Waste:   Greater emphasis on recovery and recycling
     of agricultural Cand other) wastes may change practices;
          Toxic Substances;  Tends  to induce more sophisticated
     farming practices;  could foster integrated pest management;
          NEPA Review:   Mitigation  measures may affect practices;
E.    Effects on the Scale of Farming Activity
          Air Programs:   No apparent impact;
          Water Quality Management:  Application of BMP's for
     small farms could  be burdensome and cause pressure for change,
     especially those that are marginally profitable;
          Facilities Planning:   Potential assessment charges could
     adversely affect small farms;
          Water Supply:   No apparent impact;
          Toxic Substances:  Could  favor larger farms over smaller
     ones if, pesticides and application techniques become highly
     sophisticated;
          NEPA Review:   No apparent impact.

-------
                               FOOTNOTES
1.   For a more elaborate narrative description of these operational
     interrelationships, see Section 6, Environmental Variables in
     Agricultural  Production.

2.   No specific piece of literature has outlined all the consequences
     listed here.   However, many are found in "Conservation of the Land,
     and the Use of Waste Materials for Man's Benefits", a Committee
     Print prepared for the Senate Committee on Agriculture and Forestry,
     March 25, 1975.  Also, the works of Charles Little and Dallas Miner
     (cited later) were used to identify these consequences.

3.   National Research Council Committee on Agriculture and the Environ-
     ment, ProductiveAgriculture^ and a Quality Environment, National
     Academy of Sciences, Washington, D.C.  1974.

4.   From a National Program of Research for Environmental Quality -
     Pollution in Relation to Agriculture, prepared by USDA, Washington,
     D.C., 1968

5.   G. Nelson, in "Food for Billions", special publication No. 11,
     pp. 27-30, American Society of Agronomy, Madison, Wisconsin,
     1968

6.   J. 8. Stall, in "Public Works", Vol. 93, Mo. 3, page 125, 1962

7.   G. H. Wadleigh and R, S. Oyol, in Agronomy and Health, pp. 9-19,
     American Society of Agronomy, Madison, Wisconsin, 1970

8,   U.S. National Resources Board, "Soil Erosion, A Critical Problem
     in American Agriculture", page 5, Washington, D.C., 1935

9.   David Pimentel, et. al., "Land Degradation:  Effects on Food and
     Energy Resources", in Sclence, Volume 192, 3, October 1976

10.  See The Growth Shapers, prepared for CEQ by Urban Systems Research
     and Engineering, U.S.G.P.O., Washington, D.C, May, 1976

11.  See Section 7 for a description of various types of farmland and
     their environmental significance.

12.  The most useful single source which discusses benefits of farmland
     is Farmland Retention in the Metropolitan Washington Area by Dallas
     Miner, prepared for the Metropolitan Washington Council of Govern-
     ments, June, 1976, pp. 32-33

-------
13.   See the 1977 edition of Summary of Sjate Land:JJse Controls published
     by Land Use Planning Reports^ Silver"Tprlng,"Maryland for a survey
     of agricultural  lands retention regulations currently enacted.

14.   See Open Space As An Air Resource Management Measure, by the EPA
     Office of Air and Waste Management, October 1976 (EPA-45Q/3-76-Q28),
     for sink and emission factors for soil and vegetative open space,

15,   See CEQ's-Eighth Annual Report (1977)s pp. 90-91, CEQ's Seventh
     Annual Report (1976), pp.  73-74,  and CEQ's Fifth Annual Report
     (1974), pp. 68-72.

16   Potential Cropland Study_,  by Raymond I, Dideriksen, et. al., Soil
     Conservation Service, USDA, Statistical Bulletin No. 578, October,
     1978

17.   See Potential Crop!and Study (Ibid), Appendix III, for definition
     of Soil Capability Classes.

18.   Agricultural land use shifts occur through principles of substitution
     and competition.  For example, high wheat prices, particularly
     when accompanied by low feeder cattle prices, induce increased wheat
     production on marginal land fragile lands.  The same reasoning applies
     to corn, soybeans, cotton  and feed-grain lands.  Most land uses are
     interlinked and shift back and forth in response to changes in pro-
     duct prices and factor costs emanating from foreign and domestic
     demands and supplies.

19.   This formula was originally articulated in simpler terms by Charles
     E. Little of the Congressional Research Service for a Library of
     Congress Workshop held on  February 8, 1977. Publication available
     from the author.

20-   Potential Cropland Study,  op cit

21.   Farmland categories were defined by the Soil Conservation Service,
     USDA, in 7 CFR Part 557 Prime and Unique Farmlands

22.   See reasoning in Section 2, Environmental Conferences of Farmland
     Conversion, and the efforts of shifts from prime to marginal crop-
     1ands.

23.   See Origins of the St ate and Civilization,  by E.R. Service, Norton
     Publishing Co, New York, 1975

-------
24.  These factors are described in more detail by Robert E, Cough!in,
     at. al., in Saving the Sarden:  The Preservation of Farmland and
     Other Environmentany Valuable Land,' a 'preliminary Report to the
     National Science foundation, ""'(RANK)", August, 1977, pp. S3-55

25.  Some of the spinoffs of the "impermanence syndrome" cited by
     Coughl^n, ibid, include:  land speculation, disinvestment in farms,
     discouragement of younger farmers starting out, a differential in
     the farmer's ability to cope, and legal and political reacting,

26.  The often-used phrase "farmland preservation" Is avoided in this
     paper, in favor of "farmland retention".  The term "preservation"
     suggests an absolute inflexibility in saving farmland regardless
     of cost.  Farmland retention implies that options are kept open
     and that future community goals might be best served by develop-
     ment on croplands under one set of circumstances, and permanent
     dedication to agricultural use under another,

27.  This taxonomy of methods is described in some detail in Coughlin
     Saying the Garden, op cit, and in "Land Use Policy and Farmland
     Retention:  The United States Experience", NRE Working Paper No.
     28, by Greg S. Gustafson, ERS, USDA, Corvallis, Oregon.

28.  See the 1977 edition of Land Use Planning Reports Summary of
     State Land Use Controls, available from BPI, P.O. Box 1967,
     Silver Spring, Maryland

29.  See Tab 4 for examples in New York, New Jersey, Massachusetts, and
     Maryland

30.  See NRE Working Paper No. 28, by Greg G. Sustafson, (cited in
     Footnote 27), page 28

31.  The so-called Jeffords Sill is currently being considered in
     Committee by both the House and Senate.  Likelihood of its passage
     is unclear, and the Administration has developed alternative legis
     lative proposals which eliminate the roll of federal funding to
     support State or local government purchases of development rights
     on agricultural lands.

32.  These program impacts were identified through a survey instrument,
     draft discussion paper, review comments, and follow-up interviews
     held with the Agency's Program Office and Regional Staff.  The
     format for arranging program impacts was developed by the Office
     of Land Use Coordination.  For a detail discussion of secondary
     impacts on Agriculture, see Evaluating Secondary Impacts of feste-
     Mater_ Treatmen11_Faci1itias, by ABT Associates, January 27, 1977»
     Contract No. 68-01-3268, for EPA.

-------
Environmentally Speaking
                                                The  Role  of             i
                                                Agriculture in
                                                the  Environment
                                                By Administrator Dougias M. Costie
     We live in an age of industrial and chemical pollution
     on farms as weft as in cities.
  In the early 1 970*3, national environmental efforts
concentrated on controlling the highly visible water and
air pollution coming from our cities and their great
industrial complexes. These battles against municipal and
industrial point sources of pollution are by rso means.
won. As a Nation, however, we have made very con-
siderable progress in cleaning up both our air and water.
  This progress brings into focus a less visible, but more
widespread problem, that of non-point sources of pollu-
tion, primarily runoff.
  As farming has become more technological—and as
our understanding of natural systems grows more
complete—the relationship of non-point source pcfiution
to water quality is becoming clearer. On the smaller scale,
we must team to control sediment runoff—from urban
areas as well as agricultural ones. On the larger scale,
we must protect entire watersheds and our underground
water supplies.
  Generally in the treatment of non-point source pollu-
tion in agricultural areas, voluntary cooperation will get
the job done. Clearly there is a great deal yet to be
accomplished. Thirty-seven States have already indicated
to us that non-point source pollution couid prevent attain-
ment of the statutory goals of fishable, swimmabie
waters.
  As an example of how a non-point source problem
can be handled, 1 can report that as early as 1972, EPA
funded what became known as the Black Creek project,
through the Allen County soil and water conservation
district in Indiana. The project was designed to assess
and heip solve the problems of sediment runoff in the
Maumee River Basin. Careful assessment—supported
by scientific help from a local university—proved that the
major source of the water quality problem in BSack Creek
was restricted to a small portion of the land. The local
farm community then cooperated by applying several
traditional—as well as some innovative—approaches to
solve the problem. One lesson everyone learned was that
a solid assessment of the problem is a critical first step
to solving it.
  ! might add, parenthetically, that runoff is not exclu-
sively agriculturally caused. Poorly planned urban
development, poorty managed construction, the paving
over of our fands—are each, in their way, a real problem
needing focus and attention,
  A challenge we aft face today is the control of toxic
substances in our land, air, and water. Modern agricul-
ture, like the rest of our civilization, has benefited greatly
from chemicals that increase production. But we're going
to have to face up to the fact that we are living in an age
of industrial and chemical pollution—on the farm as well
as in the cities—that is far more serious than anyone had
imagined. As President Carter has said, "The presence
of toxic chemicals in our environment is one of the grim-
mest discoveries of the industrial era," In the last few
years science has been teiiing us in no uncertain terms
that some chemicals, including some pesticides, have
totally  unexpected side effects which increasingly
threaten human health.
  The production of synthetic organic pesticides has
risen 8OO percent in the last 30 years. We, as a Nation,
now use 1.6 billion pounds of these chemicals a year.
Of course, there are also toxic chemicals that occur in
nature. But whether created synthetically or naturally,
it is essential that we do whatever we can to control
them.
  The  alarming and steadily increasing rate of cancer
in our society and the growing evidence that much of it
may be induced by cancer-causing agents in our air, soil,
and water, as well as in our workplaces,  is alarming.
  Congress responded to this threat by passing the
1976 Toxic Substances Control Act, EPA is now moving
to implement that Act. In doing so, we are just beginning
to define the dimensions of the problem—and those

-------
dimensions are enormous. For example, we are now
compiling an inventory of ail chemicals presently in com-
mercial production or use in this country. We started
with an estimate that there would be 30,000 such chemi-
cals. Today we ara up to 70,000 and the list keeps
growing.
  Not af! these chemicals are cancer-causing, of course.
The list includes common, necessary items like  tabfe salt,
but the point is that many of these chemicals are wide-
spread in our environment, and some of them are
dangerous.
  Another major challenge facing the U.S. is the preser-
vation of agriculturai land.
  All across the United States today, people—city
people—are beginning to realize what farmers  have
known for too long a time. One of America's great re-
sources is in danger: agricultural land is rapidly going
out of production.  More than one-and-a-half million seres
are being lost each year.  We simply cannot afford that.
As Will Rogers ones said, "The one thing they aren't
making any more of Is land.'r
  The pace of suburbanization increasingly threatens
farmland. With the growth of suburbia, too many farm-
ers find land values, taxes, and the price of labor sky-
rocketing, making it almost inevitable that the onfy solu-
tion left is to sef! their farms, causing the fabric of one
farming community after another to be torn apart.
  EPA has its own vested interest in this problem.  The
U.S. needs those farmlands, not only in terms of food
production, but also for their value as natural fliters and
buffers. While EPA programs in the past have not always
been sensitive enough to any potential adverse effects
on farmlands, today we realize how valuable preserving
farmland is to carrying out our own responsibilities.
  Among other steps, we are:
  Revising the construction grant program for buiiding
sewage treatment facilities so as to minimize the pressure
to take farmland out of production.
  Seeing to it that there  is a thorough review of environ-
mental impact statements on any actions that will affect
agricultural lands.
  Ctearfy, as the 208 planning program moves forward.
some tough choices lie ahead—at the local. State and
Federal levels. Even with the new monies that Congress
has authorized,  there will not be sufficient Federal funds
to pay for the control of practices needed in every soil
and water conservation district. We will need to encour-
age achieving the goals of the Water Act by voluntary
means. If and when those means do not succeed, we
need to ensure that there is an effective, reasonable
regulatory back-up to get the job done in a timely fashion
  On the local level conservation districts in six States
to date have played a crucial political roie in shaping such
fail-back regulatory systems. In another dozen States.
conservation districts are now playing a major role in
working out sensible regulatory procedures.
  I believe that conservation districts are moving rapidly
and effectively to enlarge their role. A quotation from
Vanes Ehmke, Newsletter Editor, Kansas Association of
Conservation Districts, lays it pretty much on the line.
What he says of Kansas conservation districts is likely
to be true for many cither States.
  "Like it or not," says Ehmke, "Kansas Conservation
Districts will have to face some tough problems in the
next few years.  The day of voluntary compliance by
farmers in stopping erosion from their land may be
drawing to a close.
  "Sut let's face facts: No farmer is going to appreciate
being tofd to control his non-point sources of pollution
such as fieid runoff. Farmers are one of the most fiercely
independent racss  of people on the face of the  Earth.
But there's not much of a correlation between inde-
pendence and our pollution problem. And again, let's
face facts: Silt and  sedimentation are the biggest sources
of pollution in this country,"                         C
       '973

-------
dimensions ara enormous. For example, we are now
compiling an inventory of ail chemicals presently in com-
mercial production or use in this country, Wa started
with an estimate that there would be 30,000 such chemi-
cals. Today we are up to 70,000 and the list keeps
growing.
  Not ail these chemicals are cancer-causing, of course.
The list includes common, necessary items like table salt,
but the point is that many of these chemicals are wide-
spread in our environment, and some of them are
dangerous.
  Another major challenge facing tbe  U.S. is the preser-
vation of agricultural land.
  All across the United States today, people—city
people—are beginning to realize what farmers have
known for too long a time, One of America's great re-
sources is in danger: agricultural land  is rapidly going
out of production.  More than one-and-a-half million acres
are being lost each year.  We simply cannot afford that.
As Will Rogers onea said, "The one thing they aren't
making any more of is land."
  The paca of suburbanization increasingly threatens
farmland. With the growth of suburbia, too many farm-
ers find land values, taxes, and the price of labor sky-
rocketing, making it almost inevitable that the only solu-
tion left is to sell their farms, causing the fabric of one
farming community after another to be torn apart,
  EPA has its own vested interest in this problem. The
U.S. needs those farmlands, not only in terms of food
production, but also for their value as  natural filters and
buffers. White EPA programs in the past have not always
b«n sensitive enough to any potential adverse effects
on farmlands, today we realize how valuable preserving
farmland is to carrying out our own responsibilities.
  Among other steps, we are:
  Revising the construction grant program for building
sewage treatment facilities so as to minimize the pressure
to lake farmland out of production.
  Seeing to it that there  is a thorough review of environ-
mental impact statements on any actions that will affect
agricultural lands.
  Clearly, as the 208 planning program moves forward,
some tough choices lie ahead—-at the local. State and
Federal levels. Evan with the new monies that Congress
has authorized, there will not be sufficient Federal funds
Co pav for the control of practices needed in every soil
and water conservation district. We will need to encour-
age achieving the goals of the Water Act by voluntary
means. If and when those means do not succeed, we
need to ensure that there is an effective, reasonable
regulatory back-up to get the job done in a timely fashion
  On the local level conservation districts in six States
to data have played a crucial political role in shaping such
fall-back regulatory systems. In another dozen States,
conservation districts are now playing a major role in
working out sensible regulatory procedures.
  I believe that conservation districts are moving rapidly
and effectively to enlarge their role. A quotation from
Vanca Ehmke, Newsletter Editor, Kansas Association of
Conservation Districts, lays it pretty much on the line,
What he says of  Kansas conservation districts is likely
to be true for many other States.
  "Like it or not," says Ehmke. "Kansas Conservation
Districts will have to face some tough problems in the
next few years. The day of voluntary compliance by
farmers in stopping erosion from their land may be
drawing to a close.
  "But let's face  facts: No farmer is going to appreciate
being told to control his non-point sources of oollution
such as field runoff. Farmers are one of the most fiercely
independent races  of people on the face of the Earth,
But there's not much of a correlation between inde-
pendence and our pollution problem. And again, let's
face facts: Silt and  sedimentation are the biggest sources
of pollution in this country,"                         d
 VIAPCH i 973

-------
   'RESERVING  FARMLAND
  r"jj~lhe  Environmental  Protection
A       Agency has begun an intensive re-
       view  of its programs  and regula-
 tions to  assure that  they will  encourage
 the preservation of America's prime farm-
 lands.
   The actions come at a time  when the
 American farmer is beset by pressures on
 every side to sell out and iet his  land be
 converted to other uses.
   Every year the Nation experiences a
 net kiss  of more than  a million acres in
 valuable croplands. Some of this acreage
 is eaten  up by urbanization—[he spread
 of streets and houses and shopping cen-
 ters  across once productive fields. Other
 farmland  reverts to  grazing and  forest.
 And still other acreage is prone to erosion
 and  dust storms and other natural forces
 that cause rapid soil depletion.
   The trend  would be serious enough by
 itseif. but it conies at a period  when the
Nation arid indeed a hungry world needs
 the American farmer's products. EPA in-
 tends to shape  its policies  with  the
 farmer's interests in mind.
   As Administrator  Douglas M.  Cos tie
 recently  told the  Essex Agricultural and
 TechnicaI insti1111e in Danvers, Mass.:
   "EP.\ has what might be called a vested
 interest in  preserving  farmland.  It  also
 carries out a series of mandates that—if
 not carefully  thought out and managed—
 couid conflict with that vested  interest."
   Why  is farmland  lost? What are the
 factors thut conspire to change a farmer's
 view of the future and convince  him,
 despite his own !ove of the  land, to sell
 out and either retire or find work in some
 other walkoflife?
   "Almost every  aspect of modern life
 conspires to  destroy the farmer's incen-
 tive to keep on farming." Mr. Costle  said,
   "Costs have risen. Labor  is tough to
 come by. Prices for  farm products  have
 not kept pace. Taxes have  skyrocketed.
 And  many a farmer is caught between
 the difficulty  of making a living,  the temp-
 tation to sell out to developers  who  have
 been offering top price for  his acreage.
 and  lack of  support from his  neighbors
 iind  local representatives who  too often
 would dearly love to see his farm become
 a source of greatly increased tax revenues
 through development. Yet the added costs
 of meeting  the  resource needs—roads.
 sewers, schools—of such development al-
 most inevitably offset the gutn  in tuxes,
 nut to mention the to?* us in quality ot'Iifo."
   Thcry arc  obvious reasons why many
 EPA  irn;HNAi
observers are concerned user the shrink-
ing supply of prime agricultural land. Al-
though the kiss of a miition acres annualiy
seems smali compared svith the 470 mil-
lion acres in cropland, the land going out
of food  production often  is the best in
terms of quality and  accessibility.  Also.
the change in !and use can have a major
local impact—economically, environmen-
tally, and socially.
  Once the farmland is lost to urbaniza-
tion, particularly  in industrialized  areas
such as the northeastern United States, it
cannys be  retrieved.  And  when enough
land is  taken out of  farm production,
related industries such as local feed mills,
farm machinery outlets, and farm supply
stores also must close.
  There are  other undesirable side-ef-
fects, A recent Congressional report noted
that agricultural land in fluodptain  areas
often is shifted to industrial or commercial
development,  with  pressure-then created
for pubfic  investment  to  provide  flood
protection.
  One of the social effects,  of course, is
the loss  of the farmer himself and  the
enduring, sturdy vulues that he histori-
cally has contributed to the national char-
acter.  Such things  cannot  be weighed in
dollars and cents, but they have  been
known and honored for many centuries.
As  Oliver Goldsmith wrote in "The De-
serted Village" two centuries ago:
  "!II fares the land, to hastening ills
                     a prey.
  Where wealth accumulates.
                     and men decay."
  The Environmental  Protection Agency
has an interest in preserving prime  farm-
Sand and keeping it in food production for
other and more specific reasons,
  "The drought and water  shortages of
this past summer," Mr.  Costie poinsed
out, "have  underscored one of the essen-
tial attributes  of farmland;  the protection
of watersheds. Open lands such as farms
maintain local water supplies by absorbing
precipitation  and  transferring it to  the
ground water system.  They aJso protect
aquifer recharge areas and provide buffers
for water supply and other natural areas,"
  In addition to protecting such environ-
mental  entities as wetlands and  flood
plains, farms furnish a  habitat for wildlife,
including game such as deer, grouse and
quail, as well as  songbirds and other
nongame species, he noted. Equally valu-
able are the emotional, aesthetic and  so-
cial benefits  of  our  verdant fields and
valleys.
   Because of the Agency's specific con-
cern for preserving and protecting such
valuable land, Co«!e has directed EPA to
take a fresh  look  at  the way  its pro-
grams may affect the future of farmland.
He listed these steps the Agency now is
taking;
*  An examination of tand use changes
which may be induced by-EPA programs.
"We have already begun revising the con-
struction grant program for building sew-
age treatment facilities, for example,  in
order to make sure that we are minimizing
pressure to take land out of food produc-
tion," he declared.
• £R\ is becoming increasingly sensitive
to regional variations in water and land
availability  in implementing Agency pro-
grams that affect farmlands.
• The Agency is working to bring about
closer cooperation with the Soil Conser-
vation Service through joint technical as-
sistance projects.
•  ERA is seeking to assure thai there is a
thorough review of environmental impact
statements  on any actions that will affect
agricultural lands,
» The Administrator  has directed  that
EFft develop an overall policy statement
on the preservation  of prime agricultural
lands  to give general guidance for the
implementation of EPA programs.
  The  English  pcai Goldsmith was not
the first to warn of the serious social side
effects  that can result svhen  farmland  is
squeezed out and the "bold peasantry"
disappears.
  As Costle noted. 'Two thousand years
ago the Roman poet, Virgil,  warned his
countrymen that the loss  of  agriculture
would be  the destruction of the  nation.
He was right. Just as an army becomes
vulnerable when its supply lines grow too
long, a city, a state,  or a nation is  weak-
ened when  it is no longer  capable of
producing most of its basic fotxj supply,"
  !n announcing the new policy, the Ad-
ministrator concluded;
  "1 wouid like to assure you that EPA,
both nationally and regionally, will  do
everything  in its  power and  within  its
mandate to preserve and protect our farm-
lands. We  will devote our best efforts to
developing a common-sense awareness of
the very real  problems and opportunities
that our policies and progress  can create
for farmers. We will work to minimize
the problems und expand  the -opportuni-
ties,"*

-------

           of {onvi
           t
                                                    t
                                                                         ff
DAVfD STANDLEY
  COMMISSIONER
          TO:


        FROM;

        DAT?:

     SUBJECT:
          _M_£J1JDJI_A_KJD_0_M_


Mr. William Adams, Regional Administrator
EPA, Region I

Commissioner Standley

January 5, ^973
The inter-af tion of sewerage^  s-s
agrXcuTcufa" "land use.
                        I cake the  liberty  o;  enclosing a memorandum frae
     Frederick Winthrop, Jr. , Commissioner  of  the Mass/tchtisatcs  Bepantaent
     of Food and Agriculture, dated November  22 which ! find provocative
     and worthy of serious concern.   It  is  tay  hope  thai  afcer sta£f review
     at both che Massachusetts and  EPA. Region  I levels, wa could meet with
     Coouaissioner Vinthrop and explore further his  coarerns and  suggested
     xeaedies.  If you would advise ae of a suitable  time and place, I will
     nake arrangements for attendance by appropriate  Scate parties.
     DS:eb
     Enclosure
     CC:    Commissioner Winthrop
            Mr. Kcr-tahon

-------
                            MEMORANDUM


TO:    Secretary Evelyn F.'Murphy
       Commissioners Standley, Kendall, Sn.edeker & Gullion
       William Hicks

FROM:  Commissioner Frederic Winthrop,' Jr.

DATS!  November 22, 1977

SUBJ:  Agricultural Land, Agricultural Preservation Restriction
       (H-6491), Flood Plain Management, Sewage Systems, and
       their interrelationship,
Enclosures:  1.  President Carter's Executive Order 11988,
                 May 24, 1977.

             2.  Excerpts from speech of E.P.A, Administrator
                 Douglas H. Castle, Mass. Farm Tour,
                 Danvers, August 25, 1977-

             3.  Excerpts from "the Rivar'a Reach-Flood Plain
                 Management in the Ct, River Basin, N,E,£.3.C.
                                               ^Ck^vOz*-'
     The three enclosures plus the uassage of Ho4gi "fths Agricul-
tural Preservation Restriction Bill) by the Legislature have re-
inforced ny previously expressed concern over the placement and
scope o£ sewage systems through or near agricultural lands, es-
pecially, those prona to flooding.

     The secondary effects of excess sewage capacity accessible
to currently undeveloped faraland is well known,  \fners the land
is flood prone and septic tanks are marginal, the increase in land
values can be dramatic.  This not only tends to accelerate the
demise of agriculture, but by raising the development increment,
would raise the subsequent cost of purchasing the development rights,

     Were this to happen the net effect would be to subsidise with
public funds a windfall to the landowners which, were it  still
possible, would be bought back by further public funds for the
restriction - hardly a parsimonious use of taxpayers' money.

-------
     Referring particularly to the  projects  in Hatfield, Northamp-
ton, Kadley, and South Hadley areas,  there is also the problem of
increasing the potential  for flood  damage through encouragement of
development in flood prone areas.   H.E.R.3.C.,  in "The River's Reach",
makes a strong case for nan-structural  flood control methods, pro-
poses that the compatible uses of agriculture and recreation be
actively promoted as the  most cost-effective method of ^maintaining
these areas for flood storage, and  makes specific recommendations
for the towns in question (see end.  3).

     In my opinion the most cost-effective method of achieving these
several environmental goals would be  to:

     1.  Restrict Ia_gej3ietuity^ all sever connect jong^in prime
farmland anoT^Tood prone  a?ea~^~  T"BeSIeve"'"tilis~~snouid be possible
without delaying current  projects.   S.P.A. has some precedents such
as  "Bl.ocJt Island", as described  in  their publication on "Mitigating
Secondary Efi'ects", and Costle*s statements  in enclosure 2 Indicate
an understanding of the situation and a willingness to act,

     2.  Encourage the implementation of the__N.E.R.B«C. recosssestd-
ations as delineate\I"^~tTT^entIvert s Reach1*.

  ..  3.  Investigate the  availability of Federal flood control
funding to sutrplement state funds, for the purchase or Agricurtm-aa
Preservation Restrictions on laraland within the flood plain,  (This
D,F.A. is doing),

     4,  Investigate the  possibility of and  encourage where appro-
priate the utillsatlon__gf agyijailtural  IrrHi ^°-r«- sevage plants for
the disposition of effluent  and/or  sludp-3  fcorn-post) to the benefit
of both agriculture and tirs~e"nv2T;onr3e&t.   (The Organic Waste Re-
cycling Commission headed by Dr. Clave  Willis, U. Mass, has started
to puUL together some useful information on this  score),

     To save the states agricultural land resource will require a
multi-faceted approach and action on many  fronts*  The A.P.R. program
will not in itself be  sufficient,  especially if it has to compete
for the. same land with othez^pub.llclv fiztanc_ed goals and prgt^^fe^-
(Vater Xinea^'^tinty  corridors  and Jiighvays^ as veli~'as~ Wa2T5~₯at?T"
Treataea1:~pla3SLii, fall in""iHls  cafegOry.)

     The preservation  of  our local  agriculture currently enjoys
wide popular  support  and  I b^X^y_g_a_^o£p^lgjig^tarT_apprgaeh__to the
sewage treatment_issue__would engender wide support for SOEA and
the                "
                                — 2 «•

-------
AgricuU'jral Land

      In the period, between  19CO and 1970,  land  devoted  to  urban  uses
in the Denver region Increased by 12.3 percent  while  land  devoted  to
agriculture declined by 6.8 percent.   In all, about 33,60" acres
were  lost to agricultural production.  Most new urban land-came  out
of the agricultural category, and the decline in agricultural  use
affected every county.  How much of this loss was  prime agricult-
ural   land is not known.
                                  About 134,000 acres of aaricultural
                                  land in the five county Denver Re-
                                  gion will be converted to other uses.
                                  Of that, about 30,000 acres  is
                                  classed as prime agricultural land.
                                  The 13A,inn acres represents 29 per-
                                  cent of the agricultural land in the
                                  region, whert>a-s the 38,3nr! acres of
                                  prirne agricultural land represents
                                  about 23 percent of the pri"ie agri-
                                  cultural soils of the region.  The
                                  bulk of loss of prine agricultural
                                  land would be in Aaar^s County.
                                  The U.S. Council on Environmental
                                  Quality has stated that "efforts
                                  should be made to assure that such
                                  farmlands are not irrsversitjiy con-
                                  verted to other uses unless otnpr
national interests override the importance of preservation or other-
wise outweigh the environmental benefits derived from their protec-
tion."  The benefits cited include provision of open space, scenery
and wildlife habitat; it is also pointed out that prime lands by
their nature produce more food with less erosion and lower fertilizer
and energy requirements.

     The forecasted sharp declines in agricultural land use in the
five county area represent only part of the likely future state of
agricultural activity in the region.  As the agricultural lands on
the fringe of the Denver urbanized area are gradually converted to
urban use, there will be increased pressure to exoand and intensify
agricultural activity in areas just beyond the metropolitan region.
These pressures would be felt most strongly in eastern Adams and
Arapahoe counties, southern Weld County and northern Douglas County.
If supplies of water for agricultural use permitted, increased agri-
cultural production tn those areas would take place, with little
loss in overall production despite urbanization of some cropland.
However, water is a far more important constraint on agricultural
activity than is land in this region, and local agricultural experts
report that urbanization threatens continued agricultural activity,
less because it absorbs agricultural land than because of competition
with domestic water users in the allocation of water.  The condem-
nation of water rights may make farming economically infeasibls long
before pressures for conversion of agricultural land are experienced.

     Markets for agricultural products have not been good the last
few years and farmers have had great difficulty in just breaking
even.  This, coupled with a drought caused intensification of com-
petition for available watar,  and urbanization  pressures,  has  sapped
the basic strength of the agricultural sector of the region's eco-
nomy.

-------
            UNITED STATES DEPARTMENT OF AGRICULTURE
                      •  OFFICE OF TH=T SECRETARY
                           WASHINGTON, 0. C. 2325O
                                                         Jane.? 1, 1975
                      SECRETARY'S KEKORANDUM
                      Ho. 1S27, Supolesent  1
        StaCesienC _of ^Prige_ Farmland , Range,  and  Forest Land

 The continued loss of lands wall suited  to  che  production of food,
.forsge, fiber., and debar, and  the degradation  of  the environment
 resulting from those losses is  a natter  of  growing concern to che
 Nation.  Major consideration, aust be given  to pric:a lands ar.d the
 loug-r-ange need to retain the productive capability and environmental
 values of Acerican agriculture  and forestry.  Devalop-ents that result
 in irreversible land use changes represent  a loss  a? valuable natural
 resources.  The process is dramatic in some local  arsas,   At tha
 national level, individual lossas appear snail, but the cumulative
 affect can adversely impact doraescic and international production,

 The concerns about wise use of  oriaa lands  are  local, Statewide,
 and national in .scope.  The loss of land suitable  for sustained crop
 2nd wood production in a region or ^ocrlity-csn influence the via-
 bility of supporting supply, processing  and izarksting facilities,
 Continued _loss of farmland, range, and forest land production
 affects the aconou;? locally, influencing esipioynrsnt and income
 levels.  In addition, it linits other qualities essential to che
 well-being of our people.

 Land use alternatives ara generally available that can tr.inisii.zs
 impacts on prinie lanes.  Such alternatives  should  be explored care-
 fully, particularly vr.era Federal funds  are involved.  When possible,
 laiid use decisions should ba avoided which  irrevocably co:mit prise
 lands to nonfamland, nonrange, and n.cnforestlar.d  uses, cheraby
 foreclosing the options of future generations.   USD.\ viil urge all
 agencies to adopt the policy that Federal activities that take arias
 agricultural land should be initiated only  when there ara no suitable
 alternative sires and when the  action is ir. response to overriding
 public need.  The long-tisra implications of these  land use conversions
 on the productive cepncity of our farmland* rar.gs, and forest land, as
 well as on envi.rcn^-encal impacts, should be Evaluated and sade kr.own
 to the public.

 The Department,  chrauch the Land I'se Cocnitt.ee,  counterpart State
 and local ccrrr.ii;tbes ,  and tha activities  of all  concerrsd isencies,
groups,  a^d  j*rg;ini^^rici:is will
unique  far-lar.d.-,  rar.c-i,  ir.d foriirr. l.ir.ds ;r:.r. pri.r.itur;:  or  -jr.:i=C£?
conversian  to  tv_T.^L-ficuIci_-rsl ianc -.is;-..-  l'r~:ir. »-r built-up  uaas ar.ri
watfjr inpour.dzic.r. ts chat prcclune ••.cilitar.io--. cr  r-icc'-'^r'-'  to  hisbi
quality  agriculture or forestry purpc-irei -r.  ct  particular concern.

-------
                                 -2-

 State and local interests in retaining price farmland, rar.ge, and
 forest land for production, are often based on concerns ochsr than
 the demands for food, forage,  fiber, or tiaber.   Open space, environ-
 oehtal quality, visual quality, and local economic ispaccs are ofcen
 cited as reasons for protecting chase lands.  Many of these lands
 have modest production capability, but are va..ued because of location
 and other unique factors that make them of State or local importance,
 Retaining •famland, range, and forest land anhances local values and
 protects resource options for the future-  The Bepartnsnt will =aka
 specific efforts to assist States and locaiities to identify lands of
 State and local concern and support efforts to protect these lands
 from prenature or unnecessary conversion to other uses,
                                                                i
 Tha Statement on''Land Use Polirv (Secretary's Memorandum Ho. 1827} and
„the•following specific policies are set forth for the guidance of the'
 agencies in this Department in regard to prime lands:

     1-  Advocate the protection of prise lands froa premature or
 unnecessary conversion to other land uses.   Priority will be given
 to prine lands threatened by conversion to irreversible land us&s.

     2.  Assure that environmental impact statement procedures and
 review processes thoroughly consider and evaluate the impact of
 major Federal actions on priae farolaad, range,  and forest lands-.

     3.  Ssphasis.-wil'l be placed on programs to inventory, assess and
 ev?luata the Nation's farmland, rang'a, and forasc lands to assisc
 decision makers and the general public's understanding of tha kins,
 extent, location,  and current-status of prina lands.

    '4.  Cooperative efforts with States, local governments and uni-
versities will be  initiated to assure concerns for food,  fiber, and
wood  production are recognized and aaphasirsd in the identification
of priac lands.

    5.  USBA ags-ncy actions and prograss will give thorough con-
sideration, to the  local,  State, and national concerns for the retention
.of prine lands,  the necessity of conversion of  thase lands to ochar
uses  will be considered only after a determination that feasible alter-
natives  do not exist or that overriding public needs  warrant the action,

    6.  The agencies in tha Departaient will review their  programs ta
Insure consistency  with the incent of this  supplement.
         4..
 John A.  ;:r.e
 Acting Secretary

-------
          The quality of Life for citizens of the State is enhanced
          in the following ways;

          1,   Preserves a way of  life with its unigue cherished values?

          2.   Provides fresh, high guality food at reasonable cost at
              locations close to  the cansuajer,-

          3.   Contributes to a stable economy ij7 Maryland by providing
              jojb opportunities,  income, and a raariet fox the resources
              of production;

          4.   Contributes to tie  Nation's balance of payments by pro-
              viding food and flier for e-vport,-

          5.   Provides reserve food production capacity to seat the future
              needs of our population;

          6.   Provides wood products from fans wood lots;

          7.   ifaintains the quality and ieauty of the environment tAroug-A
              frAe clsansing effect of growing plsints on tJie supply of oxy-
              gen and tne filtering effects of plants and soil on water
          S.   Maintains farm associated wildlife habitats and provides for
              private outdoor recreational areas, camping-, fishing, hunt"
              ing,  etc./

          9.   Provides areas for recycling of solid and liquid waste;

         10.   Protects aineral resources frora Seiner pra— snptsd/

         11.   Provides productive,  ta^paying, privately maintained agricul-
              tural open space with its en-^ixomaental Sen exits, includingr
              rural aesthetics and enhanced air and water
         12.   Provides for orderly development and grrowtLft,- and

         U.   Protects the hydrologic integrity of watersheds tArougn the
              control of storm water run-off and sediment damage, protects
              aquifer recharge areas, and provides buffers for wacer supply
              and other natural areas.

             Jt is for these reasons  that the conzaittee studying the need
        for preservation of agricultural land believes it is imperative for  the
        citizens of Jfaryland to preserve and protect its agriculture resources
        for the Senefit of present and future generations of the State — /


      *' "Final .Report",  CcranuCtree on the Preservation of .Agricultural  Land,
Maryland Department of Agriculture: 1974.

-------
                  EXECUTIVE OFFICE OF THE PRESIDENT
                   COUNCIL. ON ENVIRONMENTAL. QUALITY
                         722 JACKSON ?UC£, N. W.
                          WASHINGTON. 0. C. 20006
              !
                             August 30,  1976


MEMORANDUM FOB, HEADS OF AGENCIES

SUBJECT;    Analysis of Impacts on Prime and Unique Farmland
              in Environmental Impact Statements


      This memorandum,  provides guidance  to Federal agencies on how-

to 'carry out evaluation of the impact of major agency actions on prime

and unique farmland in the course of preparing environmental impact

                 #
statements (EIS),


      Paragraph 101(b)(4} of  National Environmental Policy Act  (NEPA)

establishes a  Federal policy to preserve important historic, cultural

and natural aspects of oar national heritage and maintain,  wherever

possible, an environment which supports diversity and variety of

individual choice.   This  policy should be understood to include highly

productive farmlands.


      Efforts  should be made to assure that such farmlands are not

irreversibly converted to other uses unless other national interests

override the importance  of preservation or  otherwise outweigh  the

environmental benefits derived from their orotection.  These benefits
*  Prime farmlands are those whose value derives  from their general
advantage as cropland due to  soil and water conditions. Unique farmlands
are those whose value derives from their particular advantages for
growing specialty crops.

-------
                                  .2-







sfcem from the capacity of such farmland to produce relatively more




food with less erosion and with lower demands for fertiliser,  energy,




and other  resources.  In addition,  the preservation o£ farmland in




general provides the benefits of open space, protection of scenery,




wildlife habitat and, in some cases, recreation opportunities  and




controls on urban sprawl,







      As part of its  policy to preserve the Nation's prime farm, range,




and forest lands, the Department of Agriculture (USDA) has recently




announced a general policy  to establish  and keep current an inventory




of prime and unique farmland. Recent estimates conclude that of




1. 4 billion acres  of privately owned lands in the United States, approxi-




mately £75 million are classed as  prime farmlands.







      Federal agencies should attempt to determine the existence of




prime and unique farmlands in the  areas of impact analyzed in environ-




mental impact statements prepared in compliance with Section 102(2}(C)




of the NEFA.  This  should include  threats to the continued use and




viability of these farmlands  not only from direct construction activities,




but also from urbanisation or other changes in land use that might be




induced by the Federal action.

-------
                                   -3-





      The Department of Agriculture, at its field locations throughout




the country,  is committed to assisting Federal agencies in the identi-




fication of prime or unique farmlands, and in nearly all cases has




complete information on land areas which may be impacted.   This




should simplify and reduce the burden on other agencies in carrying




out their impact analysis.   Initial contact should be made with the




USDA Land Use Committee in the state where the lands under con-




sideration are  situated.  This Committee can be located by contacting




either the Chairman of the USDA Rural Development Committee in




the state, or any nearby USDA office.  The State Land Use Committee




will then help facilitate contacts with  the appropriate USDA  office and




personnel so that all available information on prime and unique farm-




lands within  the project area, is accessible to the agency preparing an




EJS.







      Finally,  the Department of Agriculture has agreed to  place  a




major new emphasis on the review and evaluation of draft environmental




impact statements  with respect to impacts on prime and unique farmland.




In undertaking  these reviews, USDA will use soil, range, forest,  water




resource, and  other surveys and information which may be  applicable,




This service of the Department should help improve the quality of all EISs.

-------
                                  -4-
      Further information on where agencies may obtain assistance in

identifying prime and unique farmland and analysing significant impacts

on it from agency activities can be obtained from State Soil Conserva-

tion Service (SCS) offices shown on the attachment,   ^formation on

new USD A procedures to review impact on prime and unique farmlands

in draft EISs can also be obtained from these sources.

                                               /7- - •
                                      Russell W,  Peterson  ,
                                           Chairman
Attachment

-------
                    PART 657 - PRIME AND UNIQUE                        •    "*
                             FARMLANDS                                      §
                Subpart A - Important Farmlands Inventory                        *"~
Sec. 657.1  Purpose,
     657,2  Policy.
     657.3  Applicability
     657.4  SCS Responsibilities.
     657.5  Identification of important farmlands.
     Authority:  16 U.S.C. 590a-£, q; 7 CFR 2.62; Pub. L. 95-S7; *2 U.S.C.
fr321 et seq.
Subpart A - Important Farmlands Inventory
$ 657.I Purpose.
     SCS is concerned about any action that tends to impair the productive
capacity of American agriculture. The Nation needs to know the extent
and location of the best land for producing food, feed, fiber, forage, and
oilseed crops.  In addition to prime and unique farmlands, farmlands that
are of  statewide and local importance for producing these crops also need
to be identified.
i 657.2 Policy.
     It is SCS policy to make and keep current an inventory of the prime
farmland and unique farmland oi the Nation. This inventory Is to be carried
out in  cooperation with  other interested agencies at the national, State,
and local levels of Government.  The objective of the inventory is to identify
the extent and location  of important rural lands needed to produce food,
feed, fiber, forage, and  oilseed crops.
i 657.3 Applicability.
     Inventories made under this memorandum do not constitute a designa-
tion of any land area to a specific land use.  Such designations are the re-
sponsibility of appropriate local and  State officials.
I 657.* SCS Responsibilities.
     (a) StateJZgnservationist.  Each SCS State Conservationist is to:
     (1) Provide leadership for inventories of important farmlands for
the State, county, or other subdivision of the State. Each is to work with
appropriate agencies of  State government and others to establish priorities
for making these inventories.
     (2) Identify the soil mapping units within the State that qualify as
prime.  In doing  this, State Conservationists, in consultation with the cooper-
ators of  the National Cooperative Soil Survey, have the flexibility to make
local deviation from the permeability criterion or to be more restrictive
for other specific criteria in order to assure the most accurate identifica-
tion of prime farmlands for a State.  Each is to invite representatives  of
the Governor's office, agencies of the State  government, and others to
identify  farmlands of statewide importance  and unique farmlands that
are to  be inventoried within the framework of this memorandum.
     {3} Prepare a statewide list of:
     a)  Soil mapping units that meet the criteria for  prime farmland;
     (ii) Soil mapping units that are farmlands of statewide importance
if  the criteria used were based on soil information; and
     {iii} Specific high-value food and fiber  crops that are  grown and, when
combined with other favorable factors, qualify  lands to meet the criteria
for unique farmlands. Copies are to be furnished to SCS  Field Offices
and to SCS Technical Service Centers (TSC's).  (See 7 CFR  600.3, 600.6.)

-------
     (4) Coordinate soil mapping units that qualify as prime farmlands
with adjacent States, including the States responsible for the soil series.
Since farmlands of statewide importance and unique  farmlands are desig-
nated by others at the State ievei, the soii mapping units and areas identi-
fied need not be coordinated among States.
     (5) Instruct SCS District Conservationists to arrange local review
of lands identified as prime, unique, and additional farmlands of statewide
importance by Conservation Districts and representatives of local agencies*
This review is to determine if  additional farmland should be identified
to meet local decisionmaking needs.
     (6) Make and publish each important farmland inventory on a base
map of national map accuracy at an intermediate scale of 1:^0,000 or
1:100,000, State Conservationists who need base maps of other scales
are to submit their requests with justification to the Administrator for
consideration.
     (b) Technical Service Centers.  Field Representatives are to provide
requested technical assistance to State Conservationists  in inventorying
prime and unique farmlands (see 7 CFR 600.2). This  includes reviewing
statewide lists  of soil mapping units that meet the criteria for prime farm-
lands and resolving coordination problems that may occur among States
for specific soil series or soil mapping units.
     (c) National Office. The Assistant Administrator for Field Services
(see 7 CFR 600,2} is to provide national leadership in preparing guidelines
for inventorying prime farmlands and for national statistics and reports
pf prime farmlands.
1657.5 Identification of important farmlands.
     (a) Prime farmlands.
     (1) General.  Prime farmland is  land that has the best combination
of physical and chemical characteristics for producing food, feed, forage,
fiber, and oilseed crops, and is also available for these uses (the land could
be cropland, pastureland, rangeland, forest land, or other land, but not
urban built-up land or water).  It has the soii quality, growing  season,  and
moisture supply needed to economically produce sustained high yields of
crops when treated and managed, including water management, according
to acceptable iarming methods. In general, prime farmlands have an  ade-
quate and dependable water supply from precipitation or irrigation, a favor-
able temperature and growing season, acceptable acidity or alkalinity,
acceptable salt and sodium content, and few or no rocks.  They are per-
meable to water and air. Prime farmlands are not excessively erodibie
or saturated -with water for a  long period of time, and they either do not
flood frequently or are protected from flooding.  Examples of soils that
qualify as prime farmland are Paiouse silt loam, 0 to 7 percent slopes;
Brookston silty clay loam, drained; and Tarna silty clay loam,  0 to 5 percent
slopes.
     (2) Specific criteria.  Prime farmlands meet all the following criteria:
Terms used in this section are defined in USDA publications:   "Soil
Taxonomy, Agriculture Handbook &36"; "Soil Survey Manual, Agriculture
Handbook l-S"j  "Rainfall-Erosion Losses from Cropland, Agriculture Hand-
book 282"; "Wind Erosion Forces in the United States and Their Use in
Predicting Soil Loss, Agriculture Handbook 3&6"; and "Saline and Alkali
Soils, Agriculture Handbook 60."
     (I) The soils have:

-------
                                                                  3

     (A) Aquic, udic, ustic, or xeric moisture regimes and sufficient avail-
able water capacity within a depth of 40 inches (1 meter), or in the root
zone (root zone is the part of the soil that is  penetrated or can be penetrated
by plant roots)  if the root zone is less than 40 inches deep,  to produce the
commoniy grown cultivated crops (cultivated crops include, but are not
limited to, grain, forage, fiber, oilseed, sugar beets, sugarcane, vegetables,
tobacco, orchard, vineyard, and bush fruit crops) adapted to the region
in 7 or more years out of 10; or
     (B) Xeric  or ustic moisture regimes in which the available water
capacity is limited, but the area has a developed irrigation water supply
that is dependable (a dependable water supply is one in which enough water
is available for  irrigation in 8 out of 10  years for the crops commonly
grown) and of adequate quality: or,
     (C) Aridic or torric moisture regimes and the area has a developed
irrigation water supply that is dependable and oi adequate quality; and,
     (ii) The soils  have a temperature regime that is  frigid, mesic,  thermic,
or hyperthermic (pergeiic and cryic regimes are excluded).  These are soils
that, at a depth of 20 inches (50 cm), have a  mean annual temperature
higher  than 32  F (0  C).  In addition, the mean summer temperature at
this depth in soils with an O horizon is higher than £7° F (8° C); in soils
that have no O  horizon, the mean summer temperature is higher than
59  FU5  C); and,
     (iii) The soils have a pH between 4.5 and 8.4 in all horizons within
a depth of 40 inches {1 meter) or in the  root zone if the root zone is less
than 40 inches deep; and,
     (iv) The soils either have no water table or have a water table that
is maintained at a sufficient depth during the cropping season to allow
cultivated crops common to the  area to be grown; and,
     (v) The soils can be managed so that, in all horizons within a depth
of 40 inches (1  meter) or in the root zone if the root zone is less than 40
inches  deep, during parr of each year the conduciivity of the saturation
extract is less than 4  mmhos/cm and the exchangable sodium percentage
(ESP) is less than 15; and,
     (vO The soils are not flooded frequently during the growing  season
(less often than once in 2 years); and,
     (vii) The product of K (erodifaility factor) x percent slope is less than
2.0, and the product of I (soils erodibiiity) x C (climatic factor) does not
exceed 60; and
     (viii) The  soils have a permeability rats of at least 0.06 inch (0.15
crn) per hour in the upper 20 inches (50 cm) and the mean annual soil temper-
ature at a depth of 20 inches (50 cm) is  iess than 59° F (15° C); the per-
meability rate is not a limiting factor if the mean annual soil temperature
is 59  F (15  C) or higher;  and,
     (ix) Less than 10 percent of the surface layer (upper 6 inches) in these
soils consists of rock fragments  coarser than 3 inches (7.6 cm),
     (b) Unique f arm 1 and.
     (1) General.  Unique farmland is land other than prime farmland that
is used for the production of specific high value food and fiber crops.  It
has the special  combination of soil quality, location, growing season, and
moisture supply needed 10  economically produce sustained high quality
and/or high yields of a specific crop when treated and managed according
to acceptable farming methods.  Examples of such crops are citrus, tree
nuts, olives, cranberries, fruit, and  vegetables.

-------
     (2) Specific characteristics ol unique jarmland.
     (i) Is used for a specifichigh-Value I'ood^oTTIBer crop.
     (ii) Has a moisture supply that is adequate for the specific crop.
The supply is from stored moisture, precipitation, or a developed irrigation
system.
     (iii) Combines favorable factors of soil quality, growing season, temper-
ature, humidity, air drainage, elevation, aspect, or other conditions, such
as nearness to market, that favor the growth of a specific food or fiber
crop.
     (cJ Additional farmland of statewide importance. This is land, in
addition to prime and unique farmlands, that is of statewide importance
for the production of food, feed, fiber,  forage, and oilseed crops.  Criteria
for defining and delineating  this land are to be determined by the appropri-
ate State agency or agencies.  Generally, additional farmlands of  statewide
importance include those that are nearly prime farmland and that economi-
cally produce high yields of crops when treated and managed according
to acceptable farming methods. Some  may produce as high a yield as prime
farmlands if conditions are favorable.  In some States, additional farmlands
of statewide importance may include tracts  of land that have been desig-
nated for agriculture by State law,
     {d) Additional farmland of local importance.  In some local areas
there is concern for certain  additional farmlands for the production of
food, feed, fiber, forage, and oilseed crops, even though these lands are
not identified as having national or statewide importance. Where appro-
priate, these lands are to be identified  by the local agency or agencies
concerned.  In places, additional farmlands of local importance may include
tracts of land that have been designated for agriculture by local ordinance.

-------
       YOU CAN'T MOVE SXAGIT VALLEY'S AGRICULTURE TO THE COLUMBIA BASIN,


                              Robert A. Norton                                     ^
                      Superintendent and Horticulturist                            §
            Northwestern Washington Research and Extension Unit                    *~


          Driving through the Columbia Basin from Othello down to Pasco, one

can't help but be tremendously impressed with the growth of agricultural

enterprises in that area.  Gigantic circle irrigation systems, as well as

the more traditional systems are bringing thousands of acres of desert into

production.  With all of this development it's easy co see why some people

wonder why we even bother with farming in the Skagit Valley, or anywhere

else in western Washington, for Chat natter.

          Like most of us, farmers keep on farming because they are attached

to their land, have a big investment in buildings and equipment and, not to

be underestimated, they just like it here, rain and all!  Some are staking a

good return on their investment but a lot more have quit for a variety of

reasons, eg. age, unprofstability, urban pressures and taxes.

          What about the majority of us that don't farm for a living?  What

would happen if all of Skagit Valley's farmers sold out and moved to the

Basin?  Let's look at it both from the farmer's and then the non—farmer's

standpoint.

          First, although the farmer might be able to sell his land, he'd

have to leave much of his equipment behind.  Our smaller tractors are like

toys to Basin farmers who generally farm much larger acreages,

          But more important, our farmers generally would have to grow entirely

different crops.  Peas, our mainstay in the Skagit, require  irrigation in the

Basin and can't be grown all summer long because of the heat.  Our yields on

the Coast average over two tons per acre with no irrigation, just twice the

yield obtained in eastern Washington or anywhere else in the 0, S,, Western

-------
                                     -2-






Washington farmers can boast chat they have never lost a pea crop from  Che




weather, nor have yields aver fallen below 75%  of vhac they expected.  No




other area can make this claim.  An equal quantity are grown in eastern




Washington, usually in rotation with wheat or other cash crops.  Strawberries




can be grown fairly well in parts of the Basin but only one or two growers




have made a go of it.  No processing industry exists, nor is contemplated.




Except in California where strawberries are picked primarily by migrants, most




strawberries are grown in moderately populated areas where help is available




for picking.  Many people feel that it's a real asset to have an opportunity




for our young people to earn their own money and develop good work habits.




          Raspberries thrive in the moist coastal areas of the Horthwest.




Like peas, yields are double those possible anywhere else in the world.  In




the Basin, however, they ripen too fast and are subject to winter injury and




diseases that don't exist on the Coast.




     Flower bulbs, like the berries, can't be grown successfully in the




Basin.  Bulbs were first grown in. Whaecom County but the Dutch growers  exper-




ienced severe winter damage and had to move south to the Skagit.  Can you




imagine how well they would survive in takiaa's 20  below sera?  In addition,




bulb growing requires many workers, not readily available in Che sparsely




settled Columbia Basin,  The bulb crops provide the single largest source of




youth employment of any agricultural enterprise in this area.  The largest




bulb grower in the world, William Roozen, is a Skagit farmer,




     Vegetable seed crops are produced on both aides of the mountains fauc




they are not interchangeable.  Skagit Valley produces up Co 35% of the




nation's red beet, spinach and cabbage seed.  These crops require either a




mild winter (cabbage and beet) or cool temperatures during the growing




season (spinach) to get top yields.  On the other hand, the Skagit Valley is

-------
                                     -3-
not adapted co heat-loving crops like corn, beans and onions.  Several seed




companies based in Mount Vernon have seed crops in both areas.




          A. similar story can be told about many of the other crops grown on




the fertile Skagit flats, or elsewhere in western Washington - blueberries,




broccoli, cauliflower, cucumbers, rhubarb or blackberries.  These crops seem




to thrive in the unique combination of climate and soil we have here.




          And this climate is truly uniquel  What other area do you know




that has a summer temperature seldom exceeding 80 F and a winter which rarely




goes below 20 ?  I know of only a few relatively small areas like our own -




the Salinas Valley of California and other smaller valleys along the West




Coast.  Even the great Willamette Valley in Oregon does not have the climate




or soils for large scale pea production.  Our almost nightly dew makes ic




tough for rolling out the sleeping bag on the lawn like I used to do back




East, but the peas really like it, in fact they depend on it.




          What is all that newly irrigated land ia the Basin being used for?




Mostly for potatoes* alfalfa (hay), sugar beets and wheat.  Though we have




quite a bit of wheat in western Washington this year, it Is not likely Co




remain important if wheat supplies continue to increase.




          Let's get back again to the effect of Skagit Valley agriculture on.




those of us not directly involved in farming or ranching.  Is there anyone




among ua who does not somehow benefit - either from a job tor someone in our




family on the farm or in some related industry - processing, feed, fertilizer,




farm equipment, fuel or marketing farm products ?  Who does not benefit from




being able to enjoy the greenness of the fields, the pollution—free air, the




beauty of the tulips and daffodils in May, the ability to watch the sun




setting over a relatively unobstructed landscape?




          We all know chat overnight our farmers aren't going to leave the

-------
the Skagit even though ehey might make taore money fanning in. the Basin,




But, don't you think we all have a stake in keeping agriculture strong and




profitable 30 that all the benefits we now enjoy will continue?  What can we




do?  Here are a few possibilities:




1.  Support good land use decisions at the local leveL  Attend Planning




    Commission Meetings and voice your Opinions, especially when you can speak




    impartially on an issue,




2,  Eelp educate others as to the uniqueness of our agricultural resource and




    how residential development is detrimental to continued agricultural




    development.  We can use che example of aerial spraying which is much




    cheaper and more efficient than ground application.  Houses, power lines,




    children, pets are causing increased interference with profitable farming




    operations.




3.  Promote the idea that agriculture and industrial growth are not_ seriously




    competitive.  Industry requires relatively little land and. can afford




    land closer to the urban areas or land act suitable for farming.  It is.




    residential development thae seriously -Ieooardi2e9_3griculcural land.  There




    is plenty of land for homes away from the "flats", land free from the threat




    of flooding! spray planes or dust.




4.  Finally, support our farmers.  They are the key to Skagit Valley's and




    Washington's most important industry.  This dairy-berry valley is a great




    place co live.  Let's not be too much in a hurry to change it.
                                                                 5/17/76

-------
                                                                                    <7»

                                                                                    as

                                                           Assam's
          reservm
  Long Island County Buying Land to Save It
        By William Gillea.
  KI72BHEAD,N.Y.-Suffotk County,
a once-rural county inundated since
the 1950s by waves of urban emigrants,
is spending millions of dollars to keep
thousands ot acres farmland forever, '
  Under the  most  car-reaching pro-
gram of its kind in the country, county
residents ha?e approved a $55 million
bond issue  to  purchase the develop-
ment rights to as many as 15,000 of the
55,000 acres now used as farmland,
  Federal, state  and  local  officials
around  the country are watching the
Suffolk program as an example of how
a suburban area, in tbs path at urban
spillover, can retain its  traditionally
rural character.
  James Jobnson, a soil conservatio-
nist  with the U-S,  Soil Conservation
Service, quoted one study as showing ;
that  the t/imed. States "lost," during-
the period 1967-1975, a total of 5- mil-
lion acres of farmland a year.
  This figure,  according to Johnson,
consisted of 2 million acres converted
to  suburban development and 1 mil-
lion  converted to lakes,  ponds  and-
reservoirs, Another 2 million acres, ne
said,  were rendered, inefficent by the
strip-type nature of most suburban de-
velopment.
  In  the first phase of tba program,
the  Suffoik  County Legislature ap-
propriated 521 million last September
to buy the development rights to about
4,000 acres some 75  miles east Of New
York City.
 program, are paid the difference be-
 tween what rheir land, is- worth for
 tanning and what it is worth, for ex-
 ampie. for housing. The first two far-
 mers to sell their development rights
 were paid SS1S,873 for 215 acres, or an
 avecasa of 92,800 an acre.         *
   Once the  farmers have wid these
 rights to the county, they retain  own-
 ership of the land but may use it only
 for agricultural purposes.

   Many Suffolk  residents emigrated
 from  neighboring  Nassau  County,
 which was largely  rural itself before
 ths Influx of 1 million residents  atter,
 World War U. Today  Nassau,  once
 New  York City's backyard vegetable-
 garden, has about 1,600 acres of work-
 ing farmland.
   Surfolk County Executive John N.;
 Klein, who backed farmland preserva-
 tion soon aitsr his election in 19T2, said
 in a  rscent interview: "If 1 had en-
 dorsed  this  concept 10 years ago,  !
 "would have  struck" out. But today toe1
 voters realize that ths county's farms
'are important economically, environ-
 mentally and reereat ioaaily."
   Suffolk's  mirror-flat  fields   have
 more than  just |cenic  appeal.  The
 county produces more than 370 million
 a year is agricultural crops -

   The Maryland Legislature enacted
 an agricultural preservation law sn the
 1977 session  that would allow the state
 to  purchase development  rights lo
 farmland  located in designated  agri-
 cultural districts. However, no funds
             Vno participate la the  _ havs been voted for the program.

-------
 Notes on the Law:
•A N$v/Way to Save
 Our Farmland
Chapter 730 oi !he Acs si 1977 represents
th& ia!!5?$t snort tc hsit ihs ^bflnsonmsnt 5ndi
 ™?r ^s?? Tr::= new ,aw
 r~35:=,*Y™;;.rr. rs~ncr^c"?'r ^ APR? ' snci crcv^c^s
 3? rruihcr *: :r.e M-issacnufsrta Dscirrmerit c:
 ,-vT. njr'r' is 5 r**w r^u ct ccns&r/
 "ar:: prortiis^a ir.g stat^ tr3t x&

 •vr.ar. recc-r^ec;,  T*^  covenant
 rur^rs c^Tners c*  tr.s ion— ui os
 .^T'.S. ma*/ Tr'.&r. c^ sci- ^rr czhsnvi


     TSHf-.tTy^T.  n drs

     cs tec rstucn *cr t^

                                                        SOURCE:         METROPOLITAN  AREA  PLANNING COUNCIL
                                                                          BOSTON,  MASSACHUSETTS
Cr^pisr 73C will be adrn:rtarftrs3 by ar* az
r-.r-rai iar.c:^ crsservaucn c^nmittes "he:r

'AT.i"^ 'A"ii CMS- puoiishincj recrj^^oris ss.r;v
     .
                                             -"3: wner. evasuar^c prcccsed svirchasas +









                                             .•*»r* '**.-!' ** c «rcr". ss^sd w.tri, st^T^r r_, nr^s cdHT-r*c~
                                             tr.e T^rss" vaius ct :r.s A?r  it !.r.e ::rr.5
                                             ra.ssss. This oo'jid mean pa'.~j:a back T.-
                                                  ses a: raies not :c «K;«*
                                                  ^r.ss o: ;r.e ueparrmer.t c:
                                                                          sxancr.

In order to be considsrsc tor :he proor
!and must be 5hc:ib!6 ;;r  L r^rrrJdnci
rr.sr;;  ^nder General L^'.vs Chapisr
d.:r.o-jcr.  :; need  rvct -a  ?jbiect ;
p.-sgrar::- This means •>.=: cis propar
ccr.:;rra to !he regUkrerr.sr.s of the -"
secr^oris ct Chapter 6 1 A. i~a: is, it mLSt
:: at  Isasr five acras  o~;ve!y -dsvc
:arrr.;.'M  ^r to jorestf" unssr an ap
:::s::ry pisn ar.d c rnur r.dve gross*-
55J'2 2 year  ior the pin r.vc years  .-.
*u.~5l ^sas are d?*'^!^— v^r1-' brc?acv+~
^m1^:? :^ ir.ci^ci^ cr^vr.r.^ ^1 fur^cis cr

tcrsaia
                                                                              51A,
                                                                                that






-------
LU? Reports/February 9, 1376	_	,	Page _5
              s2.5 MILLION ACRES
 QF FARMLAND PASSES CALIFORNIA ASSEMBLY

      A bjjrt aimed at preserving California's 12.5 million acres of prime agri-
 cultural land and indirectly halting urban sprawl has passed Che California
 General Assembly and been sent to Che Senate.

      The bill (AB 15), sponsored by Assemblyman Charles Warren, D-Los Angeles,
 calls for the creation of an Agricultural Resources Council that would be
 charged with protection of such priine farmland.  It would require all cities and
 counties, with the exception of chose consisting of less than 1,600 acres, to
 map prime agricultural land wichin their boundaries, or have the state do it
 for them.  These maps will chen. be sent to the Agricultural Resources Council
 for certification and recommendations for types of permissible use.

      California, which provides 40 percent of the fresh vegetables and fruit
 consumed in the nation and 25 percent of all the nation's table food, has been
 losing an estimated 20,000 acres of priae agricultural land to urbanization
 each year.

      The Warren bill would permit this condition to continue for only ten. more
 years.  He estimates that land presently exeapted under his bill would amount
 to between. 200,000 and 250,000 acres, including:  land already committed to
 urban development (e.g.  that with existing sewer lines); land that cities can
 show to be required for a public welfare use more urgent than preserving it for
 agricultural use; and that land available to cities to grow to 1,600 acres.
 With 20,000 acres being urbanized each year, Warren estimates cities have lit-
 tle more than ten years to plan for the growth moratorium.

      A staff member of Warren's Cotmaittee on Resources, Land Use, and Energy,
 told LUP Reoorts the measure was an extension of the principle or agricultural
 land preservation begun under the Williamson Act of 1965.  That act sought to
 preserve farmland on the fringes of communities by means of voluntary agreements
 between the state, county, and local governments and the property owner.  Such
 agreements would call for land to be taxed on its agricultural income racher
 than its development potential with the difference between the new cax rate
 and the old being paid'to the city by the state.

      Under the Warren bill, the state would'not compensate communities for
 losses in property taxes because Warren expects land within the city to gain
 value as fringe lands are placed in the prime agricultural lands category,

      Warren is  said  to be optimistic  about  the  bill's  chances.   He has  accepted
 amendments that  have mollified opponents who  charged Che bill with being too
 rigid in its  classification categories  and  lacking  in  local  government  input.

      One amendment  ramoved from che bill a  moratorium  on any new development
 until land-classification maps ware produced.   Another amendment granted
 special consideration co  land-owners  who might  not  receive  che irrigation water
 for their land  they  had otherwise planned on.   And,  the composition of  the
 Agricultural  Resources Council has been changed to  reflect  the state,  councy,
 and local government involvement  in che program.

-------
 CONSIDERATIONS FOR FARMLAND  RETENTION  STRATEGIES
         AT STATE AND LOCAL GOVERNMENT LEVELS

         SOURCE:   NRE/ERS WORKING  PAPER NO.  28

     The 13. S. experience with land— «se controls  co  retain land  in agricultural
and other open— space uses suggests sorae common elements essential to effective
agricultural land-use policy:
                                      t — It perhaos  goes without saying
     that sound land— ass planning is an important  prerequisite for
     effectiveness.  ?ublic policy affairs  CD  guida  private  land-use
     decisions cowards public goals cannot  b*  affective unless public
     land-use goals aea well articulated and translated into definitive
     and specific designations of where farmland retention is in Ehe public
     interest.

     E^^tcact/ — Implicit to tha notion of effectiveness is the requirement
     that a land— use policy instrument hava tha capacity to  achieve che
     desired end-  The importance of this rsouiraraent is ease evident in
     the context of incentive programs.   If the incentive offered is
     insufficient: to alter private land— use decisions (as is apparently
     che case uith use— value assessment) , che  allocation of  land between
     uses will noc be affected.   Beyond this,  however, ie is not enough
     to merely prevent development on farmland.  "the economic vitality
     of agriculture1 in th« rural-urban fringe-  also requires  programs
     sensitive to the need for agricultural infrastructure,  tax policy
     consistant vich sustained agricultural uss of land, and reduced aconomic
     uncertainty.
                 cCftito£--Most land-use analyses probably aould agrse with
     Libby  (1974)  that local governments "have inportant strengths
     bat  retaining agriculture and open space is not; ane of chant".  Factors
     of core  than  local concsm need to be brought into the land-usa dacision
     making process,  ttanca, there is a need for land-use policy instruments
     vhich  place  some (but clearly act all) administrative authority at
     the  state level.
                 The management of economic growth and land-use change
     is, by its very nature, a dynamic process.  Sines there will always
     b« uncertainties preventing accurate predictions of future conditions,
     policy instruments aust be flexible enough so that land-use decisions
     can bs reviewed and revised when changing conditions warrant.
                     — Constitutionality is a aost important element in
     che contsxt of noncompensatory regulation.  While some analysts
     argue  that the scope of public regulatory powers is braaiier than is
     typically assumed, there is QO consensus on how far regulation with-
     out compensation can go and not be interpretad as a "taking" under
     the U . S . Constitution .  Policy siakers and the public wiil jresaain
     sensitive to this issue,.

     Economic fea&4.bJM~&/ — The fiscal burden of alternative land-use
     control approaches is clearly an inportant criterion.  For exaaple,
     it seems apparent that the nassiva public expenditures required
     for public purchase Q£ development rights programs has been a aajor
     Impediment to their implementation.
              a.o.C3,pti&i£iM} — The political acceptability of any land-use-
    policy instrument is dependent largely upon its anticipated impacts,
    the certainty and clarity uich which these impacts are perceived,
    and the political influence of those affected.   This factor is
    particularly important in the context of regulatory approaches.
    Because of the political backlash generated among property owners
    by noncompensatory regulation, it is argued chat at least  partial
    compensation aay be necessary to nake broad based regulatory programs
    politically acceptable.  This factor tnay limit  (for che time
    being, at least) che scope of noncompensatory open-space regulation
    in che United States to very sharply focused, limited-purpose
    programs in which the public purpose is obvious, tangible,  and widely
    supported.  Puolic decision makers,  nevertheless, Bust also recognise
    that what is politically acceptable  say change  over ciae due to
    changes in social values, citizen awareness,  and the intensity
    of political participation among different Interest groups.

-------
                 SOURCE:
                                              ;}f •"'•'".:  f.•:: 'f..4 t        	_  Harch  2Q,  1973
      r •!' Int J •= •- L; '-s t: ju .'t-  '-' ••  ?•  i -ts " '  •-••:••• P":?  arH  lr-aL' •„ > 35 rar  farmland
ervr uxi  -. '11. '•"•'. ^ fi^"-^ •   '•  :•   ••  '. ."  rvr-..::-" ,l,   • M fa^-f'  .:•••>  losses  becoae criti-
cal,  -»'. r  tdi-'ja  'i  '."'sp.  Jji.'-:1;  T-',  -•'-',",  \  r !••->-.  =  ' )••» ••••i^k "aerore  the
Nat:^r:>l  i\'3 = -:-  rj-t^'i i--f "" ;'i"-i~--.,

      joff-t-ig »-c'." r ,^t  LI-nl ^ ^•'UTrnictt*.'. ,:  ;? '-'.Lilt  che urbanization of
pri' 2 f;.,'Tl,••-.'    ";f?"-rl3  ;:'•>-.•   -I " -.   L---;:'s->.'  \i-creased concern at
che  " •  •~~^'~~    - • 'i ,  f7- '•;'  •' -!>~ .    r  •'.  ".TS  ji":?"  "1--  '•••J.;--T^  : iuse"  of fara-land  urbani-
zat '  ••  , '•  "•  : : •      ~ I .
<»-'fi
                                             *.!i^  ••  'i'  ^-U'T-.F f i "?.ilinu  Losses,  the  problea
                         'fir~;  ."if,L-'->,  J>?i-'fcro? •••III.LI n-i ; i .  ^.c^LsIation should be  dasi|aec
Co  i *• r  •> ;i,  -i1""  " 'ic •*  ' i. i'i'iy  "f ''if™,  q;i'''t'i  L—-! <-,r:?^ ar^as co  increase Congressiona]
-,:• ": ,  ';>•:  • I 'rl,  u-u'-r,;;  ".'... k  -.'i: :H  supports the  legislation,
      ; •" ''  •"" r,T •  • -.   .•"fi.i^r.t  t.h- :  f, '.-? i.jj-'- '-r:':n --:."i'j b-  id-7pc«it (.''I-s for the  Federal  gcvarrjnenc  in
cons f1 ' ! ;  ' •*:. 3™i. i -ult'u's '   '"]••?  "• - ,

      J»f f'T-is  - "-  i - L<; - ';   hy  "--;i,iv.  /',;':'. Tit ' t.j7 :  C^rn ' f " ": aide Stuart  Karay, who
agr ^-rfd  *tT,-i'; ,-h?  ie»,i,>i •"' "• ;  i   sr. -•.,''?  •• ^^c-  :::* '"'j -^:  ;,issaga.  However,  additional
fun" ,"E  fhouJ J t?  3f*,-!sd  ".c  .'•.tir.  ;:rAf;f, p r '--•;•"> :M ,  Harj1   sail,  noting  that 5en. Warren
Magna^Jif  >0 , -t-i^sh. ) p'lj'.-s t:?-  ir i'r3'"U;c -3  i-'^is- L •> *icn :. reviling  5500-aillion for jrancs,,
cw1"e  vha ame1'"'"  nnv L.-fiaf-^rf  in  Jeffords'  ^1^',  Taj 'Uigivison bill will have a  more
narr,,,_, f^c;jSt -\;if''i4s {.f, it -  rifL>f*e-;t Iv'i cf  "• i^il-^nd '*•>  "b^ isrban L:riage  "where  "he real
      In L "rp.'-.i is.  tc .i=,ie-! ;i/r,r- ,  JeCfj'r'ls  ••'Vr'-5-'  *. ••i': . > a" ^nt^ tna.t Federal agersciss
     iCR "5>grj   '."ir1'.  ' -V.ICT.  j*--, * --"^'.its'1 "«'c-r-'1  -?;;r/^.'i -3  prtjeccs. Such a  procedure,
     !r •("•*  df.".n."  th9 •="• ) * ; — .cr*. ii  L"."'V'-.i -r j-.v-.^r--   t r •   -; ,s,  woald be curabersccie and
pol i t i :*il!y ' "t"" fui 'V ,  *•.'  ^t^s ">ic,<;f"'clir! ,

      in i"hftr .^\--?i^n\,  "iii D?ti'1"l"ni!3fil: of  ^^'"'n^ 'ir-4  Urban Development drew quali-
fied  .'jrT1'^0 ''o.  *,"ACc  ;,'.f:(iir  ;,'i  ra^pcr.^e'  ^"  .'« •.;•>' in1 ;r  Isveloped  Cotumunity  Develop—
sier'<*  ° !•••;: '>'-::>-.  --»?.  ",;.<";*s '»Jlli3_"> ^~,i-3  rr-~irri''  !'"'•  ?n~c developing
       -n-i3 Le'  ^'iia«ili •;••-,  "J.IL  Iia '•.-I'-r-n  :".i(_ l,--^L * ;"5fmr.encs should closely monitor
      !fl;!;  ^ per !••;'<. ..:•• D'",i  ?j--. n  rv ,  :, ar? rs i  ".''e  !c;pir '•-•it'c ' 5  • •'"''   !" '.HI  that GDBG aid
     'd r-*  t'-jM'l  .'.' b it i •?'••>''  ' -•• -  i i-i  TO-'.^ra^a- incjrr.»  i^isons.  Although  the initial  ~5*i
      'is,.  :-taT>  c-l.ix^'?.  ';.t'  --I*',  -Li',1  s;:;bjj2t  a,3p-i.-3ticv.s  to close  scrutiny if a,
     i j',; " j.3 1 "?,?;Tit" ?:  f .-'i-! • •. LL  :,r">t  ue''^fl*:  I :'•-'•• -jns  persons. "Xegociaciotis
will  c-e  "-;qui: "i  r^r »• i •  -jprL.  ati:n?,  r  /."h  HDC?.".  D^.'I^e  was  critical of  HUD ' s  de-
cision *"-  *n-:-  f'«». r.ij--  ri'ia  2r'u;f;j - - , mt;j;  ; '"  'rhi h  u r/c- "oc •.  icT.i "t--".!  "i);ir  requests. N'ACo also sought
as,ci' r?Tt>r, d->  i:u,ct  ro'.iiu'jj   ill '-a  "hie,  tu a-jin  bi."'r):,.1  P^-f^i jptnent  Action Grants, since

-------