03 January 2012

Funding Opposed for NGPC Missouri River Grant

In reviewing grant application 12-141: Missouri River Post-Flood Habitat Recovery, these are comments as to why this grant should not be funded as submitted.

As the grant submitted by the Nebraska Game and Parks Commission states, the USDA already has programs in place to address habitat work, thus this project would be redundant. The Army Corps of Engineers also has its mitigation project which could be useful in habitat efforts, yet subsequent to the flood, a Corps' realty staff person I visited with in late December, indicated they have not had any interest in their programs from land owners affected by the 2011 flood.

Within the project summary is the statement: "Recreational landowners, both public and private, will need support renovating floodplain habitats." Certainly the Game and Parks could benefit, but do they actually have landowners requesting assistance? If this agency needs funds for post-flood recovery on public lands, they should have asked for that.

The needs section seems to indicate that this project would be a solution looking for a problem. In this section, there is no identified need indicated, but rather a perspective that there might be a need. Funding should not be provided for a project that does not have any candidate property indicated, nor known, according to the grant application.

The grant application does not even mention where it would occur, other than obviously along the Missouri River. Would there be a focus on lands adjacent to already managed public project sites? Would there be a focus on particular Nebraska counties, such as those below the Platte River confluence. Would any project be limited to property that is entirely cropland, or try to include other habitat such as woodlands to improve site diversity?

Further in the text, the application indicates that USDA, Ducks Unlimited and the Nature Conservancy would be involved. It is apparent that there are already suitable resources to assist any interested landowners.

There is no indication of how this project would be coordinated with the U.S. Army Corps of Engineers, which has been very instrumental - on a large scale - of habitat conservation efforts along the river.

In order to be most effective, any efforts should be done on a coordinated basis with all agencies.

Also, according to information made available, some of the work attributed as being done by NGPC was actually completed or financed by the ACE (flow-through chute at Schilling WMA), yet the application indicates that it was an effort of the NGPC. The NGPC effort has been to sign an agreement to take over management after the work was completed, in many instances along the Missouri River.

There is little or no information available on the direct benefits of habitat recovery projects to nongame birds - for example - as a result of any mitigation or habitat improvement efforts. This includes federal projects, and no details of this sort could be provided by the ACE, despite several requests and discussions of this.

Benefits certainly do result, as wildlife always will take advantage of new habitats. However, particular details - rather than broad statements - that indicate actual results should be available so that any further projects in the future are done in a manner to maximize results in a cost-effective manner. For example, shorebirds have benefited from lowland flooding along the river in the past two years, yet no efforts have been made to actually work with land-owners to actively create and manage such ephemeral habitat.

The Nebraska Game and Parks should not be involved in providing flood disaster relief, as listed in the socio-economic section.

In the budget summary, Environmental Trust and USDA would be the primary source of funding, with NGPC providing a relatively small amount of the hypothetical cost of this project. Yet, there is no letter of support given with the application, which indicates that USDA would provide these funds for the project as prepared by the NGPC.

There is no indication as to whether any funds would be used to hire staff or for any other personnel. If a grant is funded, it should specifically define whether it would be used for this purpose. There are already sufficient people available for the sort of project for which the NGPC asks funding.

In the timeline, the application states it will notify the public of programs options. The programs listed are those of other agencies, and they certainly will continue their ongoing efforts, so any NGPC effort would likely be redundant.

NGPC already has the staff available that could fulfill the needs identified in this project application.

This application was submitted in mid-summer 2011, before the flooding had even ended and its overall impacts were known. Perhaps if the applicant could identify particular needs, after a thorough post-flood evaluation, this project could be approved and directed to specific needs not met by other funding sources.

The applicant failed to specifically identify how it would qualify for "Feature Program Bonus" and a statement "appears to qualify" does not help in detailing any specifics.

With the limited extent of money available to the Environmental Trust, there are other proposals which should receive funding, so application 12-141 should receive a low ranking and not be funded as it was submitted.