Implementing Agricultural
Performance Standards and Prohibitions

County Questionnaire Results
July 2003

Additional Questionnaire Information

In addition to the information provided on the components of the implementation strategy, counties were asked several additional questions related to the strategy.

Level of Commitment

When asked what level of commitment in terms of numbers of staff, time, local cost sharing, etc. they will dedicate towards implementation of this strategy, ten counties provided estimates. The estimate for the number of staff ranged from 0.5 full-time employees (FTE) through 2004 to 3.6 (as available) while the number of staff hours ranged from 500/year to about 4,000 (if it's a locally –based priority or grant condition). Only 2 counties reported having a local cost-share program that they would use for state match. About 25-30% of the counties that responded to this question said they were unsure about their level of commitment. Another 25-30% said they would need more funds for staff or would have to reassign existing staff to implement the NR 151 strategy.

A companion question asked for the level of commitment from counties towards other efforts to achieve compliance with NR 151. Most of the answers were similar to those of the previous question, but 4 counties gave estimates of staff and staff hours of 25%, 50%, ¼ staff and ½ staff. Three counties stated that they are or will be devoting time to implementing non-agricultural performance standards.

Suggestions For Improving The Implementation Strategy

Most of the suggestions called for more funding, especially for staff to do the implementation and administrative work. While most funding issues are outside the scope of the implementation strategy, several of the suggestions are listed below as ideas to guide future budget discussions.

  • determine and implement a dedicated funding source for county staff to do this work
  • increase state funding support for those counties that implement the strategy and support counties that attempt to implement NR 151 when the going gets difficult
  • re-examine the strategy in light of recent budget impacts
  • tie staffing grants to implementation

The following is a sample of the many other suggestions that were submitted.

  • develop a computerized system with online reporting
  • make ArcGIS extensions available to counties for inventory/compliance tracking and development of conservation plans
  • allow counties to identify specific performance standards that are of higher priority to them and work on those first
  • make it simpler, clearer and more direct
  • provide 1 state staff person for review/concern
  • set goals, deadlines, etc. and meet them; set repercussions if the state does not meet reasonable deadlines and goals
  • training on the implementation of the rules and how the state sees the counties' role
  • provide more opportunity to share in ideas and techniques between counties
  • keep paperwork and reporting to a minimum
  • place a greater emphasis on voluntary approaches, landowner incentives and effective I&E rather then on inspections and enforcement
  • offer some implementation options other than counties
  • provide ideas or open discussion on the role other agencies may play in doing this
  • put all the tools in place first (RUSLE II, MOU, staffing)
  • make the strategy more targeted; allow counties to work with farmers on a voluntary basis first; at the same time target individuals (as in NR 243 violations); a watershed approach takes too long and doesn't target the right people
  • start over

Components That Should be Conducted Primarily by the State

When asked which of the strategy components should be conducted primarily by the state, the majority of the counties responded that enforcement or enforcement-related activities should be handled by the state. Other components that were mentioned were 2) defining workload, 3) I&E, 4) on-site evaluations portion of determining compliance, and 5) notification of compliance status.

Additional Technical or Policy Implementation Issues

Several additional implementation issues were raised including the following examples:

  • implementation of the non-agricultural/transportation performance standards and NR 216 specifically as they affect counties
  • how federal cost-sharing and staff will be used
  • the models that will be used to determine compliance/non-compliance need to be consistent and be such that everyone who needs them can use them (what are those models for soil prediction, standards, BMPs, etc.?); there needs to be scientific verification of the models and tools necessary to implement these programs
  • will the staffing resources of each county be taken into account in the state-wide strategy (e.g. impact on Land Conservation Departments (LCDs) with few staff)
  • LCD staff not convinced to provide cost-sharing for practices that require maintenance, payment of "lost opportunity" costs or payment to get to "T"
  • state should provide database monitoring for reports
  • which components and what level of time and resources is DNR going to commit to implementing this strategy; will DNR stay committed to following through with the things they say they are going to do?
  • lack of incentives to implement the redesigned program
  • no goals, timeframes or expectations for when any administrative function, much less compliance, is to be achieved
  • effects of farm economy—conflict between farm profitability and compliance with standards

The following links provide more detailed information on each component




For more information about this page, please contact: John Pfender
Last Revised: Friday August 08 2008