Members of the South Dakota Farm Bureau are expressing concerns about the Natural Resources Conservation Service (NRCS) now relying on off-site methods for determining which areas are classified as wetlands on South Dakota farms, a new practice that has just gone into effect.


NRCS staff members are no longer required to physically come out to examine the property in question or take soil samples when a farmer requests a wetland determination. Instead, NRCS is allowed to use computer imagery, aerial photos, and soil maps to make decisions about what does or does not constitute a wetland. In some cases, this type of work is outsourced to people outside of South Dakota in computer laboratories in places as far away as Texas.

“Accuracy and good customer service are the two building blocks of a successful wetland determination,” commented Wayne Smith, farmer from Moody County and SDFB Wetlands Specialist. “Despite concerns being raised time and time again by South Dakota farmers, NRCS is now able to rely solely on off-site methods for determining wetlands instead of actually coming out to see the land and take samples of the soil. This might be a faster method for NRCS to get through their backlog of determinations, but they are going to be sacrificing accuracy – and accuracy should be of utmost concern to all parties involved.”

Last summer on July 30, more than 350 farmers gathered in Aberdeen for a public forum with state and national NRCS officials. When the NRCS officials suggested using off-site methods as a way to speed up the backlog of wetlands determinations, farmers present expressed concern about the level of accuracy that could be achieved without an actual site visit. Several reported cases where on-site data gathered by private consultants did not find enough technical evidence to support a wetland, but subsequent spot-checks done by NRCS using only off-site methods overruled that and did determine the area a “wetland.”

The farmers and soil-scientist consultants gathered in Aberdeen wanted to see more reliance on soil science and actual site visits, rather than remote-sensing off-site methods, to accurately identify true wetlands instead of giving false-positives. This sentiment was echoed at a listening session hosted by NRCS last August on the topic of off-site methods, as well as in public comments sent in to NRCS by Farm Bureau members and others during a comment period which closed this February.

Mike Schmidt farms and raises livestock northeast of Dell Rapids and has followed these water issues for a number of years. He says he’s glad to hear that NRCS is finding a way to reduce the backlog of wetland determination requests, but he feels on-site visits are still important to gathering the most accurate data.

“I’m glad that NRCS is trying to accelerate the process and finally get through the backlog. Off-site methods may be a way to help get that done, but if there’s an issue, I strongly feel that the producer should have the ability to request an on-site visit. Sometimes, to get to the truth, there’s no other way but through a field visit to see what’s actually there,” Schmidt commented.

Smith says farmers should closely evaluate this new process going forward.

“Farmers do have reconsideration and appeal rights if they do not agree with the preliminary determination. Keep in mind that you do have to follow the timelines provided by NRCS for reconsideration and appeals in order to keep your options alive,” Smith noted.

On a positive note, NRCS is now acknowledging “best-drained conditions” for those areas labeled Farmed Wetland (FW). This gives farmers the right to go back to whatever the best-drained condition was in the past.

“If a farmer has an area labeled FW, it means the area at some time had manipulation, which could include a ditch of some sort, or tile drainage. In this case, the farmer has the right to the best-drained conditions that existed since the manipulation occurred. This means finding evidence through imagery or engineering specifications showing how well the manipulation accomplished the goal of draining the area. NRCS acknowledging ‘best-drained conditions’ is a victory for farmers,” Smith added.

The South Dakota Farm Bureau is the state’s largest general agriculture organization, representing more than 15,000 farm, ranch and rural families across the state. SDFB policy positions are all created by its grassroots members at the County Farm Bureau level.