January 10, 2000

DARBY-Ohio continues its enthusiastic support for the proposed Little Darby National Wildlife Refuge as described in the recently-released Draft Environmental Assessment. We encourage the USFWS to create this Refuge as soon as possible. The need for urgency was underscored by the recent US Agriculture Department study reported by the Columbus Dispatch on 12/8/99 under the headline "Spread of sprawl doubled in ‘90s." The same article notes that in just five years an area 10-times the size of the Refuge was converted from farmland to development in Ohio ("In Ohio, 521,200 acres of farmland were developed between 1992 and 1997").

The following are key to our support for the Refuge:

A. Continued Commitment to Key Refuge Goals

DARBY-Ohio’s support has always been and remains contingent on the USFWS maintaining its commitment to its original Key Goals for the project. We find the Draft Environmental Assessment to be consistent with these goals:

1. To Protect Threatened Species in the Watershed.

2. To Protect Migratory Birds & Habitat.

3. To Provide Public Use Opportunities. (Public use compatible with the Refuge’s objectives will probably include hunting, fishing, photography, wildlife education and interpretation.)

4. To Ensure above goals are achieved while respecting agriculture as an existing desirable land use.

B. Continued USFWS Sensitivity to Feedback

DARBY-Ohio considers the Draft Environmental Assessment another example of how USFWS has listened to feedback gained in the public comment process. This latest refinement of the plan states that Alternative 2 is the preferred approach for the Refuge. Alternative 2 "contains the most miles of streams" of the three options considered. This responds directly to input that the Refuge should focus as much as possible on stream protection (e.g. ODNR’s suggestion that the refuge should have "an emphasis on the stream corridor"). USFWS has even extended the farmland preservation area downstream toward West Jefferson.

Also in response to public comment, the USFWS refuge proposal continues to incorporate an innovative farmland preservation program. DARBY-Ohio considers this an important statement that wildlife and agriculture can co-exist and work cooperatively. With over half the area proposed as farmland preservation area, DARBY-Ohio notes that people involved in agriculture will have their way of life protected for subsequent generations. Also, USFWS has said that eminent domain will not be used for purchases without the owner’s agreement.

C. Focus on Sprawl as a Primary Threat

DARBY-Ohio believes urban sprawl is the primary threat to the continued health of the Darby Creeks.

USFWS has appropriately focused on this issue as indicated by the following quotes from the Draft Environmental Assessment:

• "Urban-related development is a principal threat to both agriculture and natural systems in the Darby Creek Watershed." (page 4)
• "Housing developments and associated commercial establishments are potentially the strongest and longest-lasting source of stress to the Darby and Little Darby Creeks." (page 5)

DARBY-Ohio agrees with USFWS that current local planning controls are "unlikely" to deter the threat of sprawl in the Darby watershed. The Economic Assessment clearly indicates this is a key threat to the Refuge area with population growth in the Study Area from 1980-1998 being three times higher than Ohio’s state average. This rate is even higher in the Refuge Area Townships in Madison County.

D. Need for Farmland Preservation

DARBY-Ohio agrees with USFWS that agriculture is preferred over urban development as an existing desirable land use. We note that the plan highlights the threat of sprawl toward farmland and how this threat is particularly acute in Ohio and especially in the Darby watershed.

• "From 1982-1992, Ohio ranked third in the country in the number of acres of prime or unique farmland converted to urban land. This accounted for nearly 60 percent of all land developed in Ohio during the period." (page 5)
• "It is estimated that in just 7 years, 8 percent of Darby farmland has been lost to suburban housing developments, trailer parks and strip malls, and there was a quadupling in urban development in the region between 1965 and 1988." (page 6)
• "In Champaign, Madison, and Union counties respectively, 8,000, 7,000 and 11,000 acres of farmland were taken out of agricultural production between 1990 and 1997." (page 59)

About Darby-Ohio

DARBY-Ohio announced its formation on August 5, 1999. DARBY-Ohio stands for Darby Alliance for the Refuge on Behalf of the Youth of Ohio. It is a statewide coalition of environmental and conservation groups united together to support the most important ecological restoration project ever proposed in central Ohio: the establishment of the proposed Little Darby National Wildlife Refuge along Little Darby Creek.

DARBY-Ohio believes this Refuge is the BEST way to allow everyone to experience this National Scenic River. We say we are working on behalf of youth because this is a long-term project that will protect natural resources and farmland from long-term development pressures. The Refuge is the best way to guarantee that Darby Creek National Scenic River will be protected for subsequent generations.

DARBY-Ohio’s members include the Ohio Environmental Council, Columbus Audubon Society, and the Darby Creek Association, and it is supported by Sierra Club-Ohio Chapter, Pheasants Forever - Ohio Council, The Ohio Smallmouth Alliance, Citizen Speak Out, Buckeye Forest Council, Erie Metroparks, Central Ohio Green Education Fund, The Hocking River Commission, Kokosing Scenic River Association, Loveland Greenbelt Community Council, Northside Greenspace, Inc., Ohio Lepidopterists, Olentangy River Valley Association, Rural Action, Sandusky Scenic River Advisory Council, Sugar Creek Protection Society, The Nature Conservancy, Tinkers Creek Land Conservancy, Friends of Blacklick Creek, Friends of the Lower Olentangy, Ducks Unlimited - Ohio Chapter, Citizens Protecting Ohio. Central Ohio cities that have passed resolutions expressing support for the Refuge include the City of Columbus, the City of Dublin, the City of Gahanna and the City of Upper Arlington. Taken together, these organizations and municipalities represent nearly 1 million Ohioans.