By Amy Kenyon

Who doesn’t support a pristine environment and open space? On the face of it, it would seem that everyone might be in favor of the Environmental Protection Agency’s proposal to tell NYC to spend $300 million to buy land and conservation easements in its watersheds over the next 10 years to prevent building a filtration plant for its water supply from the Catskills.

But dig deeper and read through the EPA’s proposal, and you can see that its plan is not the most effective way to protect the environment, and it does not promote the interests of the watershed communities that supply the clean water _ people who live and work here.

The EPA’s plan requires NYC land-acquisition programs to continue for another 10 years (beyond the scope of the original watershed agreement), without any comprehensive planning process, without addressing how their programs will impact our economy or the cost of land and housing, and without including local leadership in the "roundtable" discussions between the city, the state and the federal government.

The EPA’s actions have a serious impact on the future of Delaware County, particularly on the farming community, which is so important to the region’s economy, tax base and culture.

Farming is still an important business in the Catskills, especially in Delaware County. Agriculture not only contributes to the economy, it requires less in services than it pays in taxes, so it helps keep taxes lower for everyone else.

The small, family-scale farms of Delaware County generate roughly $50 million in sales annually, plus all the other businesses they support locally. Despite the challenges of agriculture, there are young people still entering this profession and trying to purchase farms here. As the EPA requires NYC to spend $300 million more buying land and conservation easements, without significant changes to the program, the price of land will be driven higher and become even less affordable for farmers.

If New York City owns a large percentage of land, and only the wealthiest are able to afford to buy in the region, the next generation of people to work the land will go somewhere else. History is full of examples of the problems associated with wealthy, far-away landlords owning all the resources, reducing those who would work the land to tenant farmers. The Anti-Rent Wars are one such example in the Catskills.

Conservation easements protect the land from development but do not keep the price of land from continuing to increase. As second-home owners continue to be willing to pay high prices for land protected by conservation easements, people who want to maintain the land in agriculture are forced out of the market within a generation. Our population of families, farmers, and young people is shrinking as we have fewer good jobs and scarce affordable housing and land.

The city’s current land acquisition programs only address water quality for the city _ not the long-term viability of our farms and villages. The EPA’s proposed Filtration Avoidance Determination does not address the very real impact watershed programs have on the people who live in the watershed.

The city could use the $300 million to protect sensitive land from development AND make sure that our best soils remain affordable for young farmers. The program as it exists now only ensures that land prices will be driven so high that the only agriculture that might remain would be tenant farmers who rent land from the city and wealthier landowners. Vermont and Massachusetts have implemented voluntary programs that not only protect open space through easements, but ensure that the protected farmland continues to be affordable for the next generation of farmers, without hurting the interests of the current farmers whose "retirement" may be their land. We propose that the city be required to do the same for our agriculture community.

If this issue is important to you, please send comments to the EPA before May 31. Comments can be e-mailed to sweeney.philip@epa.gov or mailed to New York City Watershed Team, USEPA Region 2,

290 Broadway, 28th Floor

New York, NY 10007.

Local communities should be equal partners in watershed programs and their economic concerns need to be included and considered. It is wrong for the city and the federal and state government to create a 10-year, $300 million watershed program without the local communities that supply the water at the table as a stakeholder.

As part of the program, New York City should develop new programs that can keep farmland affordable for new farmers, and ensure some level of affordable housing in the watershed. These models have been well-researched and developed in other regions, and the city should be adapting these models for use in the watershed, rather than continuing its existing programs without doing more to protect the communities that live here now.

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Amy Kenyon, of East Meredith, writes on behalf of the board of Farm Catskills, a grass-roots membership organization based in Delaware County.