Who We Are
The Kansas Natural Resource Coalition (KNRC) as an instrumentality of its member county governments, engages state and federal agencies during environmental and natural resource administrative rule-making processes and other actions.
Our members understand the limited role of executive branch agencies, the legal parity enjoyed by local government, and that state and federal procedural mandates require balancing of economic, social, cultural, and property interests when developing and implementing natural resource policies.
When executive branch agencies propose regulatory actions for our region we investigate the statutory basis for the proposals, a process we call “Show Us The Law.” Because many agencies believe they have the authority to enact administrative law, we do not accept regulations, policies or memoranda as binding without clear statutory authority. Similarly, because courts interpret, but cannot make law, KNRC does not accept opinions, decisions, or definitions of by courts as sufficient by themselves to justify administrative proposals. we hold that the legislative branch of government is the sole organic source of lawmaking.
How We Work
KNRC is comprised of elected commissioners from individual member counties, an executive director, a research analyst, a communications analyst and retained professional and legal staff on an as-needed basis.
Day-to-day operations are overseen by a steering committee that in turn reports to a policy committee governed by all member counties.
Each KNRC county has adopted a Natural Resource Land Use Plan that by federal statute requires review, coordination, and consistency in a government-to-government relationship from agencies desiring to impose rules in the jurisdictional areas governed by those counties.
This maintains local voice, assures mutual access to data and science, provides a platform for genuine transparency, and ensures balanced decision-making for both the human and natural environments.
Why it’s Effective
Navigating the maze of state and federal environmental actions is daunting for even the most involved local governments — let alone the balance of America’s 3,000-plus counties.
KNRC’s deep research, clear understanding of administrative procedure, strict adherence to statutory requirements and tactical application of government-to-government relationships brings clarity to the process and accountability for agencies who dismissively bypass the prerogatives and authority of local government.
Our philosophy, strategic plan, and long-term objectives include equipping local governments and and exhibiting their hard-won successes to others across the nation. History teaches that centralized, top-down autocratic government won’t work long term. Success requires reverting to local control.
Only local government can leverage accountability from administrative agencies during natural resource policy actions. Neither industry nor business associations, nor nongovernmental organizations (NGOs) have the authority to do so.
KNRC Provides Testimony Concerning the 30×30 and National Heritage Area Initiatives Before Special Committee
December 9, 2021 — KNRC’s Incoming Executive Director Tracey Barton provided testimony to a Kansas Special Legislative Committee on the Biden Administration’s America the Beautiful (30×30) program and the Kansas-Nebraska National Heritage Area (NHA) initiatives. Live testimony may be viewed here.
The America the Beautiful initiative is responsive to President Biden’s Executive Order 14008 provision to place at least 30% of the nation’s lands and waters in formal conservation before the end of 2030. This a step toward an eventual goal of placing 50% of the nation’s lands and waters in conservation before the end of 2050, a goal established internationally as part of the NGO-driven Half Earth project.
The Kansas-Nebraska National Heritage Area initiative is another program that has caused a great deal of concern among Kansas counties, businesses, and landholders. it would include 23 Nebraska and 26 Kansas counties in its footprint.
Executive Director Jim Carlson briefed KNRC member counties on both issues at KNRC’s Policy Committee meeting in Dodge City. The members in attendance voted unanimously to take a stand opposing both initiatives.
Proposed Lesser Prairie Chicken Habitat Conservation Plan Creates Possible Impacts to Oil and Gas Industry
February 11, 2022 – The U.S. Fish and Wildlife Service (FWS) announced availability of a draft habitat conservation plan (HCP) and draft environmental assessment (EA) covering potential impacts to the Lesser prairie-chicken (LPC) from oil and gas development in the Great Plains in the Federal Register of February 11, 2022. A public comment period on the proposal is now open through March 14, 2022.
If approved, the HCP will cover all activities associated with oil and gas development and operations throughout the LPC’s range in Kansas, Colorado, Oklahoma, Texas, and New Mexico. The HCP imposes fees on oil and gas developers in exchange for a permit in the event the LPC is listed. FWS plans to announce their final decision before June 1, 2022.
KNRC will prepare substantive comments to the record for the HCP proposal. Please review the maps, associated costs, and the FWS Questions and Answers: Lesser Prairie-Chicken Oil and Gas Energy Draft Habitat Conservation Plan for LPC Conservation, LLC for more detailed information.
Senator Moran Introduces Bill to Designate the Chisholm and Western National Historic Trails
Wednesday, April 14, 2021 — Today Senator Jerry Moran Introduced S. 1112, A bill to amend the National Trails System Act to designate the Chisholm National Historic Trail and the Western National Historic Trail, and for other purposes. In the House, Representative Ron Estes introduced a House companion bill, H.R. 2512. These bills replace those introduced in November 2020 (S. 4905 and H.R. 8771). Official text for the House version has not yet been published.
The proposed trails would extend through 22 Kansas counties, and segments would be present in 78 counties through portions of four states.
In 2009 Congress authorized a NEPA feasibility study, and in 2016 the National Park Service (NPS) issued a finding of no significant impact and proposed designating two NHTs as a single administrative unit. The final feasibility study and environmental assessment were not transmitted to Congress until mid-2019.
If Congress designates the proposed NHTs, NPS must complete a comprehensive management plan (CMP) within two years of designation. NPS Director’s Order (DO) 45 requires the CMP to “… identify the minimum level of regulation necessary to protect the resources and attributes …” that warranted designation.
KNRC has been monitoring S. 1112 and H.R. 2512. Staff reported on the NHT proposal to member counties in late summer of 2020 and provided a webinar to members and other key parties. While improvements beneficial to property owners have been made to the legislation, a statutory “no net loss” provisions may be necessary to ensure that donated lands removed from county tax rolls are compensated under the federal Payment in Lieu of Tax (PILT) system. KNRC has currently not taken a position on S. 1112 or H.R. 2512.