October 16, 2007
Cindy Smith
Administrator
APHIS USDA
14th & Independence Ave SW
Washington, DC 20250
Dear Ms. Smith:
We truly appreciate the time you and your staff took to attend and participate in our annual meeting. As you know, we took positions on several items that relate directly to the APHIS mission. We look forward to working with APHIS and the National Plant Board to advance these important issues.
1. NASDA supports USDA APHIS and USDA Forest Service developing a national educational and outreach program informing interstate tourists and travelers that firewood has the potential to introduce dangerous and damaging plant pests that is consistent and uniform across state lines.
This outreach program should be developed in cooperation with the National Plant Board and the National Association of State Foresters. In addition, USDA should develop and approve criteria that would mitigate the movement of pests in firewood. USDA should consider including heat treatment methods for firewood along with other processes / methods that could be adopted by the commercial firewood industry. NASDA concurs with the National Plant Board that USDA APHIS should immediately start the process of federally regulating the interstate movement of firewood as a commodity.
2. NASDA supports the implementation of the USDA Science Panel’s recommendations for control of Sirex noctilio (wood wasp). USDA should also consider cooperating with Canada in developing protocols to manage Sirex infestations.
3. NASDA supports the implementation of a national survey for exotic honey bee pests to protect the U.S. beekeeping industry from the introduction of exotic pests through imported packaged honey bees and queens from foreign countries. The national survey should be fully funded and accomplished as quickly as possible.
In related activities, NASDA is urging Congress to authorize resources for sustained research and analysis to address Colony Collapse Disorder (CCD) and other bee issues that affect the food security of the United States (S. 1694 and H.R. 1709 the Pollinator Protection Act of 2007 are examples of Congressional legislation in support of bee research supported by NASDA). The importance of the effects of CCD cannot be over emphasized, further supporting the need for the national survey.
4. NASDA requests that the USDA, APHIS, PPQ develop and implement a streamlined process for the review and approval of new pesticide treatment methods for incorporation in control programs for regulated plant pests. The process would allow EPA registered pesticides that have been approved by USDA, APHIS, PPQ staff and researchers to be legally binding upon listing in the individual program manuals. Treatment materials included in program manuals could be legally used in quarantine programs concurrently during the period they are being incorporated into the Code of Federal Regulations.
We appreciate the cooperative and collaborative program efforts we share with you. Feel free to contact us if you have any questions regarding any of these issues.
Sincerely,
Roger Johnson
President
NASDA
Commissioner
North Dakota Department of Agriculture
cc: Ric Dunkle
John Clifford
Gray Haun
Greg Ibach
Lester Spell