October 16, 2007
James Hubbard
Deputy Chief, State & Private Forestry
Forest Service, USDA
14th & Independence Av SW
Washington, DC 20250
Dear Mr. Hubbard:
The National Association of State Departments of Agriculture (NASDA) is a nonprofit association whose members are the commissioners, secretaries and directors of the fifty states and 4 territories. The Association recently took positions on issues related directly to the Forest Service mission. We look forward to working with the Forest Service and the National Plant Board (NPB) to advance these important issues. We also understand that several members of the NPB met with you recently (since NASDA’s annual meeting) to discuss the redesign project and its implication to the Gypsy Moth: Slow The Spread efforts. As you are no doubt aware, in addition to Gypsy Moth funding, several NASDA member agencies also receive funds from the Forest Health Program for emerald ash borer, Sirex and several other surveys through our cooperative interests to curb exotic pests and diseases.
1. NASDA was briefed on the US Forest Service State and Private Forestry Redesign project at its meeting in September. We were disappointed to learn that this project was proceeding without input from the NPB and would likely affect funding of the Forest Health Program, an area of vital interest to NASDA. NASDA supports the NPB’s request that the State and Private Forestry budget exclude Forest Health Program resources from the competitive resource allocation process. NASDA also supports the NPB’s request to meet with you and fully discuss your redesign project.
We understand that you may be able to offer a position to the NPB on the implementation committee for the redesign project. We assume this will assure further advancements of programs of mutual interest within the Forest Health Program aimed at eradication / mitigation of pests and diseases of interest to the Forest Service and the States. It would be a travesty if fewer funds were made available for these important issues because of this redesign project. The combined authorities of federal and state agriculture and forestry programs compliment each other; the unique regulatory authority of the state agriculture agencies makes our partnerships with the state forestry agencies (some of which are housed within the same agency in several states) an important component of successful pest exclusion and eradication programs. These liaisons should be further strengthened and made transparent in any reorganization effort, rather than weakened or made more difficult, cumbersome or bureaucratic. In addition, the idea of making funding of pest exclusion, eradication, detection, response or recovery a competitive process seems to condone a desire to allow lesser priority pests to become established. This is truly counterproductive and must be avoided. Let us know how you perceive future steps transpiring so that we may work cooperatively with you through the NPB membership to assure beneficial and successful supportive programs.
Another topic of mutual interest is that NASDA took a position on is:
2. NASDA supports USDA APHIS and USDA Forest Service developing a national educational and outreach program that is consistent and uniform across state lines and will inform interstate tourists and travelers that firewood has the potential to introduce dangerous and damaging plant pests.
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.
NASDA also took a position on another key forestry related issue. Since cooperation with the Forest Service through the Forest Health Program has lead to advances in developing means to more rapidly respond to the Sirex wood wasp, we want you to know that the Association supports the implementation of the USDA Science Panel’s recommendations for control of Sirex noctilio (wood wasp). NASDA also believes that USDA should consider cooperating with Canada in developing protocols to manage Sirex infestations.
If you have any questions regarding our position on these topics, please feel free to contact us.
Sincerely,
Roger Johnson
President
NASDA
Commissioner
North Dakota Department of Agriculture
cc: Cindy Smith, APHIS Administrator
Rob Mangold, FS Forest Health Program
Gray Haun, NPB President
Greg Ibach, Nebraska Department of Agriculture
Lester Spell, Mississippi Department of Agriculture and Commerce