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NASDA URGES ACTION ON CUBA TRADE & CARBON MARKETS
Published: February 18, 2008
The state agriculture departments are calling on the Bush administration to interpret the Trade Sanctions Reform and Export Enhancement Act as broadly as possible, to enable U.S. companies to compete with other countries in Cuba. NASDA members unanimously adopted a policy amendment offered by Nebraska Agriculture Director Greg Ibach during the group's recently concluded midyear meeting.
NASDA President and North Dakota Agriculture Commissioner Roger Johnson noted that U.S. trade policy with Cuba is completely inconsistent with respect to the United States' relations with other countries. He said that "Cuba is a major potential market for U.S. products, especially agricultural products, but our efforts to increase trade there are severely restricted by our own federal government." Johnson is leading a 12-member North Dakota trade delegation to Cuba this week.
NASDA members also approved a resolution in support of a carbon emissions cap and trade system. Montana Agriculture Director Ron de Yong cosponsored the energy policy amendment with Johnson. de Yong noted that a cap and trade system for lowering carbon dioxide emissions has been adopted by the European Union, where carbon credits traded recently at about $24 per ton. In this country, the Chicago Climate Exchange manages a voluntary registry, from which industries can purchase carbon credits offered by agriculture and other industries. Credits on the Chicago exchange have traded recently for between $3.50 and $4 per ton. Farmers can currently earn up to $2 per acre by adopting no-till practices and other measures to reduce carbon dioxide emissions. The six-fold reduction in price compared to Europe would likely disappear if a nationwide mandatory system were adopted in the United States, de Yong said. (Contact: Charlie Ingram)
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AG LEADERS PROMOTE RESEARCH ON HIGHER ETHANOL BLENDS
Published: February 18, 2008
NASDA members are urging the Environmental Protection Agency (EPA) to promote increased research to make higher percentage ethanol blends, such as E20 and E30, available to American consumers. The expansion and utilization of renewable fuels resources has been one of NASDA's top priorities.
The Energy Independence and Security Act of 2007 mandates an increase in renewable fuels (RFS) to 36 billion gallons annually by 2022. It also directs EPA to ensure that the target volumes of renewable fuels are introduced into the U.S. annually. In a letter to EPA Administrator Stephen Johnson, NASDA President and North Dakota Agriculture Commissioner Roger Johnson said America's transportation infrastructure is insufficient to move enough ethanol from the production centers in the Midwest to the dense population centers on the coasts. "This logistical roadblock makes it impractical to satisfy the RFS mandate utilizing current blends of renewable fuels," he said. "By incorporating higher blends of ethanol, we can help meet annual target volumes of the RFS while working to improve the biofuels transportation infrastructure."
NASDA pointed out that the Minnesota Department of Agriculture is leading an effort to provide the scientific basis that EPA needs to support a waiver for an E20 ethanol blend. The letter noted that research demonstrates that the higher blends do not pose a threat to the environment and human health, and that they increase efficiency, while decreasing pollution. EPA is also working with others to look at issues beyond those relating to human health and the environment. NASDA's letter said it is important that those issues such as engine performance, engine wear, etc., be studied. NASDA encouraged EPA to complete these studies quickly in order to avoid serious market disruption resulting from the rapid expansion of the ethanol industry in the Midwest. (Contact: Charlie Ingram)
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NASDA URGES CONGRESS TO LINK FOOD PROGRAMS WITH LOCAL PRODUCERS
Published: February 18, 2008
NASDA has urged Congress to encourage the use of locally produced fruits, vegetables, and other food products in federal nutrition programs. The issue has been one of NASDA's key nutrition recommendations for the 2007 farm bill.
In a letter to members of the House and Senate Agriculture Committees, NASDA said the goals of federal nutrition programs are best achieved when there is a connection between nutrition program recipients and those who farm close to them. "These programs help ensure that good nutrition is available to everyone," said North Dakota Agriculture Commissioner and NASDA President Roger Johnson. "At the same time, these programs are providing agricultural producers with new markets for fresh fruits, vegetables, and other commodities."
The letter was endorsed by NASDA's membership during the group's recent midyear conference in Washington, D.C. It was presented by Alabama Agriculture Commissioner Ron Sparks, who chairs NASDA's Food Regulation & Nutrition Committee, along with North Carolina Agriculture Commissioner Steve Troxler who co-chairs the panel. "This approach also reduces the distance food must travel, which in turn helps shrink both our overall carbon footprint and the transportation costs associated with these programs," they said. "By buying directly from local producers, program administrators improve efficiency and accountability while helping to sustain local agricultural operations." (Contact: Charlie Ingram)
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NASDA ADOPTS RESOLUTION ON PESTICIDE CANCELLATION
Published: February 18, 2008
NASDA has adopted a resolution urging the Environmental Protection Agency (EPA) not to cancel the registration of a widely-used pesticide until effective, alternative products are available.
In a letter to James Gulliford, EPA deputy administrator for prevention, pesticides and toxic substances, NASDA expressed concern about the continued availability of effective agricultural products that are critical to producers and the farm economy. EPA's proposal to cancel the crop protection chemical carbofuran is a matter of concern, particularly to Midwestern corn growing states. The use of carbofuran is also important to specialty crop producers, such as sunflower growers who use it to control stem weevils, especially when there are no alternative or cost-effective products available in the marketplace.
The state departments of agriculture have long been the lead state agencies for implementing federal pesticide laws. NASDA supports efforts to ensure that chemical/pesticide use does not cause unreasonable adverse effects to human health and the environment. The carbofuran issue was presented by Illinois Agriculture Director Chuck Hartke and Iowa Agriculture Secretary Bill Northey. NASDA members adopted the resolution on carbofuran during their recent midyear meeting in Washington, D.C. (Contact: Charlie Ingram)
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NASDA URGES SCHAFER TO REVISIT DISASTER PROGRAM
Published: February 18, 2008
NASDA has urged the new U.S. secretary of agriculture to reconsider the Senate-approved proposal of a permanent disaster program in the 2007 farm bill. NASDA's president, North Dakota Agriculture Commissioner Roger Johnson, delivered the letter to Schafer after he addressed NASDA's midyear conference on February 11.
The NASDA membership--the agriculture commissioners, secretaries and directors of the 50 states and four U.S. territories--welcomed Schafer, congratulated him on his recent confirmation and presented him with more than 200 recommendations for the farm bill. Specifically, they urged him to reconsider the administration's continued dependence on existing programs and ad-hoc assistance to deal with disaster situations. "We are disappointed in your January 31 statement indicating that you will not fight the administration's opposition to a permanent fund for weather-related disaster aid," the NASDA membership said in the letter. "We believe it to be a mistake and shortsighted to pass up the opportunity to fix this obvious shortfall in the safety net."
"Relying on crop insurance and ad-hoc assistance to deal with disaster situations has proven to be inefficient, unreliable and unpredictable," they said, pointing out that producers are just now getting disaster assistance payments for losses suffered in 2005, 2006 or 2007 and that the waiting has caused others to go out of business. "Continuing down this policy path is unacceptable." The letter described the program in the Senate version as "national in scope," providing disaster relief for all producers who purchase crop insurance or participate in the Non-insured Assistance Program (NAP). The NASDA members said the program complements crop insurance by providing an incentive for producers to purchase higher levels of coverage. It also includes a livestock indemnity program for disaster-related livestock deaths, and is based on "whole-farm revenue," providing assistance only when a farm's total revenue falls below the determined revenue guarantee.
NASDA's letter also pointed out that "it will likely cost less in the long-term than ad-hoc assistance programs, which are often delivered in a 'shotgun' approach."
"It targets assistance to those who need assistance when they need it." (Contact: Charlie Ingram)
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CONGRESSIONAL & ADMINISTRATION LEADERS ADDRESS NASDA MEETING
Published: February 18, 2008
NASDA members had the opportunity to meet and hear from key House and Senate agriculture leaders and administration officials during their recently concluded midyear meeting held February 7 to 11 in Washington, D.C.
House Agriculture Committee Chairman Collin Peterson (D-Minn.) addressed the NASDA general session on Friday, February 8, and discussed the latest 2007 farm bill activities. Peterson explained his work to reach a compromise on farm bill funding and policy issues. On February 9, Peterson and ranking member Bob Goodlatte (R-Va.) issued an "open letter" to the agriculture community outlining their plans to advance the 2007 farm bill (see separate story).
Senate Agriculture Committee ranking member Saxby Chambliss (R-Ga.) also addressed the NASDA membership. He agreed with the need for an agreement on the 2007 farm bill, but pointed out the Senate had different sentiments about timing, funding, and specific policy issues. The NASDA session was moderated by former Congressman Charlie Stenholm who offered his own perspectives on the farm bill activities in the House, Senate, and administration.
USDA Secretary Ed Schafer spoke during NASDA's business session on February 11 and described his goals for the farm bill and other key agricultural policy issues. Schafer said he had already taken an active role in the congressional farm bill negotiations and reiterated that President Bush would not support a bill that raised taxes or failed to make real reforms in farm programs. (Contact: Rick Kirchhoff)
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NASDA COMMITTEES DISCUSS KEY TOPICS AT MIDYEAR MEETING
Published: February 18, 2008
NASDA's policy committees discussed key topics on trade, immigration, specialty crops, and other issues during their midyear conference held in Washington, D.C., from February 7 through 11. The state agriculture leaders also continued to advance NASDA's 2007 farm bill recommendations in meetings with congressional and administration officials (see separate story).
The Marketing and International Trade Committee, chaired by Florida Agriculture Commissioner Charles Bronson, heard a report from USDA's Foreign Agricultural Service (FAS) about NAFTA implementation including latest trade numbers and specific information on Canada and Mexico. The Consultative Committee on Agriculture (CCA) for Mexico met in January 2008 and issues of concern include trade in livestock, dry beans, corn, potatoes and apples. USDA's Animal and Plant Health Inspection Service (APHIS) answered questions concerning trade with Mexico and offered assistance to work with NASDA on Accord issues.
Minnesota Agriculture Commissioner Gene Hugoson, co-chair, U.S./Canada Working Group, and California Secretary A.G. Kawamura, co-chair, U.S./Mexico Working Group, provided updates to the committee regarding preparation for the 2008 Accord meeting in Coeur D'Alene, Idaho. It will be held August 13 to 15, 2008, and meeting registration will start in mid-March. New Mexico Agriculture Secretary Miley Gonzalez informed members about the activities of the trilateral working group on rural development and its October 2007 meeting in Edmonton, Alberta, Canada. Additional meeting dates were also announced--please check the Accord website, http://www.nasda.org/accord/, for details.
California Agriculture Secretary A.G. Kawamura chaired NASDA's Specialty Crops Task Force meeting on February 7. Members heard from USDA's Agricultural Marketing Service (AMS) about the Specialty Crops Block Grant Program. The next deadline for grant applications is April 11, 2008. Twenty-one states have projects approved for FY07. Furthermore, $8.39 million is available in FY08 and a notice of fund availability will published in the Federal Register in coming weeks. Representatives from the Western Growers Association and WineAmerica gave reports on the specialty crop provisions in the 2007 farm bill.
NASDA's Rural Development and Financial Security Committee, chaired by Oklahoma Agriculture Commissioner Terry Peach, heard legislative reports on bioenergy, immigration reform and transportation. Matt Hartwig of the Renewable Fuels Association (RFA) provided an update on the ethanol industry and its impact on agriculture. Members also heard updates on AgJOBS legislation and the proposed changes to the H2A workers program recently announced by the Bush administration. Committee members also discussed transportation legislation that would provide certain exemptions to drivers of intrastate commercial motor vehicles engaged in agricultural purposes.
All of NASDA's midyear meeting documents, including committee reports, policy amendments and action items, are available on the NASDA website, http://www.nasda.org. (Contact: Charlie Ingram)
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DONNA RISE RETURNING TO MONTANA
Published: February 18, 2008
Nevada Agriculture Director Donna Rise has announced she is returning to Montana to resume a job as a bureau chief for that state's agriculture agency. While Rise called her brief tenure as Nevada agriculture director an "amazing experience," she added, "I guess down deep I'm still a Montana girl." Her resignation is effective Feb. 20.
"When I took the job, it was with the intent of finishing out my career, as director, for the next 15 ears," Rise wrote. "One cannot, however, predict whether a role or experience is a good fit until such time as they are tried."
She said while she valued the experience, "it has become clear to me that the position of director is not a particularly good fit for me."
"I come from a state where cattle outnumber people and amber waves of grain has a true meaning for me," Rise said during a board meeting last week in Reno.
Under state law, Nevada Deputy Agriculture Director Rick Gimlin will assume the post until the board recommends a permanent replacement to the governor, who makes the final selection.
Prior to her appointment as director, Rise served in a number of different capacities within the Montana Department of Agriculture. She began with the department in 1992 and served as an agriculture specialist. She later went on to serve as a groundwater specialist, groundwater specialist III, programs manager, and, most recently, the commodity services bureau chief. She earned a bachelor's of science degree in horticulture from Montana State University, Bozeman.
Throughout her 15 years with the Montana Department of Agriculture, Rise's career includes several industry-related accomplishments including authoring the Montana Generic Management Plan, coauthoring the Montana General Agricultural Chemical Groundwater Management Plan, drafting the administrative rules for the state's first Agricultural Chemical Groundwater Management Plan, establishing quality control/quality assurance policies and standard operating procedures for the groundwater program, establishing an employee recognition and appreciation program, the development of enforcement case development procedures for apiary and nursery programs and standardizing case development procedures for all regulatory programs. (Contact: Rick Kirchhoff)
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NASDA HONORS ROBERT MUNGARI
Published: February 18, 2008
New York State Department of Agriculture and Markets' Director of Plant Industry Robert Mungari was honored last week by NASDA for his outstanding service to agriculture.
Mungari, nominated by his peers at the Eastern Plant Board, was presented with NASDA's James A. Graham Award for Outstanding Service to Agriculture during NASDA's 2008 Midyear Meeting, February 11.
New York State Agriculture Commissioner Patrick Hooker said, "Over the course of 30 years, Bob Mungari has demonstrated tremendous leadership, become a catalyst for change, and set a standard for interagency cooperation at all levels. His efforts to eradicate the Asian Longhorned Beetle and detect the Sirex woodwasp, highlights his modern day approach to pest regulation, maximizing efficiencies while minimizing expenditures. I thank Bob for his dedicated efforts to safeguard our industry and congratulate him on this greatly deserved award."
Mungari started at the department in 1978 as a Horticulture Inspector. Since that time, he has also served as an agricultural entomologist, assistant director, acting director and now director, all within the department's Division of Plant Industry, which works to maintain plant health, promote integrated pest management practices, and preventing the spread of bee diseases. During that time, Mungari has strived to balance regulation with risk mitigation.
Among many other professional accomplishments, Mungari was effective in bringing the Cooperative Agricultural Pest Survey (CAPS) Program to the Department, adopting the program's early pest detection philosophy and targeted inspections. In doing so, he was also able to secure $400,000 in state funding for CAPS pest detection activities, which has helped in the detection of Southern Bacterial Wilt and the European Crane Fly in 2003, the Swede Midge in 2004, the European Woodwasp in 2005, and Plum Pox Virus in 2006. (Contact: Rick Kirchhoff)
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APHIS LIAISON TO NASDA APPOINTED
Published: February 18, 2008
At the NASDA Midyear meeting, Cindy Smith, administrator of the Animal and Plant Health Inspection Service (APHIS), announced that she had created a new position, located in the Intergovernmental Affairs staff of Legislative and Public Affairs (LPA). The primary purpose of this new position is to serve as the national coordinator and principal communication link between APHIS and state governments (e.g., NASDA member agencies) and national organizations (e.g., NASDA) on policy and technical matters to facilitate effective communications and harmonious relationships with these entities and ensure effective functioning of APHIS programs. In addition, the position will advise, consult, and coordinate with all APHIS program deputy administrators and staff, as well as existing intergovernmental affairs specialists in LPA and other program state liaisons, to establish and implement processes and a national plan for effectively communicating and working with State governments and National organizations. It i s envisioned that this position will work closely with the Animal & Plant Health Safeguarding Coordinator, a position that was created at NASDA as a part of a cooperative agreement between NASDA and APHIS.
Cindy also announced that Hallie Zimmers will serve as the interim state liaison for APHIS while the agency recruits to fill the position. Prior to being named the interim state liaison, Zimmers was LPA's assistant director of public affairs. In this role, she provided direction to APHIS' team of public affairs specialists, planned major press announcements, and developed and implemented national outreach strategies to ensure that the agency's messages were clearly communicated to the public on such high profile topics as biotechnology, bovine spongiform encephalopathy, and avian influenza. Before becoming assistant director in 2005, Zimmers spent two years as an intergovernmental affairs specialist in LPA where she was responsible for interfacing with congressional offices and communicating with stakeholders about all APHIS activities. Zimmers began her career with APHIS in 1999 as a public affairs specialist. Prior to joining APHIS, Zimmers worked as a reporter for The Journal Newspapers in Fairfax, Virginia.
Zimmers can be reached at Hallie.Zimmers@aphis.usda.gov or at 202/720-0378 or by using Bob Ehart, NASDA's animal & plant health safeguarding coordinator, as a conduit. (Contact: Bob Ehart)
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FARM BILL NEGOTIATIONS CONTINUE
Published: February 18, 2008
Congressional agriculture leaders and the Bush administration are continuing to hold intense negotiations on the 2007 farm bill. Lawmakers are working hard to reach a compromise and pass legislation before the current Farm Bill expires on March 15.
Both House and Senate Agriculture Committee chairmen have released new farm bill spending proposals in recent days. On February 13, House Agriculture Committee Chairman Collin Peterson (D-Minn.) and ranking member Bob Goodlatte (R-Va.) announced a farm bill spending framework that was offered to the Senate. The funding framework includes policy proposals that could reduce funding for the House-passed farm bill to a level that would be $6 billion over the baseline cost. It includes reforms sought by the administration and does not include any tax increases which have been cited by President Bush in his veto threats. The framework also authorizes farm bill programs fo ten years, instead of five.
Late February 15, Senate Agriculture Committee Chairman Tom Harkin (D-Iowa) made a counteroffer and proposed farm bill spending of $12.3 billion above the baseline over five years. Harkin released a statement saying that the spending level is critical for farmers and rural America, but also the nation as a whole.
The House and Senate proposals only outline budget numbers and do not spell out detailed policy changes. At press time, lawmakers were continuing negotiations. (Contact: Charlie Ingram)
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GLOBALIZATION DEMYSTIFIED AT 2008 U.S. FOOD EXPORT SHOWCASE
Published: February 18, 2008
Globalization will be thoroughly examined in numerous forums at the 2008 U.S. Food Export Showcase to help small and mid-size food manufacturers make sense of the brave new world--and exciting opportunities--unfolding before their eyes. The U.S. Food Export Showcase is part of the larger Global Food & Style Expo 2008 that takes place in McCormick Place, April 27 to 29, and caters to the massive demand for U.S. products around the world.
Kevin Coupe of the MorningNewsBeat.com will lend his unique brand of quick, concise, and slightly irreverent reporting to the Global Retailer Forum on April 28 focusing on up-to-the-minute industry trends from a global perspective. Coupe will take attendees on a multimedia world tour to examine leading retail trends and practices. In addition, Coupe will moderate a panel of industry experts who have a deep understanding of--and experience in--major markets in North America, Asia, and Europe. The panelists include Robert Neslund, former COO of Dairy Farm International, a pan-Asian retail group with over 2,200 outlets; Sharon Jeske, director of operational management programs at CIES--the Food Business Forum, the only independent global food business network; and Bobbi Goselin, senior vice-president, Daymon International, an international company specializing in the sales and marketing of private-label consumer products.
The Global Retail Forum general session promises to be insightful, lively, interactive, and a must-attend for decision-makers adapting to today's transnational business climate.
Attendees of the 2008 Global Food & Style Expo can choose from 35 concurrent workshop sessions focusing on different aspects of the international marketplace. In particular, workshops will provide a global perspective on such timely topics as health & wellness trends, food safety issues, and the growing emphasis on sustainability.
The U.S. Foreign Agricultural Service (FAS) is a full partner in the annual U.S. Food Export Showcase and FAS trade experts will be on hand to help exhibitors make the most of the opportunities the Showcase offers. In addition, renowned international business consultant, John Kauke of Global Market Linkage, will be available to provide individualized strategies to promote the buyer/seller relationship. A special International Trade Center located on the exhibit floor will provide even more services to help with language translation and trade questions.
"Adaptable entrepreneurs will be empowered by the information they receive at this year's Showcase," said Showcase Director DeWitt Ashby. "From multimedia presentations, panel discussions, workshops, and one-on-one consultations we cover globalization and what it means to countries, companies, and individuals."
The U.S. Food Export Showcase is sponsored by NASDA. This year's Showcase is co-located with two other organizations with growing global perspectives; the National Association for the Specialty Food Trade (NASFT) Fancy Food Show and the Organic Trade Association (OTA) All Things Organic show. All three shows will be presented under the umbrella of the Global Food & Style Expo 2008. For information on attending or exhibiting at the 2008 U.S. Food Export Showcase April 27 to 29 in Chicago, please contact NASDA at nasda@nasda.org. (Contact: DeWitt Ashby or Megan McDonald)
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COURT VALIDATES NEW YORK's POSITION ON CANADIAN MILK IMPORTS --Canadian Dairy Producers Group No Longer Allowed to Export Milk to U.S.
Published: February 18, 2008
New York State Agriculture Commissioner Patrick Hooker February 19 expressed his approval of a decision by the Canadian court system against BTU36094 Group, Ltd., a group of four Ontario dairy farmers who have been shipping milk into the United States. The court found this group to be operating outside of Ontario's mandatory quota system and granted a motion for an order restraining the group from marketing milk outside the system, including shipping milk to the United States.
"This long-awaited court decision brings hope to resolving the issue of imported Canadian milk in New York," Hooker said. "For at least five years now, there have been a number of dairy producers in Ontario who have defiantly shipped milk to the U.S. and I am pleased that the court's decision acts to put a stop to this situation."
Hooker wrote to Ontario Premier Dalton McGuinty and United States Trade Representative Susan Schwab last November to urge swift and appropriate enforcement against these dairies. The decision against BTU36094 directs the group of producers to abide by the quota system as the Commissioner requested in his letters. Based on the court's decision, Hooker is now requesting that the U.S. Trade Office take immediate action to ensure enforcement of the Canadian court ruling.
"The Canadian court has validated our concerns about the lack of quota enforcement in the Canadian dairy industry and I would expect our U.S. Trade Representative to require the Canadians to abide by the terms of this decision, NAFTA and previous WTO rulings," Hooker. "Even though BTU36094 has said it will comply with the court ruling and stop shipping milk into New York, I look to the Bush administration to make certain that the Canadian government complies with our trade agreements."
All Canadian dairy producers are required to participate in a milk supply management system (or quota system), based on a 2003 dispute settlement by the World Trade Organization in order to ensure fair trade between the United States and Canada. Up until now, BTU36094 Group, Ltd. has been operating outside of the required system, and for at least five years, has been permitted by the U.S. Food and Drug Administration to import milk into the U.S. under a Federal Import Milk Act Permit issued. (Contact: Jessica Chittenden, 518/457-3136)
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JOHNSTON COUNTY RESIDENT NAMED DIRECTOR OF NCDA&CS EMERGENCY PROGRAMS
Published: February 18, 2008
North Carolina Agriculture Commissioner Steve Troxler has appointed Sharron W. Stewart as director of the Emergency Programs Division at the N.C. Department of Agriculture and Consumer Services (NCDACS). She has assumed her duties.
Stewart previously was deputy director of the division. She replaces Marty Zaluski, who left the department last year to become Montana's state veterinarian.
The Emergency Programs Division is the department's chief emergency preparedness and response unit. Its work focuses on reducing the N.C. agricultural community's vulnerability to disasters, diseases and terrorist attacks. "Throughout her career, Sharron has demonstrated the ability to lead and get things done," Troxler said. "Her management skills and experience will be extremely beneficial in overseeing the Emergency Programs Division, which is responsible for providing coordinated planning, response and recovery efforts for agricultural disasters."
Stewart joined the department in 1981, working briefly with the Plant Industry Division before becoming an inspector with the pesticide regulatory programs. She left the department in 1988 to run a private business, but returned in 1991 and held several positions in pesticide regulation before becoming deputy director of emergency programs in 2005.
Trained extensively in incident management and command, Stewart was on a team that ran a shelter for displaced animals along the Gulf Coast following Hurricane Katrina in 2005. She also has served as commander of NCDA&CS drought and hay relief efforts.
Stewart is a graduate of N.C. State University and holds the Certificate for Community Preparedness and Disaster Response from the University of North Carolina at Chapel Hill. She is a member of the American Academy of Certified Public Managers, the N.C. Society of Public Managers and the State Animal Response Team.
She is married to Charles K. Stewart. Her hobbies include horses, dogs and reading. (Contact: Brian Long, 919/733-4216)
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