NASDA News - September 15, 2009

September 15, 2009

NASDA ANNUAL MEETING PREVIEW:

Administration officials & policy experts to address NASDA meeting *** Policy committees plan active agendas

LEGISLATIVE AND REGULATORY NEWS:

Department of Labor proposes sweeping changes to H-2A program *** US DOT Inspector General reports on Mexican trucking *** Lincoln takes top spot on ag committee  *** US announces tariff on Chinese tires, china plans to retaliate on poultry *** Senate confirms controversial Sunstein for key regulatory post *** Exports of U.S. goods and services drop over ’08 levels *** EPA to clamp down on Chesapeake pollution *** USDA announces hearings on proposed leafy greens agreement *** USDA continues implementation of Farm Bill disaster programs

STATE NEWS:

KY: Commissioner Farmer encourages agritourism month *** CO: Grant program returns for agricultural renewable energy proposals *** MD: Program Brings fresh food to public schools *** WI: Pesticide clean sweep events announced *** MI: Plum Pox Virus quarantine lifted *** WA: Washington seeks Commodity Inspection Division Assistant Director *** SD: Department of Agriculture seeks Director of Ag Development ***



  • NASDA ANNUAL MEETING PREVIEW
    Published: September 15, 2009

    ADMINISTRATION OFFICIALS & POLICY EXPERTS TO ADDRESS NASDA MEETING

    NASDA members will have the opportunity to meet and hear from administration officials and policy experts during their upcoming Annual Meeting being held September 16-21 in Montgomery, Alabama.

    USDA Deputy Secretary Kathleen Merrigan will address the plenary session on September 18 to discuss the Administration’s goals and priorities for agriculture.  Other featured speakers include Monty Bain, Southeast Regional Cotton Board; Berrye Worsham, President and CEO of Cotton Incorporated; and Jerry Steiner, Executive Vice President, Sustainability & Corporate  Affairs, Monsanto.  Former President of Mexico Vicente Fox has been invited as the keynote speaker during the September 18 luncheon.

    POLICY COMMITTEES PLAN ACTIVE AGENDAS

    NASDA’s policy committees and task forces are planning to address key topics on food safety, renewable energy, environmental regulations, specialty crops, rural development, and other issues when state agriculture leaders hold their annual meeting this week.

    The Food Regulation and Nutrition Committee, chaired by North Carolina Agriculture Commissioner Steve Troxler, will meet with officials from the Food and Drug Administration (FDA) on September 19. The committee plans to discuss a number of issues including food safety, interstate meat shipment, and nutrition programs.

    The Marketing and International Trade Committee, chaired by Florida Agriculture Commissioner Charles Bronson, will meet on September 19. USDA’s Associate Administrator for Foreign Agriculture Service (FAS) will offer an update on the US trade agenda, focusing on the expectations for free trade agreements. Patrick Ford of Ford’s Gourmet Foods will discuss the benefits of the MAP branded program. Members will also be updated on the Mexican trucking situation.

    The Animal and Plant Industries Committee meeting will be chaired by Nebraska Commissioner Greg Ibach and Vice-Chair of the committee Dr. Lester Spell, Mississippi Agriculture Commissioner. It meets on September 20, with much of the agenda focusing on APHIS issues. Cindy Smith, APHIS Administrator, will be on hand to provide key priorities and issues of interest. Dr. John Clifford will discuss Vision 2015 and its relationship to existing animal diseases and national traceability. Bill Hawks of AgWorks Solutions will be on hand to discuss a new irradiation facility in Gulfport, MS.

    NASDA’s Natural Resources and Pesticide Management Committee will address regulatory and legislative issues dealing with NPDES permits for pesticide applications, rangeland management, and methyl bromide. Utah Agriculture Commissioner Leonard Blackham is Chairman of the panel and Iowa Agriculture Secretary Bill Northey serves as Vice Chairman.

    The Rural Development and Financial Security Committee, led by Oklahoma Agriculture Commissioner Terry Peach, anticipates an active agenda.  Opening the discussion will be USDA Deputy Undersecretary of Farm and Foreign Agriculture Services (FSAS) Michael Scuse, a former NASDA vice president and Delaware Secretary of Agriculture.  To continue the critical discussion, Chris Beyerhelm and Brandon Willis, both of the Farm Service Agency, will provide details on economic issues facing farmers and producers.  Beyerhelm will focus on the current credit situation in rural America, while Willis will pay particular attention to the 2008 Farm Bill disaster programs, which are now in the process of implementation.  Following the USDA speakers, Commissioner Leonard Blackham of Utah will present the recently-established working group’s “Meat the Need” proposal to address the crisis in our nation’s protein sectors.

    The Energy Task Force will be conducting its inaugural meeting to address critical energy-related issues currently facing agriculture.  Former NASDA President Nathan Rudgers, currently serving on the 25x’25 steering committee, will speak on a multitude of issues, including climate change legislation, renewable fuels regulations, and other energy concerns on the farm and for rural America.  The Task Force is led by Minnesota Department of Agriculture Commissioner Gene Hugoson.     

    The Biotechnology Task Force will hear an update from Michael Gregoire, Deputy Administrator of APHIS, on current issues at Biotechnology Regulatory Services. The task force will also focus on animal biotechnology.

    On September 18 the Tobacco Task Force will convene with a legislative update from Chairman Troxler.  The task force will also review current policy items and discuss concerns regarding leaf moisture testing. 

    The Specialty Crops Task Force, chaired by California Agriculture Secretary A.G. Kawamura, will meet with Ms. Trista Etzig, project manager for USDA’s Agriculture Marketing Service (AMS) Fruit and Vegetable program.  She will provide an update on the Specialty Crops Block Grant Program. (Contact: Bob Ehart, Amy Mann, Nathan Bowen, or David Hickey)

     


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  • DEPARTMENT OF LABOR PROPOSES SWEEPING CHANGES TO H-2A PROGRAM
    Published: September 15, 2009

    The Labor Department has announced new proposed rules for the nation’s agricultural guest worker program, which would reverse many of the Bush Administration’s changes and would substantially alter the H-2A program in many respects.  The proposal would amend the rules governing the certification of temporary employment of nonimmigrant workers in temporary or seasonal agricultural employment and the enforcement of the contractual obligations applicable to employers of such nonimmigrant workers. 

    The changes continue a long line of confusing regulatory actions affecting the H-2A program.  In 2008, the Bush Administration announced significant changes to the program.  Those changes went into effect in December 2008 but were suspended by the Obama Administration when it came into power in January 2009.  In May, 2009, the Obama Administration finalized a rule suspending the 2008 rules but the suspension was enjoined by court order in June.  Understandably, for the past ten months there has been a good deal of confusion over which rules govern the program. 

    The 61-page proposed rule can be found online.  Comments are due by October 5, 2009.  (Contact: Amy Mann)


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  • FSIS PROPOSES RULES FOR INTERSTATE MEAT SHIPMENT
    Published: September 15, 2009

    USDA's Food Safety and Inspection Service (FSIS) tomorrow will publish proposed regulations to implement a new voluntary cooperative program under which select State-inspected establishments will be eligible to ship meat and poultry products in interstate commerce. The new program was created in the 2008 Farm Bill to supplement the existing Federal-State cooperative inspection program to allow State-inspected plants with 25 or fewer employees to ship products across State lines. This announcement is part of the USDA's new 'Know Your Farmer, Know Your Food' initiative, which seeks to better connect consumers with local producers to help develop local and regional food systems to spur economic opportunity.

    Currently, 27 states operate State meat or poultry inspection programs, and FSIS verifies that the State programs are implementing requirements that are "at least equal to" those imposed under the Federal meat and poultry products inspection acts. For these programs, FSIS provides up to 50 percent of the State's operating funds and provides oversight and enforcement of the program.

    Under the proposed rule, which went on display at the Office of the Federal Register Monday and will be published this Wednesday, selected establishments will receive inspection services from federally trained and/or supervised State inspection personnel who will verify that the establishments meet all Federal food safety requirements. Meat and poultry products produced under the voluntary cooperative program will bear an official USDA mark of inspection, thereby enabling interstate shipment of the products.

    State-inspected establishments that are not selected for the voluntary cooperative program, including state-inspected establishments with more than 25 employees, are only eligible to sell and ship their products within their State.

    Comments must be received on or before Monday, November 16, 2009, through the Federal eRulemaking Portal at www.regulations.gov , by mail to: FSIS Docket Room, USDA, FSIS, OPPD, Docket Clearance Unit, 5601 Sunnyside Avenue, Stop 5272, Beltsville, MD 20705. All comments must identify FSIS and the docket number FSIS-2008-0027. Comments will be available for viewing online(Contact: Bob Ehart)


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  • US DOT Inspector General reports on Mexican trucking
    Published: September 15, 2009

    On September 2, the U.S. Transportation Department’s inspector general issued its report to Congress stating that the department still needs more information to determine if Mexican trucks are safe enough to enter this country.   The report, prepared by department auditors, says that some states don’t adequately report the nationality of people convicted of traffic violations, and that some buses aren’t inspected sufficiently when they cross the border. 

    While the Federal Motor Carrier Safety Administration concurs with the report’s recommendations, it is important to note the Agency’s vigorous defense of its ability to inspect drivers’ license at the border and its findings regarding the safety of Mexican-domiciled trucks.  With regard to the bus/motor coach inspections, the agency points out the ports of entry are not properly designed for such inspections.  A copy of the report, which includes the FMCSA’s response, can be found online(Contact: Amy Mann)


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  • LINCOLN TAKES TOP SPOT ON AG COMMITTEE
    Published: September 15, 2009

    Sen. Blanche Lincoln (D-AR), a moderate southern Democrat and rice farmer’s daughter from Arkansas, took her place as chair of the Senate Agriculture, Nutrition, and Forestry Committee this week.  Lincoln takes over the agriculture committee following the departure of the former chairman, Sen. Tom Harkin, who moved to chair the Senate Health, Education, Labor, and Pensions Committee (HELP).  In the committee’s 184-year history, Lincoln will be the first Arkansan and first female ever to serve as chairman. 

    In this new role Lincoln will bring a different perspective to the committee on a number of issues, particularly on climate change legislation and on commodity payment limits. 

    Congressional observers have closely watched a number of moderate Democrats—including Lincoln—during debate on cap and trade legislation this year.  Lincoln has advocated a go-slow approach to climate change legislation, indicating that she does not believe the Senate should act on the issue this year.  As the agriculture committee is one of several Senate committees with at least partial jurisdiction over a cap and trade legislation, Lincoln will now have a bigger role in that debate.   

    Lincoln, along with a number of other farm state Senators from the South, has also resisted efforts to further limit commodity payments.  The Obama administration earlier this year proposed to trim commodity payments as a way to reduce federal spending.

    Also this week, Lincoln announced that Robert Holifield will serve as the committee’s Staff Director.  Holifield is the former Deputy Chief of Staff at the Commodity Futures Trading Commission and served as Lincoln’s senior agriculture policy advisor from 2000 to 2007.

    After the death of former Senator Ted Kennedy, Senator Chris Dodd considered taking over as chairman of the health committee, deciding instead to stay at the helm of the banking committee.  In comments last week, Harkin left open the possibility that Dodd would take over the health committee next Congress, while Harkin would resume his previous position as chair for the agriculture committee.  (By: Preston Asay, Policy Contact: Nathan Bowen)


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  • US ANNOUNCES TARIFF ON CHINESE TIRES, CHINA PLANS TO RETALIATE ON POULTRY
    Published: September 15, 2009

    President Obama announced Friday that imports of Chinese tires will soon be subject to a 35 percent tariff.  The tariff is in response to a surge of Chinese tires into the U.S. that caused a major decline in the domestic tire industry, ultimately resulting in the closing of several tire plants and the loss of thousands of American jobs.  After a year the tariff will be reduced to 30 percent, then 25 percent in the third year. 

    As a countermeasure to the U.S. action, China has said it will investigate whether the U.S. has disrupted Chinese markets by importing automotive and poultry products at prices below cost, a practice known as dumping.  If China determines that the U.S. has dupmed products into the Chinese market they plan to levy tariffs on U.S. imports to offset the damage.  (By: Ethan Mathews, Policy Contact: Amy Mann)


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  • SENATE CONFIRMS CONTROVERSIAL SUNSTEIN FOR KEY REGULATORY POST
    Published: September 15, 2009

    Dr. Cass Sunstein, a Harvard professor, was confirmed last week by the Senate to serve as the Administrator of the Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget.   Sunstein had come under fire from Senate Republicans, as well as agriculture organizations, for his views on animal rights.  Opponents of Sunstein cited previous writings that suggest animals should have the right to sue their owners in court.  A number of environmental groups expressed concerns with Sunstein’s nomination as well over his support for utilizing cost-benefit analysis in the regulatory process.

    The Senate voted 57-40 to confirm Sunstein, with incoming Senate Agriculture Chairman Blanche Lincoln joining five other Democrats voting against his confirmation.  (By: Preston Asay, Policy Contact: Nathan Bowen)


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  • EXPORTS OF U.S. GOODS AND SERVICES DROP OVER ’08 LEVELS
    Published: September 15, 2009

    The Department of Commerce recently released its July Report of US International Trade in Goods and Services.  Through the first seven months of 2009 (January – July), U.S. goods and services exports totaled $867.6 billion, a 20.3 percent decline through the same period of 2008. Comparatively, U.S. goods and service imports fell faster than exports, with imports declining 29.2 percent through the first seven months of 2009 (when compared to the year earlier period). 

    When compared to June 2009, U.S. exports of goods and services increased by 2.2 percent in July 2009 to $127.6 billion and imports increased 4.7 percent to $159.6 billion.  Over the same period, the U.S. goods and services trade deficit increased by 16.3 percent to $32.0 billion when compared to June 2009. The largest export markets for U.S. goods year-to-date through July 2009 were Canada ($112.6 billion), Mexico ($69.8 billion), China ($35.7 billion), Japan ($28.9 billion), and the United Kingdom ($26.7 billion).

    In a statement following the report’s release, United States Trade Representative Ron Kirk said: "The United States has seen three consecutive months of export growth and two consecutive months of import growth. This is consistent with a global economy that is getting back on track. It is critical that we continue to increase exports of American goods and services to the world, which would help create more jobs for the American people. At the WTO ministerial meeting last week in India, I reaffirmed the commitment by the United States to reach a successful conclusion of the Doha Development Agenda. Additionally, under the leadership of President Obama, USTR will continue our work to open new markets throughout the globe for American businesses and to step up trade enforcement to ensure our trading partners play by the rules and promote fair, rules-based competition in the U.S. market." The report can be found online(Contact: Amy Mann)


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  • EPA TO CLAMP DOWN ON CHESAPEAKE POLLUTION
    Published: September 15, 2009

    In the wake of President Obama’s executive order calling on federal agencies to protect the Chesapeake Bay, the Environmental Protection Agency (EPA) has announced its intention to more strictly enforce rules on farmers surrounding the bay.  This is the fourth time the agency has made promises to clean up the area since the mid 1980’s.  In hopes of achieving a different outcome, EPA will aim its efforts at state-level officials, giving them two years to devise plans to reduce pollution levels by a predetermined amount.  If the EPA determines that the state’s plans are insufficient, states risk losing federal grant money or being denied permits necessary for new developments such as subdivisions, retail outlets and sewage plants.  States affected by the new regulation include Virginia, West Virginia, Pennsylvania, New York, Delaware and the District of Columbia. 

    Sen. Benjamin L. Cardin (D-MD) has recently introduced legislation giving the federal government the ability to incentivize farmers to lessen their impact on the water system, allowing them to sell credits for reducing pollution levels below their allotted amount.  (By: Ethan Mathews, Policy Contact: Nathan Bowen)


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  • USDA ANNOUNCES HEARINGS ON PROPOSED LEAFY GREENS AGREEMENT
    Published: September 15, 2009

    The Agriculture Marketing Service (AMS) has announced a series of public hearings to consider a proposed marketing agreement under the Agricultural Marketing Agreement Act of 1937 to cover the handling of leafy green vegetables and products in the United States. The proposal was submitted by a cross-section of producer and handler representatives from the fresh produce industry and would authorize the development and implementation of production and handling regulations (metrics). Such metrics would reflect Good Agricultural Practices, Good Handling Practices, and Good Manufacturing Practices and would be voluntary in that only handlers who sign the marketing agreement would be subject to the requirements of the marketing agreement. Signatory handlers could only handle leafy green vegetables or product from the production area or imported that meets the requirements of the program.

    The hearing dates are:  September 22 through 24, 2009, Monterey, California; September 30 through October 1, 2009, Jacksonville, Florida; October 6, 2009, Columbus, Ohio; October 8, 2009, Denver, Colorado; October 14 and 15, 2009, Yuma, Arizona; October 20, 2009, in Syracuse, New York; October 22, 2009, in Charlotte, North Carolina. 

    More information, including the hearing locations and AMS contact information can be found in the Federal Register notice. (Contact: Amy Mann)


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  • USDA CONTINUES IMPLEMENTATION OF FARM BILL DISASTER PROGRAMS
    Published: September 15, 2009

    Producers may now begin applying for the Emergency Assistance for Livestock, Honeybees, and Farm-Raised Fish Program (ELAP) and the Livestock Forage Disaster Program (LFP), permanent disaster programs established in the 2008 Farm Bill.  These programs, along with the Livestock Indemnity Program and the Supplemental Revenue Assistance Program (SURE), will serve as a replacement to the standard practice of ad hoc disaster assistance.

    LFP, which provides payments for livestock grazing losses due to drought or fire, is eligible for livestock producers of beef cattle, alpacas, buffalo, beefalo, dairy cattle, deer, elk, emus, equine, goats, llamas, poultry, reindeer, sheep and swine.  ELAP is an emergency assistance program for certain losses not covered by the other disaster programs established by the 2008 Farm Bill.  Available to eligible producers of livestock, honeybees and farm-raised fish, ELAP is for losses due to disease, adverse weather or other conditions. 

    Producers seeking to use either program must have suffered losses that occurred on or after January 1, 2008, and October 1, 2011.  For more information on these USDA disaster programs, including new payment limitation restrictions beginning for the 2009 crop year, please visit your Farm Service Agency county office or www.fsa.usda.gov .  (Contact: David Hickey)


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  • KY: COMMISSIONER FARMER ENCOURAGES AGRITOURISM MONTH
    Published: September 15, 2009

    Agriculture Commissioner Richie Farmer encourages all Kentuckians to check out one of the Commonwealth’s more than 300 farm destinations during Kentucky Agritourism Month in September.

    “A trip to the farm gives people a chance to treat their families to clean, wholesome fun,” Commissioner Farmer said. “It enables people to revisit Kentucky’s agricultural roots. And it helps farmers make a living.”

    Travelers can find farm destinations where they can pick pumpkins, go on a trail ride, sample some of Kentucky’s award-winning wines, buy farm-fresh produce at a farmers’ market, and take part in a vast array of other activities. Agritourism generated some $3.2 million in income for Kentucky farms in 2007, according to the most recent Census of Agriculture.

    To find out more, go to www.kentuckyfarmsarefun.com. (Contact: Bill Clary, (502) 564-1137)


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  • CO: GRANT PROGRAM RETURNS FOR AGRICULTURAL RENEWABLE ENERGY PROPOSALS
    Published: September 15, 2009

    The Colorado Agricultural Value Added Development Board is offering $500,000 in grant funding to promote agricultural energy related projects in Colorado.

    The Board administers the Advancing Colorado’s Renewable Energy (ACRE) program which has provided funds over the past three years to promote energy-related projects beneficial to Colorado’s agriculture industry such as micro-hydro, small-wind, solar, biomass and biofuel projects.  For more information or an application and guidelines, visit: www.colorado.gov/ag/energy(Contact: Christi Lightcap, (303) 239-4190, Christi.lightcap@ag.state.co.us)


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  • MD: PROGRAM BRINGS FRESH FOOD TO PUBLIC SCHOOLS
    Published: September 15, 2009

    School lunches are getting a makeover this fall with more interesting and more nutritious foods.  School children in hundreds of public schools across Maryland will get a taste of fresh, Maryland-grown and produced food in their lunches during the second annual Maryland Homegrown School Lunch Week, September 14-18.

    A kick-off celebration is planned with special classroom educational activities and local lunch with students, farmers, and federal, state and local officials The Homegrown School Lunch Week, an element of the Jane Lawton Farm to School Program, was created during the 2008 Session of the Maryland General Assembly when SB 158 Farm-to-School Program was signed into law by Governor Martin O’Malley. The program is designed to help educate students about where their food comes from, how it is produced, and the benefits of a healthy diet as well as to expand markets for Maryland farmers.

    More information: www.marylandfarmtoschool.org (Contact: Sue duPont, MDA, 410-841-5889; Julie Oberg, MDA, 410-841-5888 or Bill Reinhard, MSDE, 410-767-0486)


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  • WI: PESTICIDE CLEAN SWEEP EVENTS ANNOUNCED
    Published: September 15, 2009

    Homeowners, farmers, rural property owners, and businesses in 43 counties, two cities and five tribal nations will have access to disposal services for hundreds of chemicals this fall. Wisconsin Clean Sweep is open to urban homeowners and renters, farmers and rural residents as a way to dispose of unwanted chemicals, pesticides or hazardous waste.

    collection participants bring lead paint, solvents, pipeline cleaners from dairy farms, old pesticides that are no longer on the market like DDT and newer products like Round-up. Businesses will also find better access to lower cost disposal services through Wisconsin Clean Sweep. Since the Clean Sweep program began in 1990 with the focus on collecting agricultural chemicals, the program has expanded to include household hazardous waste as well.  The program has collected more than five million pounds of unwanted chemicals, pesticides and hazardous waste.

    For information on Wisconsin Clean Sweep, contact Roger Springman, 608-224-4545 or by e-mail roger.springman@datcp.state.wi.us. (Contact: Jane H. Larson, (608) 224-5005 or by email Jane.Larson@Wisconsin.gov. )


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  • MI: PLUM POX VIRUS QUARANTINE LIFTED
    Published: September 15, 2009

    Michigan Department of Agriculture (MDA) Director Don Koivisto announced September 14 the successful eradication of Plum Pox Virus (PPV) in Michigan.  Effective immediately, MDA also lifted the PPV quarantine, which has been in effect since June 2007.

    The quarantine was implemented after MDA inspectors detected PPV in Berrien County during routine disease survey activities. PPV is an exotic disease of stone fruit, which up until July 2006, was previously unknown in Michigan. This disease poses no human or animal health or food safety threat.

    “This is a tremendous success story where MDA’s early detection and rapid response mitigated tremendous economic losses for producers and the state and prevented widespread losses throughout the stone fruit industry assuring continued production of these valuable crops,” said Koivisto. In cooperation with Michigan’s fruit producers, the United States Department of Agriculture (USDA) and Michigan State University (MSU), MDA conducted comprehensive sampling to ensure the virus had been eradicated from the state.

    Additional information about PPV is available on the MDA Web site at  www.michigan.gov/mda. (Contact: Jennifer Holton, 517-241-2485 or holtonj@michigan.gov)


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  • WA: WASHINGTON SEEKS COMMODITY INSPECTION DIVISION ASSISTANT DIRECTOR
    Published: September 15, 2009

    The Washington State Department of Agriculture (WSDA) is seeking an experienced leader and manager to serve as the Assistant Director of their Commodity Inspection Division.  This full-time exempt position is located in the Natural Resources Building in Olympia, Washington. 

    This Assistant Director provides leadership and oversight for programs that support agriculture, protect the consumer and work in partnership with agricultural and consumer groups, and state, local and federal officials to ensure public safety.  This position is a member of the agency Executive Leadership Team (ELT) and is accountable to the Director and Deputy Director, reporting to the Deputy Director.

    The Assistant Director works in close partnership with the Director and the members of the executive leadership team in formulating and executing the strategic goals of the agency.  This position supervises five direct reports, and a division of approximately 220 permanent staff and is responsible for managing a yearly operating budget of $23,000,000.

    For more information or to view the job announcement, visit http://agr.wa.gov/Employment/.


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  • SD: Department of Agriculture seeks Director of Ag Development
    Published: September 15, 2009

    The South Dakota Department of Agriculture is now seeking applicants for Director of Agricultural Development.  The position is located in Pierre, SD and while salary depends on experience, the initial pay range is $60,000 to $70,000 annually.

    Position Purpose:  To work with businesses, banks, government organizations, local agricultural development groups, educational institutions, and citizens to maximize and leverage public-private sector partnerships to generate new ideas, to develop new agricultural opportunities to strengthen existing agricultural opportunities and to encourage additional investment in South Dakota Agriculture. Supervise and oversee the activities of the division which include: Agriculture Loan and Finance Programs, Farm Loan Mediation and Agriculture Finance Counseling Programs, Livestock Development Programs, Dairy Development Programs, Value-added/Crop Marketing Programs.  For more information, or to apply, visit http://bop.sd.gov/workforus/.


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