News Releases

DATE:	December 13, 2004
CONTACT:	Leslie Cahill
	(703) 837-8140

ASTA Comments on Federal Register Notice, August 10, 2004
Volume 69, Number 153

December 8, 2004

Director
Conservation and Environment Programs Division (CEPD)
Farm Service Agency
Room 4714-S, Stop 0513
1400 Independence Avenue, S.W.
Washington, DC 20250-0513

By email: crprule.crprule@wdc.usda.gov

RE: Federal Register Notice, August 10, 2004
Volume 69, Number 153

Dear Director:

Founded in 1883, ASTA is one of the oldest trade organizations in the United States. Its membership consists of over 840 companies involved in seed production and distribution, plant breeding, and related industries in North America. As an authority on plant germplasm, ASTA advocates science and policy issues of industry importance to the seed industry. Its mission is to enhance the development and free movement of quality seed worldwide.

ASTA and its members support the Conservation Reserve Program (CRP) and are committed to providing appropriate conservation seed to meet the CRP’s objectives of supporting wildlife and reducing soil erosion. The availability of quality, appropriate seed is a key success factor for the CRP. Applauding the Department’s commitment to full enrollment up to the authorized level of 39.2 million acres and recognizing that more than 28.7 million acres will expire between September 30, 2007 and 2010, ASTA agrees there is a management challenge concerning CRP objectives; USDA staffing needs and technical service provider resources. We offer comments on the questions of program management and delivery and program administration raised in Federal Register Notice, Volume 69, and Number 153.

Program Management and Delivery

There are a number of steps that ASTA recommends with respect to program management. The first is to involve stakeholders, including the seed industry on an ongoing basis. For the seed industry, this includes greater representation on NRCS technical committees; input from the seed industry on the optimum mix of seeds to use for specific program objectives following the principles in “The Use of Local Native Seed – Position Statement From The American Seed Trade Association” which is attached; and a greater emphasis on planning and notification of expected needs.

In regard to planning and notification, we note that in the past some sign-up notifications have been short and sometimes delayed. We believe that ongoing discussions between the seed industry and the Department that provide greater lead time for procuring the right mix and quantity of seed would result in significant savings for the taxpayers and increase the effectiveness of the program. Specifically, we believe that announcements made at least six months or more in advance would result in a more consistent availability of the proper mix of seed for the CRP. In order to smooth out expected surges in sign-up, we recommend that CRP participants whose contracts expire in 2007 and 2008 be offered an early opportunity to re-bid their acres.

ASTA believes that the overall goal of the CRP should be to provide enduring, stable groundcover comprised of appropriate grasses, forbs and legumes that are beneficial for erosion control, water quality, and wildlife as well as being a source for emergency forage needs. The best quality seed available should always be used. We strongly recommend the use of NRCS ecological site-guides when selecting plant materials.

Program Administration

With regard to program administration, the first priority should be consistency. Bid processes should be the same among all locations. The use of the EBI should not vary among locations, and the selection process should always be consistent with program objectives. The seed selection process should take into account science, economics, market availability and suitability. ASTA believes that the seed industry can and should continue to provide expertise and support to the Department and producers in the seed selection process. Such industry input would help ensure the selection of the most appropriate seed types and reinforce best management practices.

ASTA encourages the Department to seek the funds needed form Congress for the staffing needed to manage the program. When technical service providers are used, as ASTA stated in previous comments to the Department, there should be clear provisions to preclude conflicts of interest that could add to the cost of the program.

Training of all people involved in the delivery of the program, including technical service providers will be important to effective and efficient program administration and delivery. ASTA members are willing to work with the Department to provide training on seed related issues. At the same time, ASTA encourages the Department to draw on the resources and expertise of the National Plant Materials Centers from which many products have been developed.

Finally, ASTA endorses the development of new information technologies to improve program administration and delivery.

Thank you for the opportunity to provide input on the CRP program. Please contact us if you have questions or if we can provide additional information.

Sincerely,



LESLIE CAHILL
Vice President, Government Affairs


Attachment
“The Use of Local Native Seed
Position Statement from the
American Seed Trade Association”

###

Founded in 1883, the American Seed Trade Association (ASTA), located in Washington, DC, is one of the oldest trade organizations in the United States. Its membership consists of about 900 companies involved in seed production and distribution, plant breeding, and related industries in North America. As an authority on plant germplasm, ASTA advocates science and policy issues of industry importance. Its mission is to enhance the development and free movement of quality seed worldwide.