May 18, 2004

Mr. Joel Holtrop
Deputy Chief, State and Private Forestry
USDA Forest Service
Washington, D.C. 20090-6090

Dear Joel:

The National Association of State Foresters (NASF) is writing to clarify our position on the allocation formula for the Urban and Community Forestry Program developed by the USDA Forest Service. We have worked long and hard to reach agreement within our organization and with the Forest Service on a new formula that meets Congressional intent while enabling every state to address the needs of their communities for urban and community forestry. We recognize some inadequacies exist in the current formula; however, we believe it goes a long way in meeting Congressional intent to deliver funds based on population. For example, 66 percent of UCF program funds in 2003 went to the 25 most populated states, serving 82 percent of the nation's population.

The NASF Executive Committee directed the NASF Urban and Community Forestry (UCF) Committee to work closely with the Forest Service to develop a revised formula. The UCF Committee and the NASF spent many long hours on this project, making this effort a high priority. The NASF values the close working relationship the UCF Committee established with the Forest Service throughout this process and appreciates the extensive work of the UCF Committee and the Forest Service staff. The UCF Committee made a recommendation to the NASF Executive Committee to support Option C. The NASF Executive Committee was unable to come to agreement on an allocation formula.

The most serious concern to NASF is that the reallocation of UCF funding will threaten to leave less populated states without a viable UCF program. This will erode the states' capabilities to continue to deliver needed technical and financial assistance to communities of all sizes. NASF holds the UCF program as a cornerstone program in the delivery of forestry assistance to communities nationally, to the extent that every community has access to technical and financial assistance.

If a new allocation formula is to be implemented, NASF will request that Congress fund the UCF program at a level which allows member states to continue to deliver their UCF program at a minimum funding level equal to the FY 2003 state allocations. In the meantime, NASF supports the continuation of the current eight-factor allocation formula to NASF regions. Our request reflects the conviction and obligation of the state foresters that a quality program be available to all communities.

Fundamentally, we believe that the formula you will be sending to Congress will ultimately disadvantage many states, to the point of reducing funding below the threshold necessary for some to have a viable urban and community forestry program. Based upon our experience, this threshold is $200,000 per state.

We are committed that every community regardless of size should be able to participate in the UCF program.

Sincerely,
Burnell C. Fischer
President

Cc: Steve Scott, Chairman, NASF Urban & Community Forestry Committee