Ms. Abigail Kimbell, Chief
USDA Forest Service
Office of the Chief (4NW Yates)
201 14th Street, SW
Washington, DC 20250

Ms. Teresa Lasseter, Administrator
Farm Service Agency
1400 Independence Ave, SW
STOP 0506
Washington, DC 20250

Mr. Arlen Lancaster, Chief
Natural Resources Conservation Service
14th & Independence Avenue, SW
Room 5105-A
Washington, DC 20250

Dear Chief Kimbell, Chief Lancaster and Administrator Lasseter,

On behalf of the National Association of State Foresters (NASF) I wish to express our appreciation for your leadership and guidance in development of the 2008 Farm Bill as recently passed by Congress. The spirit of interagency collaboration and willingness to engage organizational interests such as NASF contributed to meaningful content and enthusiasm for continued partnerships to implement the forestry provisions contained in the bill.

As we work together to develop policies and procedures for new programs as well as strategies to improve implementation of current programs, NASF respectfully requests your attention to the following issues and suggestions:

• NASF encourages interagency collaboration throughout the upcoming rulemaking process to promote the best levels of communication and collective direction. As you are aware, various aspects of forest policy reside among your agencies and require close coordination to ensure program success and efficiency. NASF would suggest careful consideration and dialogue on those shared responsibilities, particularly on those programs of consequence to State and Private Forestry and the Cooperative Forestry Assistance Act.
• While acknowledging agency responsibilities for developing rules and administrative guidance, NASF requests the opportunity to be engaged in formative discussions of those rules. The linkage with state forestry agencies is significant where program services apply to non-industrial forest landowners and related organizations. The rulemaking process is a timely opportunity to ensure meaningful connection with the operational and delivery capabilities of the States.

• Certain forestry programs authorized by the Farm Bill are more time-sensitive than others as a matter of preparedness. It is important to expeditiously address those procedures of the Emergency Forest Restoration program (Title VIII-Section 8203) as may be necessary to successfully prepare for disasters that could occur within the continued and projected wildfire and hurricane seasons. Similarly, the Pest and Disease Revolving Loan Fund (Title X- Section 10205) should receive priority consideration as state and local governments organize to contain and prevent the spread of insects and disease such as Emerald Ash Borer, Sudden Oak Death, Sirex Woodwasp and the Asian Longhorned Beetle.

• The Farm Bill also authorizes the establishment of the Forest Resource Coordinating Committee (Title VIII, Section 8005) to provide guidance on National Priorities including development of a competitive process for Cooperative Forestry Assistance program funding. Committee responsibilities are linked to the preparation of Statewide Forest Assessments and Strategies that must be completed by June of 2010. Prompt attention to the organization and appointment of committee members is important to provide timely direction and meet statutory deadlines. NASF would welcome an opportunity to provide input on committee organization including recommendations on the respective State Forester appointments.

State forestry agencies are well positioned to effectively meet the requirements in Title VIII, Section 8005 due to the alignment of these requirements with the ongoing State and Private Forestry Redesign effort. 

NASF appreciates the opportunity to be a partner with USDA in the development and implementation of programs directed at the sustainable management of non-industrial private forestlands. We look forward to continued collaboration in crafting rules and administrative guidance for the 2008 Farm Bill.

Sincerely,

Kirk Rowdabaugh, President
National Association of State Foresters