News Releases

DATE:	July 8, 2003
CONTACT:	Leslie Cahill
	(703) 837-8140

Farm Bill – Conservation Reserve Program – Long Term Policy

Mr. Matt Ponish
Mangi Environmental Group
7915 Jones Branch Drive
Suite 2300
McLean, Virginia 22102


RE: 7CFR Part 1410 – Interim Rule 2002 Farm Bill – Conservation Reserve Program – Long Term Policy

Dear Mr. Ponish:

The American Seed Trade Association (ASTA) is pleased to offer comment to the above referenced notice. ASTA is the leading national trade association charged with representing the interests and concerns of 800 seed companies, a number of which provide support and products for conservation activities, reclamation projects and forage and pasture uses. ASTA is in a unique position to offer perspective and guidance to the U.S. Department of Agriculture (USDA) to help producers meet their objectives and to develop an appropriate conservation plan that would set forth terms and conditions of enrolling acreage in the Conservation Reserve Program, update program eligibility requirements, eliminate unnecessary regulations and improve the remaining regulations. ASTA strongly supports the CRP program and its members work hard to support farmers and ranchers interested in participating in the program. This is accomplished by providing advice and the highest quality of seed.

ASTA strongly supports the notion that native seed and vegetation species that are suited to the soil and climatic conditions of a site provide high wildlife benefits. ASTA concurs with the Farm Service Agency that the use of native vegetation is a practical objective and provides great benefits to habitats. ASTA does, however, note that in some cases where environmental conditions prohibit or severely impede the use of natives, or where the management objectives justify it, the use of introduced vegetation species may be appropriate.

These species can stabilize the soil more quickly and protect the soil and valuable water resources. In some cases, an introduced species may be easier to establish and could provide more cost-effective conservation covers. ASTA believes that great care should be taken to ensure that producers have realistic choices and adequate consultation with seed specialists. These choices include native and non-native species.

Mr. Matt Ponish
Page 2
July 7, 2003

ASTA and its members are strongly committed to native species. Native species cultivars developed by the Agricultural Research Service and Natural Resources Conservation Service Plant Material Centers provide demonstrated viability and performance balanced with economics and practicality. Native harvest seed from existing pastures may be used to complement this seed resource. Our members, however, believe strongly that local ecotype debates should remain focused and mindful of economic realities, seed supplies and past performance.

Regarding the use of private sector and other technical service providers, ASTA reiterates its belief that the regulations must address conflict of interest concerns and minimum standards for technical training, education and assistance. ASTA believes that conflicts of interests need to be addressed not only in relation to historical agreements and relationships, but also future arrangements as well.

In particular, ASTA believes there is a high potential for actual and perceived conflicts of interest if technical service providers are also permitted to provide inputs and other goods and services to producers. These conflicts include such things as providing proprietary inputs, preferential access to information not available to all vendors, and arrangements that would link TSP plan development and products or activities from the NRCS.

ASTA also recommends minimum standards for the technical training, education, or experience needed to perform the level of technical assistance for which certification is sought. ASTA believes that TSPs should be well-trained and experienced to address the many and varied needs and requirements of producers interested in complying with specific CRP programs and rules.

Regarding cropping history requirements, ASTA agrees with changes to the rule that provide land may be eligible if it was devoted to a conserving use, which would include any planted alfalfa and other multi-year grasses and legumes. ASTA also agrees that the exception for managed harvesting for hay, including the managed harvesting of biomass and the installation of wind turbines will increase the diversity and quality of vegetatative covers and improve the quality of wildlife habitats.






Mr. Matt Ponish
Page 3
July 7, 2003

ASTA strongly supports the research and development that has been done on native and introduced plant species by the U.S. Department of Agriculture and the Department of the Interior. We would encourage all departments and agencies to work together when considering appropriate species selection.

ASTA appreciates the opportunity to provide these comments. We welcome the serious consideration they will be given and will be happy to discuss any questions arising from them.

Sincerely,



RICHARD T. CROWDER
CEO/President

###

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.