[MPWG] AHPA Submits Comments on Special Forest Products and Proposed Fees

[Karen Robin]

AHPA Submits Comments on Special Forest Products and Proposed Fees

 

(January 25, 2008) - The American Herbal Products Association (AHPA) has
submitted comments to the USDA Forest Service in response to that
agency's proposed rule governing the sale and disposal of nontimber
forest products that are harvested on National Forest System lands. The
proposed rule, which was issued last October, sets requirements for the
Forest Service to monitor such harvests and ensure that they occur at
sustainable levels, and establishes programs for collection of fees from
harvesters.  

 

"Our National Forests and National Grasslands provide many commercially
valuable plants to the trade," said AHPA President Michael McGuffin.
"AHPA and its members are committed to sustainable use of our plant
resources and we applaud the Forest Service for its management efforts.
We are also supportive of reasonable fees that can be used to manage
those resources, but those fees must be established at levels that do
not disrupt the income of individual collectors and other small
businesses that are engaged in sustainable harvest operations." 

 

Among its comments to the Forest Service, AHPA suggested that fees for
harvested forest products be calculated at the point of harvest, rather
than further along the distribution or value-added chain, and that these
fees should be 3 percent of each product's value at the point of
harvest. AHPA also suggested that existing resources should be used in
both monitoring and pricing activities. These include AHPA's tonnage
surveys, the AHPA/AHP Good Agricultural and Collection Practice for
Herbal Raw Materials(1), and the ISSC-MAP(2).

 

The Federal Register notice for the Forest Service's proposed rule can
be downloaded at:
http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo
.gov/2007/pdf/E7-20658.pdf.

 

AHPA's comments are available are at:
http://www.ahpa.org/Portals/0/pdfs/08_0122_AHPAComments_USFS.pdf.

 

 

Notes:

1) Jointly published in December 2006 by AHPA and the American Herbal
Pharmacopoeia, this document is available at
http://www.ahpa.org/portals/0/pdfs/06_1208_AHPA-AHP_GACP.pdf.

2) International Standards for Sustainable wild Collection of Medicinal
and Aromatic Plants, available at
http://www.floraweb.de/proxy/floraweb/MAP-pro/Standard_Version1_0.pdf

 

 

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