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

Sun Jan 27 06:27:34 CST 2008

Hello,
Glad to see that AHPA was able to submit comments for this.  I wish that this list had more of a roll in discussion.  To me, the following announcement appeared to be relevant to Alaska.  Sorry, but frankly as most people do I often scan emails and this one had Alaska written all over it.  Since it is calling for revisions to the Alaska Administrative Code and comments were to be sent to DNR in Alaska, excuse me but, if public comment were really important to DNR on this matter, it might have been valuable to make it more clear that this rule affects collection in the lower 49 states.  Here in PA when I called the Forest Service to ask how to request permission to harvest teaberry, black cohosh and aralia on a recently clearcut large piece of state forest land I was connected to four different people who did not know procedure, was told they'd find out and call back, and never heard back from them.  Granted this was state land not national forest land.  None the less, DNR might want to think about more effective public outreach (even though public comment is such a nuisance) and might also want to do some outreach to their state siblings.  Democracy may be a bit quicker without including everyone but then, that isn't really the point, is it?  At any rate, glad some of the people got to put their two cents in.  Perhaps next time this list could work openly on a participatory democratic process of discussion and accord, and submit a group comment.  Even if we never reached a point of agreement, it might inspire a few more citizens to throw some cents into the mix. So long as people are not too busy and important for participatory democracy, it would be nice to give it a chance to work. 

The following is the public notice regarding these proposed regulation 
changes: 
NOTICE OF PROPOSED CHANGES IN THE
REGULATIONS OF THE DEPARTMENT OF NATURAL RESOURCES

The Department of Natural Resources (DNR) is proposing to add new 
regulations and revise others concerning the use of state lands for the 
commercial harvest of non-timber forest products (NTFPs).  DNR proposes to 
adopt regulation changes in Title 11 of the Alaska Administrative Code, 
specifically 11 AAC 96.030 dealing with the Applications for a land use 
permit. The Department of Natural Resources also proposes to adopt new 
regulations in Title 11 of the Alaska Administrative Code, specifically 11 
AAC 05.010(a) and (e) dealing with the Fees,  11 AAC 96.035 dealing with 
the Commercial Harvest of non-timber forest products and 11 AAC 96.250 
dealing with definitions. 
The revised regulations include the following: 
refunds of annual use fees for land use permits
requirements for applications for land use permits

The new regulations include the following: 
establishes an application and minimum permit fee for commercial harvest 
permit for non-timber forest products,
establishes permit harvest fees for the commercial harvest of non-timber 
forest products,
establishes a permitting process, standards and conditions for the 
issuance of permits for the commercial harvest of non-timber forest 
products,
defines terms used in the issuance and management of permits for the 
commercial harvest of non-timber forest products.

The proposed regulation additions and changes are necessary to establish a 
sustainable commercial harvest program for limited amounts of non-timber 
forest products on state lands and to ensure that the public interest is 
served in the commercial harvest of these materials. 
You may comment on the proposed regulations, including the potential costs 
to private persons of complying with the proposed changes, by submitting 
written comments to the Division of Mining, Land and Water, 550 W. 7th 
Avenue, Suite 1070, Anchorage, AK 99501-3579 or by e-mail to 
dnrmlw at dnr.state.ak.us  or by fax to 907-269-8904.  The comments must be 
received by the department no later than 5:00 p.m. on Friday, on January 
4, 2008. 
If you are a person with a disability who needs a special accommodation in 
order to participate in this process, please contact Joseph Joyner at 
269-8511 no later than December 21, 2007, to ensure that any necessary 
accommodations can be provided.
For more information or a copy of the proposed regulation changes, go to 
http://www.dnr.state.ak.us/mlw/hottopics/, or write to the Director’s 
Office, Division of Mining, Land and Water, Department of Natural 
Resources, Attention Joseph Joyner, 550 W. 7th Avenue, Suite 1070, 
Anchorage, Alaska 99501-3579; or call 907-269-8511, or email at   
Joe.Joyner at alaska.gov . 
After the public comment period ends, the Department of Natural Resources 
will either adopt these or other provisions dealing with the same subject, 
without further notice, or decide to take no action on them.  The language 
of the final regulations may be different from that of the proposed 
regulations.  You should comment during the time allowed if your interests 
could be affected.
Statutory Authority:   AS 38.05.020; AS 38.05.035; AS 38.05.850; 
Statutes Being Implemented, Interpreted, or Made Specific:   AS 38.05.020; 
AS 38.05.035; AS 38.05.850;
Fiscal Information:  The proposed regulation changes are not expected to 
require an increased appropriation.

-----Original Message-----
From: Karen Robin <KRobin at ahpa.org>
To: mpwg at lists.plantconservation.org
Sent: Fri, 25 Jan 2008 1:14 pm
Subject: [MPWG] AHPA Submits Comments on Special Forest Products and Proposed Fees

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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