PUBLIC SUBMISSION

Docket: NRCS-2009-0007 Technical Service Provider Assistance 
Comment On: NRCS-2009-0007-0001 Technical Service Provider Assistance 
Document: NRCS-2009-0007-DRAFT-0009 
Comment on FR Doc # E9-00828 

As of: April 24,2009 
Received: March 17, 2009 
Status: Pending_Post 
Tracking No. 80918435 
Comments Due: March 17, 2009 
Submission Type: Web 

Submitter Information 
Name: Leslie Allen Everett 
Address: 173 McNeal Hall 
         1985 Buford Ave. 
         St. Paul, MN, 55108 
Email: evere003@umn.edu 
Phone: 612-625-6751
 
Submitter's Representative: Leslie Everett 
Organization: University of Minnesota Water Resources Center 

General Comment 

1. The FOOD, CONSERVATION, AND ENERGY ACT OF 2008, Title II Conservation 
Subtitle H-Funding and Administration of Conservation Programs, SEC. 1242. 
DELIVERY OF TECHNICAL ASSISTANCE, (f) ADMINISTRATION, (4) ELIGIBLE ACTIVITIES, 

(A) INCLUSION OF ACTIVITIES, states: "The Secretary may include 
as activities eligible for payments to a third party provider, (i) technical 
services provided directly to eligible participants, such as conservation 
planning, education and outreach, and assistance with design and implementation 
of conservation practices; and (ii) related technical assistance services that 
accelerate conservation program delivery." It appears that education and 
outreach are authorized in the law but not implemented in the rule. Education and outreach are an indispensable part of implementation and maintenance of conservation practices and should be explicitly provided for in the rule as intended by Congress. 

2. We welcome the recognition that some aspects of training Technical Service Providers require the participation of NRCS personnel. Adequate knowledge for training in Department regulations, policies, procedures, and processes cannot be adequately maintained by those outside the Department. 

3. Technical training of TSPs in subject matters with very limited audiences cannot be supported by participant course fees. Course development and delivery takes too much personnel time to be paid for by courses that are delivered once per year to a small audience. In Minnesota for two years we have supported these trainings on limited-time state clean water grant funds. This is coming to an end. If NRCS wishes to have trained TSPs, they need to put some funds into it. There is sufficient flexibility in the law to accomplish this, and the Cooperative Extension Services are willing partners if there is a contribution from NRCS to offset some of the costs.