Wyoming State Forestry Division 
THE FOREST RESOURCE AGENCY OF WYOMING 
1100 W. 22nd STREET PHONE: (307) 777-7586 
CHEYENNE, WY 82002 FAX: (307) 777-5986 
Forestry@state.wy.us 

17 March 2009 


Docket Number NRCS-IFR-08011 
Section 2706 of the 2008 Farm Bill, interim final rule for the implementation of Technical Service Provider Initiative (TSP).

 
“Currently, the TSP rule provides national criteria including that a TSP must meet State, Tribal and professional business licensing requirements. No additional criteria will be added at the national level. In addition, experience has shown that unique state level requirements beyond licensing and state law may be a hindrance to effective implementation of the TSP provision. Consequently, NRCS is taking the opportunity to clarify its policy that licensing and state law requirements will be the only state level certification criteria allowed. No change to the regulation is necessary since state law and licensure requirements are already addressed at section 652.21(a)(2).” 
 
"Section 2706 of the 2008 Act also requires the Department to review TSP certification requirements within one year of enactment of the 2008 Act to determine if adjustments are needed to improve participation. In accordance with the new statutory requirement, NRCS will review the TSP certification requirements based upon the criteria that NRCS employees must meet to be authorized to provide technical assistance related to particular conservation practices or activities.”

In many states, State Agencies responsible for forest management and private lands assistance have played an active role in assisting with the implementation of forestry related EQIP practices. Given the recent changes in the Farm Bill, that role will likely expand. Current technical service criteria for providers of forestry assistance, offers three qualification options: certification or experience or education. This flexible approach in combination with the need to meet local licensing requirements and State law strikes a good balance between the need for national criteria and adjusting to local standards. Were the NRCS to reduce its current flexibility or adopt additional requirements at the national or local level, the pool of available technical service providers and the ability to offer local forestry assistance in regard to the EQIP program would be negatively impacted.
 
John Crisp, Resource Forester 
Wyoming State Forestry Division