February 2, 2009
Ms. Judy Rude
Communications Staff
Cooperative State Research, Education, and Extension Service
U.S. Department of Agriculture
Mail Stop 2201
1400 Independence Avenue, SW.
Washington, DC 20250–2201
RE: Comments on establishment of the National Institute for Food and Agriculture, in response to CSREES Federal Register Notice CSREES–2008–0004
Thank you for this opportunity to provide suggestions on the formation of the National Institute for Food and Agriculture (NIFA). We believe the formation of the Institute should be guided by the following principles.
- NIFA should be implemented to maximize research funding and minimize expenditures on administration. The statute stipulates that no more than 4% of the appropriated funds may be retained by the Secretary for administrative costs. We have been concerned that the six new NIFA Program Directors would increased administrative costs and simply add another bureaucratic layer between the agencies and the Under Secretary. We encourage USDA to make only those structural changes that improve efficiency and program delivery.
- Duplicative or conflicting reporting relationships should be avoided. According to the notice, the Secretary has determined that the NIFA Director will report to the Undersecretary for Research Education and Economics. We believe this is most appropriate and will avoid conflicts in reporting among agencies. Support for NIFA must not come at the expense of the Agricultural Research Service. These agencies have complementary but very different roles and responsibilities. Both must be adequately funded to sustain US agricultural growth and productivity.
- We encourage the Secretary to cap allowed charges for institutional overhead in NIFA granting programs at no more than 20%. Our immediate goal must be to increase the stature, capacity, and support for agricultural researchers within the USDA and the scientific community. Institutional overhead charges are now commonly 50% or more, consuming a large proportion of these valuable and limited funds. A reasonable cap on overhead is needed to increase the proportion of funds that go to conducting research, while still providing some basic institutional support.
- The critical importance of capacity building must not be overlooked in funding of competitive grants. Many important research needs are, by nature, long term and do not readily fit into competitive grant programs. These must be addressed with multi-year grants or ongoing investments. Furthermore, without capacity investments in facilities, equipment, and people, the pool of talent competing for grants will dwindle. ARS has lost many ‘permanent’ research positions as operating funds have been lost to unfunded salary increases and inflation. State universities are also under severe funding pressure, which will make grants even more important in funding core programs.
- We are pleased that the Agriculture and Food Research Initiative (AFRI) includes provisions for long-term grants and refers specifically to critical activities like plant breeding and germplasm enhancement, which require long-term research and funding commitments. Support for breeding is critical in crops like wheat, barley and oats where public sector programs play a large role in development of new cultivars. NIFA must develop effective guidelines for periodic review and managing of longer-term grants to ensure projects are productive and do not waiver from their approved missions. We encourage funding collaborative projects with regional focus, particularly with regard to breeding, that can more effectively addresses local threats and production constraints.
- The notice says the NIFA Director is responsible for determining the appropriate balance between applied and basic research, but we note the statute appears to provide no discretionary flexibility: it requires 60% of available funds to be invested in fundamental research and 40% in applied research. We encourage funding of applied and multidisciplinary research to ensure that scientific advances are translated throughout agricultural industries and have impact on-farm. We would appreciate clarification regarding the priorities and process to determine funding allocations among the six general program areas. We encourage the Director to invest in program areas that address critical, economically important near-term industry needs, while also providing vision, foundation, and funding to address the long-term needs of US agriculture. As such, we suggest that the Plant Health, Production, and Plant Products Division should be a high priority for agency funding.
- The Institute must carefully balance funding and priorities to address near, medium, and long-term research needs. Priorities must be placed on research that will lead to increased production and production efficiency; reduced vulnerability to diseases, insects, and environmental stress from climate change; improved processing quality, nutrition, and food safety; and new technologies for long-term crop improvement as identified under the Plant Health, Production, and Plant Products section of the statute. Economic impact must be an important consideration in determining research priorities and selecting research proposals.
- We encourage broad solicitation and use of industry input to establish priorities and assist in evaluation and selection of research proposals. Grower and private sector input will help focus efforts and encourage high levels of performance and accountability.
Our organizations are very interested in how the National Institute is implemented, and would be happy to respond to other specific requests for input.
Sincerely yours,
National Wheat Improvement Committee
National Association of Wheat Growers
National Barley Improvement Committee
American Malting Barley Association
National Barley Growers Association
North American Millers’ Association
American Bakers Association
National Oat Improvement Committee
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