NAFO - pesticide permit development 

Steen, Ellen 

to: 

Allison Wiedeman, Jack Faulk, Jordan Page 

02/11/2010 04:17 PM 

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Allison, Jack, and Jordon: 

Thank you all very much for your time last week to meet with the National Alliance of Forest Owners (NAFO) to 

discuss the pesticide permit development as it relates to silvicultural pesticide use. The NAFO team found the 

discussion very informative and useful. I hope it was helpful to you, too.

The NAFO team is working on two "action items" to follow up on that discussion. The first is that we will provide 

you with a narrative description of the practical reasons why pesticide deposition into ditches is often 

"unavoidable" in order to effectively target the "pest" (vegetative competition) during herbicide application to 

managed forest lands. We hope that this will remove any lingering question that silvicultural herbicide application, 

in addition to insecticide use, should be covered under the general permit (that is, coverage should be available 

for forest landowners who conclude that, for their operations, a "discharge" is likely and coverage is desired). The 

second "action item" is that we are gathering data from the largest NAFO member companies on how many 

application sites would be captured if site-specific information (e.g. in an NOI) were limited to application sites 

above several hypothetical acreage thresholds. We suggested an application site threshold of 250 acres in our 

meeting, and we believe that most if not all of the larger landowners would have sites of this size, but we will 

provide more specific information. As we discussed at our meeting, our goal is to find some way to limit the 

number of application sites for which a landowner would need to provide site-specific information (location 

description, map, etc.) in an NOI and other submissions, to avoid situations in which landowners must provide 

dozens, hundreds, or even thousands of maps and other records along with their permit submissions. 

I also made a note that we should provide you with good sources of information on forest land ownership. You 

will find some good information at the Forest Inventory and Analysis Program website: http://www.fia.fs.fed.us/, 

including a downloadable pdf copy of the National Report of Forest Resources 2007 (which is undoubtedly too 

large to attach to this email). This report, particularly pages 19 to 22 (on Forest Ownership), 58 to 66 (on 

Timberland Area), and 67 to 69 (on Planted Forests and Plantations). These sections provide a lot of data on 

acreages of various types of forest land and the type of ownership (public, corporate private, and noncorporate 

private) in which those acreages are held. I don't see any specific discussion of pesticide or herbicide use in the 

report, but it certainly gives a good picture of the acreages and numbers of land owners involved. Tables at the 

back of the report provide good back-up numbers for the narrative discussions in the text. 

Another useful resource is: Brett J. Butler, Family Forest Owners of the United States, 2006: A Technical 

Document Supporting the Forest Service 2010 RPA Assessment. Here is a link/URL: 

http://nrs.fs.fed.us/pubs/gtr/gtr_nrs27.pdf. This includes a lot of information on family forest owners (a subset of 

noncorporate private owners), including numbers of owners with various sizes of land holdings. One interesting 

statistic here, for example, is that 928,000 family forest owners reported having applied chemicals to their lands 

within the past five years prior to the survey. Our NAFO team tells me that they understand the reference to 

"chemicals" to mean pesticides.

We have already had one follow-up meeting among the NAFO team, and we are working to have our homework 

back to you by the end of February. When we provide this additional information to you, would you also like to 

have any additional information from us on silvicultural "best management practices" for pesticide use? We have 

provided you with a compendium of State BMPs. I know EPA's current thinking is that BAT would be quite 

general and would not specify particular control measures. But please do let me know if it would be helpful for us 

to provide details on the particular control measures that are typically used (and that we would expect to see in 

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many forest landowners' plans). 

Again, many thanks for your time and for all your hard work to come up with rational permit requirements. 

Ellen 

Ellen Steen 

Crowell & Moring LLP 

1001 Pennsylvania Ave, NW 

Washington, DC 20004 

Direct: (202) 624-2539 

Mobile: (202) 236-1300 

Fax: (202) 628-5116 

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