April 16, 2007 - ASM Recommendations for the 2007 Farm Bill Research Provisions

The Honorable Tom Harkin
Chair, Senate Committee on Agriculture, Nutrition, and Forestry
328 Russell Senate Office Building
Washington, DC 20510

Dear Chairman Harkin:

The American Society for Microbiology (ASM), with more than 42,000 members, applauds the efforts of Congress, the US Department of Agriculture (USDA) and the USDA Research, Education and Economics Task Force, to increase and improve US agricultural research in the research title of the 2007 Farm Bill. The ASM is the largest single life science organization. Its mission is to enhance the science of microbiology, to gain a better understanding of life processes, and to promote the application of this knowledge for improved health and for economic and environmental well-being.

The ASM appreciates the opportunity to comment and to provide recommendations to the Senate Agriculture Committee as it considers the provisions for agricultural research in Title VII of the 2007 Farm Bill. The ASM is concerned that the United States is losing ground in the important field of agricultural research, just as the challenges the nation faces in global competitiveness, food safety, energy production, and climate change, place more emphasis on the need for greater research to respond to these demands. The CSREES National Research Initiative (NRI) competitive grants program has never met its authorized funding level of $500 million. We encourage Congress to better meet these challenges by including important provisions to enhance agriculture research in the 2007 Farm Bill and to increase funding for agricultural research.

The ASM supports the general concepts proposed by both the USDA and the Task Force to achieve the goals of increasing support for agricultural research, improving efficiency in meeting USDA’s mission, strengthening linkages between government and universities, and improving the perception of USDA science. The ASM recommends a combination of the USDA and Task Force proposals to establish a USDA Office of Science and a National Institute of Food and Agriculture (NIFA) to best meet these goals.

The ASM proposes the following recommendations for Title VII of the 2007 Farm Bill:
  1. A NIFA should be established to administer competitive, peer reviewed grants on basic research. The Institute would act in addition to and independent from the current USDA research programs, such as the Agricultural Research Service (ARS) and the Cooperative State, Research, Education and Extension Service (CSREES). The Institute should be mandated and receive new funding to ensure adequate support for its program in addition to the ARS and CSREES programs. The ARS and CSREES programs should continue to receive strong funding. 
  2. USDA research programs should be strengthened by bringing together ARS, CSREES, and the newly established NIFA under an Office of Science, led by a USDA Undersecretary for Science. 
  3. The recommendation of the Task Force to increase indirect cost support to be the same as the standard negotiated rates that now apply to National Institutes of Health (NIH) and National Science Foundation (NSF) grants, rather than the current artificially low rates associated with USDA research grants, should be adopted as funding for USDA agricultural research increases. 
  4. A 4 year period to transition institutions from formula funding to competitive grants funding should be implemented. 
  5. The USDA should be given the requested authority to conduct research and diagnostics for highly infectious foreign animal diseases on mainland locations in the United States.
USDA Research Agencies
The establishment of NIFA would provide a high profile, scientific entity to administer an expanded competitive, merit-reviewed grants program. The Institute would strengthen agricultural research because it could develop an interactive relationship with Congress, the scientific community, and the public, similar to that of NSF and NIH. The ASM supports the outline and funding structure for NIFA recommended by the Task Force, but recommends locating NIFA within a USDA Office of Science. Additionally, integrating the USDA scientific agencies under an Office of Science would create better dialogue and integration of the intramural and extramural research programs, as well as preserve their proximity to and integration with the USDA education and extension programs.

USDA Indirect Costs
Indirect costs of research are important institutional costs that benefit and support research. An increase in the indirect cost of grant support may attract more researchers and their institutions to apply for USDA grants. Currently, USDA CSREES competitive grants are limited to 20 percent of total funds provided in a grant award, while the NIH funds allowed indirect costs that enable institutions to recover more fully the actual costs of research. The ASM endorses the recommendation of the Task Force to increase indirect cost support to be the same as the standard negotiated rates that now apply to National Institutes of Health (NIH) and National Science Foundation (NSF) grants, rather than the current artificially low rates associated with USDA research grants. We also urge Congress to increase funding for the full costs of agriculture research grants.

USDA Competitive Grants
Transitioning from the formula funding mechanism to a larger competitive grants funding mechanism will support the best science. This approach will create more opportunities and better support the advancement of agricultural research. However, the ASM urges that Congress create a competitive grants mechanism that preserves the ability to address local and regional issues, as well as provides long term research support on a competitive basis. The NSF has been successful fulfilling these goals through programs such as the Long Term Ecological Research (LTER) program.

USDA Animal Health Facility
Giving the USDA authority to conduct research safely on highly infectious animal diseases and diagnostics on mainland locations in the United States is necessary. Currently, research and diagnostics for highly infectious foreign animal disease agents are conducted offshore at the Plum Island Animal Disease Center (PIADC). The Department of Homeland Security (DHS) has begun to move all functions of the PIADC to a new facility, the National Bio and Agro-Defense Facility (NBADF), and when it is fully established and operational, all USDA work at the PIADC will relocate to the NBADF. USDA is anticipating that the NBADF will be built on the US mainland, and the USDA must be authorized to conduct research on highly infectious foreign animal diseases at this new facility or at other US mainland locations. Such research is critical for the development of vaccines, therapeutic drugs, and detection methods to protect against diseases that could severely damage US agriculture, our food supply, and our economy. To foster the highest quality research it will be advantageous to have the facility interact with the NIH and the Department of Homeland Security (DHS) Academic Centers of Excellence on key areas of research.

The ASM believes that the recommendations outlined above will not only improve the USDA research infrastructure, but most importantly will provide the best system for conducting research and a safe, secure and plentiful food supply. We appreciate the opportunity to comment and look forward to working with the Committee on Agriculture on this important issue.
Ruth L. Berkelman, Ph.D., Chair, Public and Scientific Affairs Board
Michael P. Doyle, Ph.D., Chair, Committee on Agricultural and Food Microbiology