N Bickford WI County Forests Assn. 30 day comment response

Wisconsin County Forests Association Letter 30 day comment response.docx

Good Neighbor Agreements With State Cooperators

N Bickford WI County Forests Assn. 30 day comment response

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June X, 2015

Mr. Norman Bickford

President, WI County Forests Association

3243 Golf Course Road

P.O. Box 70

Rhinelander, WI 54501

Ms. Jane Severt

Executive Director, WI County Forests Association

3243 Golf Course Road

P.O. Box 70

Rhinelander, WI 54501

Dear Mr. Bickford and Ms. Severt,

Thank you for your comments submitted regarding the Information collection for Good Neighbor Agreements with State Cooperators. We received formal comments from several entities, including you. We reviewed all of the comments, and responses to your comments are enclosed.

I think that you will be pleased to see that we have incorporated many of your suggestions. We feel that the collaborative effort made to develop these Good Neighbor Agreement templates has been very valuable and will ensure that our documents will fit the needs of both the Forest Service and our State partners.

Thank you for taking the time to assist in this effort that will surely benefit forests across the Wisconsin.


Leslie Weldon

NFS Deputy Chief

Wisconsin County Forests Association

Master Agreement

Question: Recommend including sub-contractors and sub-awardees in the Non-Federal Status for State Participant Liability provision.

Answer: This is a good suggestion and they will be added to the templates.

Question: What workload is associated with the System for Award Management (SAM) Registration Requirement provision?

Answer: Registration in SAM is required for every recipient of Federal funding through a grant or agreement. There will be no additional burden as all of the States have current registrations because they already received Federal funding through other instruments.

Question: Will subcontractors/sub-recipients be required to use the same indirect cost rates established by the State?

Answer: Indirect rates for subcontractors/sub-recipients will follow the regulations in 2 CFR 200.331

Question: Is it necessary for the State to have approval from the Forest Service for sub contacting?

Answer: The only approval for the use of subcontractors occurs if there is a transfer of substantive programmatic work to a subcontractor that was not identified in the original scope of work. This follows the regulations in 2 CFR 200.407.

Question: Can the Program Income provision be updated to reflect the additive method as the default?

Answer: The provision has been updated to make the additive method the default.

Question: Are States required to require that all subcontractors ensure that their workers complete and I-9 form and are eligible workers?

Answer: According to 2 CFR 200.317, a State will follow their own procurement policies and procedures, which may include the requirement to ensure that all workers are eligible.

Comment: Suggest that language be added to specifically allow maintenance of permanent roads.

Response: This was added to the Title paragraph of the Supplemental Project Agreement since it applies to more than just timber sales. It is also included in appendix D for the timber sale plan

Question: What, if any, role does a subcontractor play in the development of the Scope of Work?

Answer: The development of the Scope of Work is between the Forest Service and the State partner. Should the State choose to use subcontractors or sub-recipients to complete some of the work on their behalf, then that negation should occur between the State and any subs, however use of subcontractors/sub-recipients should be identified in the SOW and financial plan.

Question: Can Financial Status Reporting only be required annually?

Question: Can Performance Reporting only be required annually?

Answer: The reporting frequency may be negotiated between the Forest Service and the State. The reports must be completed at least annually and no more often than quarterly.

Comment: Clarification is needed for who prepares/provides the silvicultural prescription and/or marking guides.

Response: Under II. A. (2). In the SPA, language was modified to say “provided or approved silvicultural prescriptions and timber marking guides.” The project specific statement of work will have to clarify whether the state or the Forest Service prepares them.

Question: It is unclear how the purchase of Equipment comes into play with timber sales.

Answer: The provision allowing purchase of equipment has been removed.

Comment: Would like to see the development of an approved timber sale contract template that would allow for a more streamlined process for quick approval of contracts.

Response: The Forest Service would support development of an approved timber sale contract template. This will need to be done at the agreement level and is therefore not specified or required in the template.

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