Notice_to_Vendors_0001.docx

Background on the issues encountered this Spring. Changing the specifications mid-way thru a buy is not standard practice and definitely requires significant issues to justify making the change. I will start with the timing issue. In March when the solicitation was posted, I had no idea of the issues that would ultimately change the Buy. If I would have known prior to March, the spec would have been changed and the Solicitation issued with the revised specs. We were too far into the Buy to cancel and start over. All I could have done was cancel the Spring Buy and wait for the Fall Buy to start. Our warehouses were extremely low on stock due to the extreme fire season last year. We needed to stock up to be somewhat prepared for this fire season. We (myself and the BLM Solicitor’s office) felt that the changes that were made, along with some leniency on tolerance points, were fair and reasonable to you, the vendors. The fairness portion of that statement is due to the fact that you selected and identify 2 labs upfront and we gave vendor’s the ability to select a 2nd lab of their choice, if a 2nd test was required. I also utilized the tolerance table as a guide for variances between 2 tests.

When we started the review process on the Pre-Qual seed after the solicitation closed on April 5th, we started asking questions on tests that didn’t appear to be original certification tests as required in the specs. We were provided additional test results from multiple vendors that showed substantial differences in test results that included noxious weeds, downy brome, or extremely low TZ or germ rates. I WILL STATE, IT IS NOT OKAY TO BID SEED AS PRE-QUALIFIED WHEN YOU KNOW THAT A NOXIOUS WEED WAS FOUND ON OTHER TEST RESULTS, BUT YOU HAVE 1 TEST RESULT THAT DIDN’T FIND THE NOXIOUS WEED. THE SAME GOES FOR BIDDING PQ-ABF, IF YOU HAVE TEST RESULTS SHOWING DOWNY BROME—DO NOT BID IT AS ABF ON A TEST THAT DIDN’T IDENTIFY DOWNY BROME.

After finding the issues listed above, we started digging deeper into the lot numbers and tests. We found where we purchased or rejected lot numbers (offered on the Spring Buy) in the past with significantly different test results. The Pre-Qualified Seed process is designed to get good seed to the Government quickly to utilize immediately on projects. If the Pre-Qual process is eliminating the Gov from getting good seed, the process doesn’t benefit the Government. The Pre-Qual process is not designed for you as vendor’s to “shop around” and provide the best test result possible out of 10 or 20 or 30 or more tests. That “best” test result is more than likely, erroneous-definitely unrepeatable by multiple labs. The Pre-Qualifed test result should be a base-line test that is a true representation of the seed and that you have multiple test results that are similar.

After finding and discussing the Pre-Qual test issues with the Seed Program staff, a comment was made about noxious weeds being found in existing stock. When I questioned the comment, I was give the following issue:

In late winter as seed was being mixed out of the warehouses, some older seed was identified to be used on projects. Any seed with a test more than 2 years old, requires retesting (TZ). The customer requested a germ test be conducted; purity was included in the request. I am not sure how many lots were requested to be retested, but 4 lots tested positive for noxious weeds. Those 4 lots had been purchased on the Consolidated seed buy with tests that showed no noxious weeds found.

At this point I am very concerned that we are spending a massive amount of money on seed that is not good and that is defeating our whole purpose of improving the health and condition of our public lands. I get that you all were upset by the changes that I imposed, but you need to know that I was shocked and livid by what we discovered was being misleadingly offered and delivered to the BLM under the disguise of Pre-Qualifed seed.

The Consolidated Seed Specification is written relying on Seed Labs being diligent, unbiased, and providing a true representation of the seed. I get that their will always be variances in results, but they need to be repeatable results and a true effort needs to be put forward to identify noxious weeds and downy brome. I have heard comments that vendor’s want labs that provide favorable results to them. What I hear with that comment is: If they are favorable to you the vendor, more than likely they are unfavorable to the Government, your customer, and affecting your Public Lands.

I have heard many comments that seed testing results are highly variable and not consistent. That is not what we found this Spring on the majority of the labs. The Spring Buy spot-checks (49 lots) were distributed amongst 3 labs (ID, WA, and MT). When comparing tests results from ID, WA, MT, and WY, we found that 92% of the test results were within 7 points. The other 8% were within 10 points. We had 13 lots that were based on results from other labs (not ID, WA, MT, WY), that were more than 15 points out of variance and some seed tested as poor quality on the BLM spot-check.

On the existing inventory, we retested lots that had been accepted based on a test from labs that we have identified with issues. We retested about 110 lots between the 3 warehouses. About 45% of the lots were tested by 2 labs, so that we could identify consistencies or inconsistencies within the labs we chose. We divided up the retesting of the existing inventory in 2 groups Idaho and Ut paired together and Washington and MT paired together. The results show 78% of the tests fell within 7 pts. Within 10 pts, we had 91%. Only 4 tests had a greater than 10 pt range and we are following up with the labs to identify which tests are erroneous and try to resolve the issue going forward.

We will try and follow-up with the labs on all erroneous test results going forward to resolve the issue and hopefully the labs will learn from the experience.

The majority of the issues found in the spot-checking and the retesting of stock involved 2 labs. Those labs have been removed from the approved lab list. 98% of the issues involved Sourced Identified (SI) seed, that is why SI is no longer eligible to be offered as Pre-Qualified seed. Certified blue tag seed is the only eligible seed classification to be offered as Pre-Qualified. We considered removing the Pre-Qualified process all together (as many vendors suggested), but that is our only option to get Annual Brome Free seed-which is important to us. We will be working on an incentive program for Annual Brome Free seed on future Buys. We are requiring a Germination test on the PQ test submission, with the hope that this will eliminate the “shopping around” for the best test result. We will continue to spot check heavily on the Buys until our confidence in the program is re-established and we are sure that the issues have all been identified. Spot checking will be a standard practice on all seed buys to keep the vendors and labs providing and testing seed with integrity and showing the results as a true representation of the seed. Any vendors identified to be offering seed as Pre-Qualified with significant issues being found on the spot-checks will be rated as poor or unacceptable on their CPARS report and the performance rating will be considered when selecting seed on future buys.