The American Seed Trade Association supports the following positions with regard to implementation of federal and state hemp regulations:
1.	The term ‘hemp’ should be defined consistently as the plant Cannabis sativa L. and any part of that plant, including the seeds thereof and all derivatives, extracts, cannabinoids, isomers, acids, salts, and salts of isomers, whether growing or not, with a delta-9 tetrahydrocannabinol concentration of not more than 0.3 percent on a dry weight basis. 
2.	Seed supply sourcing should only include free market accessibility from commercial production.
3.	The Association of Official Seed Certifying Agencies standards for production of industrial hemp seed should be used for all production to ensure quality and differentiation between hemp and marijuana because of the difficulty in differentiating between the two crop seeds. 
4.	Interstate transportation rules should be clarified to eliminate the disparate and confusing standards on commerce for hemp seed and plant shipments.
 
Thank you for the opportunity to comment.

Pat Miller
American Seed Trade Association
Alexandria, VA