Comments

Browse National Association of State Foresters comments:

September 20, 2024

NASF submits comments responding to Land Management Plan Direction for Old-Growth Forest Conditions

NASF submitted comments responding to the U.S. Department of Agriculture (USDA) Forest Service Draft Environmental Impact Statement (DEIS) to amend Land Management Plans for old-growth forests across the National Forest System (NFS). Old-growth forests contribute to nature-based climate solutions, increase biodiversity, mitigate wildfire risks, enhance climate resilience, enable subsistence and cultural uses, provide outdoor recreation [read more]

July 18, 2024

NASF responds to OSHA’s new emergency response standards

NASF submitted comments responding to the Occupational Safety Administration’s (OSHA) request for input regarding the potential impacts to the wildland firefighting community of incorporating various National Fire Protection Association (NFPA) standards into the proposed Emergency Response Standard. In the comments, NASF expressed concern that the National Wildfire Coordinating Group's (NWCG) existing standards and training are [read more]

June 28, 2024

NASF Submits Comments to USDA on Proposed Rules for Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program

The National Association of State Foresters (NASF) submitted comments in response to the United States Department of Agriculture Forest Service request for public input to support the preparation of proposed regulations intended to implement the Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program. The purpose of the Program is to facilitate farmer, rancher, and [read more]

February 2, 2024

NASF submits comments in response to the USDA Forest Service Notice of Intent for an Environmental Impact Statement on Old Growth forests

The National Association of State Foresters submitted comments in response to the United States Department of Agriculture (USDA) Forest Service Notice of Intent (NOI) to prepare an environmental impact statement (EIS) to amend all land management plans for units of the National Forest System to include consistent direction to conserve steward and recruit future old-growth [read more]

November 17, 2023

NASF Responds to the EPA’s Revisions to Air Emissions Reporting Requirement in Official Comments

NASF submitted official comments to the Environmental Protection Agency’s (EPA) proposed Revisions to the Air Emissions Reporting Requirements (AERR). In the letter, NASF emphasizes the burden to State Forestry agencies that the proposal would create for the collection and reporting of prescribed fire data. Ensuring that the use of prescribed fire remains in the toolbox [read more]

September 29, 2023

NASF Provides Official Comments to CEQ Regarding NEPA Reform

NASF submitted comments on the Council of Environmental Quality’s (CEQ) proposed “Bipartisan Permitting Reform Implementation Rule” to revise its regulations for implementing the procedural provisions of the National Environmental Policy Act (NEPA). In the letter, NASF states that NEPA should be implemented in “ways that are more productive by (1) utilizing landscape scale planning, (2) [read more]

August 11, 2023

NASF Responds to USDA Request for Comments on Greenhouse Gas Measurement Strategy

NASF submitted comments to the U.S. Department of Agriculture on the Federal Strategy to Advance Measurement and Monitoring Greenhouse Gas Measurement and Monitoring for the Agriculture and Forest Sectors. “The USDA Forest Service’s Forest Inventory and Analysis (FIA) program provides crucial information to federal and state forestry agencies, industry, academic, and conservation organizations on a [read more]

March 28, 2023

NASF Joins Partner Organizations in Comments to EPA on the Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

NASF, in partnership with the National Alliance of Forest Owners (NAFO), the Society of American Foresters (SAF), and the Forest Landowners Association (FLA), submitted official comments to the EPA in response to the Reconsideration of the National Ambient Air Quality Standards for Particulate Matter. The comments stress the importance of avoiding undue or unintended restrictions [read more]

August 30, 2022

NASF submits comments on defining old-growth and mature forests

Today, the National Association of State Foresters (NASF) submitted comments on the joint USDA Forest Service-DOI Bureau of Land Management request for information on federal old-growth and mature forests. The management of federal forest lands greatly influences the resilience and health of all America’s forests and the full range of social, economic, and environmental benefits [read more]

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