Comments

The National Association of State Foresters has submitted official comments to the U.S. Fish and Wildfire Service (FWS) and the National Marine Fisheries Service (NMFS) regarding its proposed revisions to consultation regulations under the Endangered Species Act (ESA). The proposed rule addresses the precedent set by Cottonwood Environmental Law Center v. U.S. Forest Service, a [read more]

Last week, the National Association of State Foresters provided comments to the Natural Resources Conservation Service regarding its proposed guidance for identifying non-industrial private forest land (NIPF). The term “NIPF” first appeared (without definition) in section 4(a) of the Cooperative Forestry Assistance Act of 1978 (CFAA), Pub. L. 95-313. The 1990 Farm Bill (short for [read more]

The National Association of State Foresters has provided official comments on a proposed directive regarding the implementation of the Landscape Scale Restoration (LSR) program. Given the importance of LSR in furthering priorities identified in state Forest Action Plans and the extensive role state forestry agencies and the regional state forester organizations play in administering LSR, [read more]

NASF has provided the USDA Forest Service with official comments on information collection related to the administration of the Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) programs. Through FEPP and FFP, state and local firefighting agencies acquire the property necessary to protect American homes and lives from wildfire, all while reducing the cost [read more]

The National Association of State Foresters has submitted official comments to the U.S. Fish and Wildlife Service regarding its proposed rule on the treatment of "critical habitat" as it pertains to Endangered Species Act (ESA) implementation. NASF has a substantial interest in how ESA provisions are applied and what consequences they have on the ground. [read more]

Today the National Association of State Foresters submitted official comments to the U.S. Fish and Wildlife Service and the National Marine Fisheries Service regarding their proposed rule to define “habitat” as it pertains to implementation of the Endangered Species Act (ESA). NASF supports the first and second sentences of the agencies' proposed habitat definition. However, [read more]

Today, the National Association of State Foresters submitted comments on the USDA's Agricultural Innovation Agenda: Research, Education, and Economics. NASF is pleased to provide comments on the Agriculture Innovation Agenda and the role of forestry in bringing transformational innovation for the next era of American agriculture productivity and environmental conservation. Forestry offers many opportunities for [read more]

On June 30, the National Association of State Foresters submitted comments on the current Sustainable Forestry Initiative (SFI) Standards Revision Process: There is one area of the SFI standards – specific to the Forest Inventory and Analysis (FIA) program – that we would like to offer revisions to. In the past five years, several forest [read more]

On March 10, 2020, the National Association of State Foresters submitted public comments to National Environmental Policy Act Council on Environmental Quality regarding its proposed changes to the  National Environmental Policy Act (NEPA) published in the January 10, 2020 Federal Register. NASF welcomes CEQ’s effort to update and streamline NEPA review requirements for federal agencies. [read more]

On January 13, 2020, the National Association of State Foresters submitted comments on the USDA’s proposed rule changes to the Conservation Stewardship Program (CSP) put forth in response to amendments approved in the 2018 Farm Bill. In its comments, NASF noted its appreciation for increases in CSP authorized funding through 2023. We also appreciate that [read more]