Browse National Association of State Foresters comments:

April 15, 2019

NASF comments on revised WOTUS definition

On April 15, 2019, the National Association of State Foresters submitted comments on the Environmental Protection Agency's revised definition of waters of the United States, commonly referred to as WOTUS. In its comments, NASF made clear that one size does not fit all when it comes to water quality policy and regulation. Each state's approach [read more]

November 27, 2018

NASF comments on proposed deregulation of the emerald ash borer

In comments submitted to the USDA Animal and Plant Health Inspection Service last week, NASF detailed its concerns regarding the federal deregulation of the emerald ash borer (EAB) and its recommendations for addressing those concerns. In cooperation with federal agencies, state forestry agencies have been at the forefront of EAB monitoring, early detection, delimiting, and outreach since [read more]

May 18, 2016

State Foresters Disappointed about USFWS Revisions to Petition Process

The National Association of State Foresters (NASF) submitted comments this week in response to the U.S. Fish and Wildlife Service (USFWS) revisions to the proposed rule for those who want to file petitions for listing under the Endangered Species Act (ESA) (81 Fed. Reg. 23448). Learn more about the revisions at  In July 2015, NASF submitted [read more]

May 27, 2015

Final Rule Defining Waters of the US Released

Today the US Environmental Protection Agency (EPA) and the Army Corps of Engineers released a final rule defining waters of the United States (WOTUS), which sets the bounds of federal jurisdiction under the Clean Water Act. In November, NASF provided comment to the agencies on the proposed rule and Arkansas State Forester Joe Fox testified before the [read more]

January 9, 2014

NASF submits comments on Northern Longeared Bat

Last week, NASF submitted comments to US Fish and Wildlife regarding the potential listing of northern long‐eared bat as an endangered species. The letter outlined concerns about regulations that may be imposed on forestland owners that will have little to no effect on the cause of the bat's diminishing numbers due to  the fungus‐caused disease, [read more]

August 9, 2013

NASF submits comments to SFI on the SFI Standard

NASF provided comments this week regarding the Standard used by the Sustainable Forestry Initiative Inc.® (SFI®). They launched the process of revising their current standard to develop the SFI® 2015-2019 Standard in June.  SFI®  reached out to more than 10,000 stakeholders for input. In the comments, NASF spoke highly of the current SFI Standard and [read more]

April 9, 2013

NASF submits comments concerning the role of forests in response the Climate Adaptation Strategy at USDA

Last week, NASF submitted comments to the USDA regarding their efforts to adapt to a changing climate as laid out in its 2012 Strategic Sustainability Performance Plan. The comments advanced the concepts approved by NASF as part of the policy statement, NASF Adaptation and Mitigation: Concepts for Forest-Climate Adaptation and Mitigation Legislation and Administrative Policy. [read more]