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 the discovery of EAB in southeast Michigan in 2002. Today, the highly mobile and destructive exotic insect is found in 35 states.

The federal deregulation of EAB concerns state foresters for the following reasons:

  • Any shift in federal funding away from EAB surveying will significantly reduce state forestry agencies’ capacity to monitor EAB spread, and thus respond to infestations.
  • Federal EAB quarantines have been beneficial in several ways. They have (1) slowed the spread of EAB, giving states more time to plan, (2) proven to be effective communications tools that non-regulatory agencies have used to reach the public, and (3) allowed for consistent policies state-to-state that support wood-based interstate commerce.

In an effort to address these concerns, state foresters recommend that APHIS champion a national, multi-agency approach to EAB management by taking the following actions:

1. Redirect available funding remaining from terminated quarantine and regulatory efforts to support state research and management of EAB. 

2. Continue to fund the EAB parasite lab, distribution of EAB parasites, and identification of ash tree genetics tolerant and/or resistant to EAB.

3. Articulate a refreshed strategy for curbing the spread of EAB.

4. Work with USDA Forest Service to develop a cooperative EAB Management program to sustain and replace ash trees killed by EAB.

5. Provide information to the public about the federal deregulation of EAB and exactly what it means for a board range of audiences, including businesses.

Click here to see the final letter in full.

Have questions? Contact Communications Director Whitney Forman-Cook at

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