NASF comments on proposed NIPF guidance

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 the Food, Agriculture, Conservation, and Trade Act of 1990, Pub. L. 101-624) established a definition for NIPF that has since appeared 50 times in the last five Farm Bills and is still consistently used by Congress today, 30 years later. The intent of the definition has always been clear: to identify and exclude from eligibility those forest lands owned by vertically-integrated timber companies that use those lands to supply their mills. As the number of vertically integrated timber companies has substantially declined in the past 30 years, it now appears with this proposal that NRCS has decided to repurpose the definition of NIPF for other unclear policy objectives.

Despite recent discussions with both NRCS and the USDA Forest Service (USFS), NASF has not been able to identify any issues that would necessitate a new definition and/or guidance for identifying NIPF. Likewise, state foresters maintain strong partnerships throughout the country – ranging from private land owners and public forest managers to officials in Washington, D.C. – and have never heard any concerns regarding the longstanding definition of NIPF, nor has the Joint Forestry Team, which is composed of representatives from NRCS, USFS, NASF, and the National Association of Conservation Districts (NACD). Congress’ definition for NIPF – used consistently for three decades by USDA – has worked well in the implementation of both NRCS and USFS programs.

Changes to the guidance for identifying NIPF or to the definition of NIPF would have broad ramifications, including effects on state landowner assistance programs. NASF strongly encourages NRCS to work collaboratively within the Joint Forestry Team to better understand the effects of such a proposal. NASF would also recommend that any proposed changes be considered under Farm Bill reauthorization to ensure that forestry and conservation stakeholders are able to make a thorough assessment and Congress has the chance to clarify intent. Finally, NASF would caution finalizing any proposed changes during a presidential transition.

Click below to read the comments in full.

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