Comments

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]

The National Association of State Foresters has provided official comments to the U.S. Fish and Wildlife Service (USFWS) regarding the agency's proposal to change the listing status of the northern long-eared bat (NLEB) from threatened to endangered. Over the decades since the Endangered Species Act (ESA) was enacted, NASF has observed how ESA provisions affect [read more]

In official comments sent to the USDA, the National Association of State Foresters responded to the Executive Order "Tackling the Climate Crisis at Home and Abroad." America’s trees and forests are a strategic national resource with vast potential as solutions for climate change, public health, and economic challenges. Wildland fire is a national crisis – [read more]

The National Association of State Foresters has submitted formal comments to the USDA Forest Service regarding its guidebook chapter on Good Neighbor Authority (GNA). States are an essential partner in realizing GNA accomplishments; and NASF continues to appreciate the efforts by the Forest Service to embrace coordinating with state forestry agencies on GNA policy and [read more]

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]