The U.S. Forest Service (USFS) and Natural Resources Conservation Service (NRCS) have proposed to change the definition of industrial and non-industrial private forest (NIPF) landowners based on private forest landowners managing forests for timber income or with forest acreage above 45,000 acres. Changes to the guidance for identifying NIPF or to the definition of NIPF would have broad ramifications, including effects on state landowner assistance programs.

The intent of the NIPF 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.

Excerpt from FLA Comments to NRCS

FLA believes that all forest lands and all types of forest landowners should be eligible to participate in NRCS’s conservation programs, regardless of acres owned, mill ownership status, frequency of timber harvest, or adjusted gross income. If a tract of forest land demonstrates a high enough conservation value that its inclusion in an NRCS program would be beneficial to the ecosystem, the environment, and the region, then that land should be eligible for participation regardless of other arbitrary factors imposed by program administrators. No equivalent restrictions are imposed on agricultural lands or landowners, and forest land should be treated in a similar manner when determining eligibility for NRCS programs.

FLA, along with many other forest and conservation stakeholders strongly oppose the proposed change and encourage the USFS and NRCS to work collaboratively with forest stakeholders who their programs exist to serve.

FLA Comments to USFS

FLA Comments on NRCS NIPF Definition

Excerpt from the National Association of State Foresters

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.

NASF Comments to NRCS