Draft regulations on guest workers for reforestation work pose a risk to domestic reforestation of private and public lands. NAFO submitted comments on the draft regulations today, stating, in part:
NAFO urges the Department to reconsider this approach and retain reforestation as part of the H-2B program. Failure to do this will negatively affect reforestation efforts and cause significant harm to the economic viability of long-term forest management.
Reforestation work differs significantly enough from annual agricultural crops that the mandates for the H-2A program don’t fit reforestation. For example, because of the spatial arrangement of forests on the landscape and the decades-long growing cycle, work sites vary from year to year and may stretch across multiple states. Additionally, reforestation is much more susceptible to weather and other delays, including: too hot; snow; too wet; too dry; early or late seedling shipments; and the requirements of site preparation.
Read the entire comments (PDF).
Tags: environment
