NDA Pens Comments to Forest Service Regarding National Forest Management

July 25, 2023 By: Torin Miller

The National Deer Association (NDA), along with conservation partners, recently submitted comments to the U.S. Forest Service (Forest Service) to provide input on the recent Advance Notice of Proposed Rulemaking (ANPR) to inform potential agency actions to “adapt current policies to protect, conserve, and manage the national forests and grasslands” for climate resilience, ecological integrity, and social and economic sustainability.

The nation’s 193 million acres of national forests and grasslands are of utmost importance for providing habitat for wild deer and other species valued by America’s 40 million hunters and anglers. Responsible forest management is necessary to sustain and support fish and wildlife populations across varied landscapes. Our recommendations are intended to ensure that vital habitats for deer and other species are maintained and improved over time—supporting ecosystem resilience and opportunities for future generations to enjoy our public lands.

Specifically, we believe that any forthcoming forest management policies for our national forests should support, in part, the following outcomes:

  • Promote forest diversity – a shifting mosaic of young, middle-aged, and old forest across landscapes – is imperative to manage for climate resilience. Climate resilience, carbon optimization, and biodiversity are maximized when many forest ages are interspersed across landscapes, from young forests to old growth. Humans are major ecological players and have been for thousands of years. Science and professional experience tell us that humans must continue to play an active role in stewarding many natural systems.
  • Streamline project permitting – we encourage the Forest Service to exercise its existing NEPA authority to identify categories of restoration actions that do not individually or cumulatively have a significant, deleterious effect on the human environment and therefore do not require either an environmental assessment, or environmental impact statement. Doing so will help avoid multi-year NEPA processes, avoid litigation, and realize advancement toward climate resilience.
  • Build local capacity – many national forests exist within a matrix of underserved communities. A restoration economy could strengthen these same communities by creating family-supporting jobs in the forestry, forest products, and restoration sectors. The Forest Service can facilitate social and economic stability by investing in projects that improve forest and watershed resiliency while also ensuring a steady supply of wood fiber from national forests. Failure to do so results in the loss of workforce capacity, mill closures, and stressed economic conditions that hit rural communities especially hard.
  • Collaborate with partners – close collaboration with partners (such as the NDA) and formal agreements are necessary to expand forest unit capacity. Policy and guidance should reflect the importance of such partnerships with output metrics reflecting the number and scope of co-stewardship agreements that support climate resilience both within and across national forest boundaries.

Of course, forest management at a national scale must require flexibility, adaptation and input from a wide range of stakeholders. This ANPR is the first step of a significant undertaking by the Forest Service to shape forest policy for years to come. The NDA will continue to work with the Forest Service and conservation partners through the rulemaking process to ensure our national forests are set up for long-term management that supports ecosystem resilience and opportunities for future generations to enjoy our public lands. We’ll be here for deer from start to finish.

About Torin Miller:

Torin Miller is a licensed attorney and NDA’s Senior Director of Policy. He works at the intersection of conservation and natural resources law, policy, advocacy and education. He has bachelor's and master's degrees in wildlife and fisheries science from Penn State University and a J.D. from Penn State Law. Torin came to NDA via the National Deer Alliance, where he served as the Policy and Outreach Coordinator.