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Comments on USFS Old Growth Protections due Feb 2nd

Want more background on this issue? Scroll down.

In December 2023, the Forest Service announced its plans to begin the process of amending all Forest Plans across the country with language that protects old growth trees. This is the first time the agency has made significant commitments towards permanently banning commercial logging in old-growth forests. 

However, there are some big loopholes in the language that must be closed if we want to ensure enforceable protections for big and old trees. There are a variety of exceptions for old growth logging written into the proposal, and there are no protections for the nearly-old-growth (“mature”) trees that are crucially augmenting what little old growth remains. 

Commenting during this “scoping” phase of the process is critical if we hope to strengthen the language in this proposal. We have until 9pm Pacific time on Friday, Feb 2nd. Here’s how you can do so:

  • Visit the USFS comment portal

  • Fill out your contact information 

  • Leave a comment in your own words about why protecting public forests is important. Here are some points to consider:

    • Our country has so few old growth forests left. What remains is incredibly valuable and must be protected! 

    • We must also focus on protecting future old growth - sometimes called “mature” forests. They are the next generation and, in some places, are providing the functional equivalent of old growth for species that need it. In the Blue Mountains, mature and old growth trees comprise only 3% of the forest, but contain 42% of the aboveground carbon storage.

    • In order to deliver on President Biden's Executive Order promises, there must be real protections for both mature and old-growth trees - including from the threat of logging and “inappropriate management” techniques by the agencies. 

    • Old-growth trees from public lands should not be sold. Forests can be managed effectively without selling those trees. It’s time we recognize (and protect) them for all the services they provide: pulling pollution and carbon from our air, combating drought by storing and slowly releasing water throughout the year, and providing excellent habitat that is used by fish and wildlife throughout their lives.

Feel free to contact with questions.

What’s the background on this rulemaking?

Last year, President Biden issued an Executive Order calling on the Secretaries of Interior and Agriculture to do a number of things: conserve our country’s mature and old growth forests, combat deforestation, retain and enhance carbon storage, promote biodiversity, and much more. By doing this, he issued the Secretaries – and their agencies, the Bureau of Land Management and US Forest Service – some homework. They were to inventory the mature and old trees in the forests they manage, and use that information to create new rules to better conserve these big trees and the biodiversity that surrounds them.

As an agency that has historically been tasked with producing timber as its primary directive (the USFS does belong to the Department of Agriculture, after all), this exercise could seem a little counterintuitive. But they did do it, and it showed around 32 million acres of old-growth and 80 million acres of mature forest across the country. If those numbers sound large to you, you’re not alone. Of the several estimates that have been published in 2023, the federal government’s are certainly the most inflated.

Even if they’re 100% accurate (which is unlikely), we know that the situation in the Blue Mountains isn’t so rosy. Like most of the West, forests in the Blues were heavily commercially logged, leaving us with a deficit of mature and old growth trees. In many cases, “mature” trees – trees that are not yet old growth, but are next in line to become it – are all that’s left. And even those trees are vulnerable to logging, especially with the revised” Eastside Screens.

Big trees like these on the Wallowa-Whitman National Forest are still being logged. Photo credit: Rob Klavins.

So, how much mature and old forest is left in the Blues, and what is their role in combating the climate crisis? 5 researchers (including Dr. David Mildrexler and Dr. Beverly Law, both from Oregon) have recently published several studies and articles that help answer that question. In 2020, they identified that mature and old trees (in this case, trees ≧ 21” in diameter at breast height) only accounted for ~3% of all trees in the forest, but stored 42% of the aboveground carbon. This showcases two things: what little mature and old growth forests we have left in the region, and that those few remaining trees play a disproportionate role in storing carbon.

Our eastside forests are wonderfully diverse and complex! We have everything from the delightfully orderly and dry ponderosa pine forests to messy, moist mixed-conifer forests jam packed with biodiversity. But the complexity of these forests has often been seen as a liability – eastside forests have historically been left out of legislation and policy efforts because of their complexity, or prescribed a one size fits all “treatment” that should only apply to truly dry forests.

The Big Mosquito project on the Malheur National Forest is another example of mature and old trees being logged under current regulations, Photo credit: Daniel Howland.

There was an initial comment period in summer of 2023. Over a half a million people called on the Forest Service to protect mature and old growth trees! What’s being proposed now? 

In December 2023, the US Dept of Agriculture (of which the US Forest Service is part), issued a formal Notice of Intent to create a nation-wide Forest Plan Amendment. This means that the agency would essentially amend the language of all Forest Plans across the country at once to include “consistent direction to conserve and steward existing and recruit future old-growth forest conditions and to monitor their condition across planning areas of the National Forest System”. The specifics of this are still being solidified. 

This process will be done by Environmental Impact Statement, with a full proposal and draft EIS coming in May. In the interim, we are being asked to comment on a 7-page preliminary proposal. Here are a few highlights: 

  • Standards (mandatory) that will allow vegetation management (logging) in old growth forests. It names 5 instances where logging will be allowed, with the broadest and most concerning being “cases where it is determined that the direction in this amendment is not relevant or beneficial to a particular forest ecosystem type”.  This definition is far too ambiguous to be enforceable. 

  • A management approach that calls for each National Forest to create an “Adaptive Strategy for Old-Growth Forest Conservation” within 2 years of rulemaking – essentially, areas that should be prioritized for creating future old growth. The USDA suggests that areas placed in this category will not be binding or subject to legal challenge. 

  • Guidelines (suggestions), which are not mandatory and would apply to areas that don’t qualify as old growth. It encourages the agency to take proactive action towards increasing the amount and redundancy of old-growth conditions across the landscape. 

  • A goal of ensuring that all of this work recognizes and respects tribal sovereignty and treaties. 

There’s more to it. If you’d like to see the full proposal, check out the posting in the Federal Register. We hope you have time to submit a comment!


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