Report: Federal logging projects put 10 climate-saving forests on chopping block

Old multistory forest slated for phased clearcut within logging unit 72 of the Black Ram timber sale on the Kootenai National Forest in Montana. Photo by Yaak Valley Forest Council.


Report: Federal logging projects put 10 climate-saving forests on chopping block

Trees in Kootenai National Forest included on list of 10 threatened forests that help fight climate change

MISSOULA, MONTANA—Federal agencies are targeting mature and old-growth forests for logging despite these trees’ extraordinary ability to curb climate change and President Biden’s directive to preserve them, according to a new report spotlighting the 10 worst logging projects in federal forests across the country.

In the report released today, Worth More Standing, the Climate Forests coalition details federal logging proposals targeting nearly a quarter of a million acres of old-growth and mature forests overseen by the U.S. Forest Service and Bureau of Land Management. The report outlines “a pervasive pattern of federal forest mismanagement that routinely sidesteps science to turn carbon-storing giants into lumber” and calls on the Biden administration to pass a permanent rule to protect these big old trees.

“The best way to protect these carbon-storing giants is to let them grow, but our federal agencies keep turning them into lumber,” said Randi Spivak, public lands director at the Center for Biological Diversity. “The Biden administration can help curb climate change by permanently protecting mature and old growth trees. It takes centuries to make up for the carbon lost when these trees are chopped down and we don’t have that kind of time.”

The threatened forests are in Montana, North Carolina, Vermont, Wisconsin, South Dakota, Wyoming, Arizona, California, and Oregon.

In northwest Montana, the U.S. Forest Service’s Black Ram project will allow nearly 4,000 acres of the Kootenai National Forest to be commercially logged, including clearcutting more than 1,700 acres and logging hundreds of acres of centuries-old trees. These rare, old forests are champions of carbon storage, which reduces harms from climate change. Conservation groups sued to challenge the logging and road building project on June 30, 2022.

“The U.S. Forest Service is racing to eradicate ancient primary forests on our public lands in direct opposition to President Biden’s proclamation to protect old and mature forests as an effective means of battling climate change” said Rick Bass, chair of the Yaak Valley Forest Council. “Primary old forests in the proposed Black Ram project on the Kootenai National Forest can store up to 1,900 metric tons of biomass per hectare. The Forest Service is committing climate treason in broad daylight, racing to cut the last old forests in the backcountry—logging in the wet swamps, the one place fire doesn’t go. It’s climate madness disguised as greed.”

“This report demonstrates that logging remains a critical threat to mature and old-growth forests,” said Adam Rissien, ReWilding Manager with WildEarth Guardians. “The urgent need for meaningful protections could not be more evident and until then we will continue to challenge the Forest Service when the agency seeks to decimate habitat important for imperiled species such as grizzly bears and Canada lynx.”

Mature and old-growth forests hold enormous amounts of carbon. Preserving old-growth and mature forests is a meaningful, cost-effective measure the Biden administration can take immediately to mitigate climate change. Biden issued an Earth Day executive order directing an inventory of old forests and policies to protect them.

“Without a federal rule in place to restrict logging of these critical forest tracts, these mature and old-growth trees could be lost, along with the opportunity to make significant progress toward addressing climate change,” said Blaine Miller-McFeeley, Senior Legislative Representative at Earthjustice.

Also today, more than 125 groups sent a letter to the U.S. Agriculture and Interior departments requesting an immediate start to a rulemaking process to ensure permanent protections for mature and old-growth trees and forests across federal lands, while allowing for necessary measures to reduce wildfire risk. Large, older trees are more resistant to wildfires and studies show logging them doesn’t reduce the risk of climate change-driven fires.

“This report highlights what we have—but also what we stand to lose,” said Alex Craven, senior campaign representative at the Sierra Club. “Our old and mature growths are a natural climate solution, and we must protect these trees if we wish to tackle the intersecting climate and biodiversity crises.”

Scientists have pointed to forest preservation as one of the most effective ways to remove carbon from the atmosphere. U.S. federal forests sequester 35 million metric tons of carbon annually, a number that could rise steadily with new conservation measures.

Protecting older forests also safeguards clean water, clean air, wildlife habitat, biodiversity and recreational opportunities.

The full report is available here:

39 thoughts on “Report: Federal logging projects put 10 climate-saving forests on chopping block”

  1. The Colville NF qualifies as well. The Bulldog Timber Sale makes no bones about it – logging is for economic purposes and cutting trees up to 25” diameter. Back to big clearcuts – it’s the new normal. Twenty years of collaboration was just a ploy – the supe proclaimed is no longer needed – has served its purpose? Forest restoration is a hoax. The “new” Forest Plan is as bad or worse than the ‘88 plan. Thousand acre clearcuts okay? Really?

    Shame, shame, shame

    • Hi Tim, can you point me to the specifics of where the thousand acre clearcuts are located in the Bulldog Timber Sale? Also the conditions that allow cutting 25″ diameter living trees?

    • “This sale includes about 196 acres, of which an estimated 156 acres are marked and/or designated for cutting. The method of cut includes about 156 acres of shelterwood cutting utilizing ground based systems.”

      My understanding of shelterwoods is that they give a chance for regeneration to start, while leaving large trees (albeit not all of them) in place. I don’t know about NC, but in some places the old trees are likely to live longer with less competition, plus young trees would start to fill in and also suck up carbon. So I’m not sure about the carbon arguments in this case.

      I guess perhaps one person’s “eradicating old trees” is another person’s “making conditions so that old trees survive longer.”

      • All shelterwood methods have as a goal the eventual establishment of young forest and a commercial harvest of old trees.

        The Buck Project scoping states:
        Shelterwood with Reverses: Currently, 34 stands are being proposed for regeneration using a two-aged shelterwood with reserves treatment (refer to Table 1 for stand numbers and the area of environmental analysis). This would be implemented by commercial timber harvest, using ground-based skidding equipment. The majority of the timber would be cut and removed while approximately 10 – 20 square feet of basal area would remain through the next rotation. The residual trees would be left in clumps or dispersed throughout the stand, depending on site specific characteristics. The result of this treatment is the creation and maintenance of a two-aged stand in which one of the age classes is the regenerating trees and the other is the mature trees that remain after the harvest is complete.

        Importantly – ‘the majority of the timber would be cut’ and ‘approximately 10-20 sqft of basal area’ would remain. That doesn’t sound like many old trees surviving longer.

        The average DBH in the sale is listed as 16″. One leave tree at 16DBH is 1.4 sqft of basal area. So basically 10 leave trees at 16 DBH would be sufficient for remaining basal area requirement. My experience in Pisgah/Nantahala is 10-20 BA means about 20-30 trees per acres from 6-12 DBH. They leave very few old trees, typically only the snags.

          • Thanks, I did look through that glossary. There’s not a generic ‘shelterwood’ (the term used in the bid prospectus) definition available AFAIK. That’s why I referred back to the project archive for the description used in the EIS and analysis. It’s a peeve of mine that the USFS mixes terms and definitions liberally which makes it a challenge for a lay-person like myself to know what they mean or what they intend.

            • Yes, the FS is pretty bad about calling something a “shelterwood” or a “seed tree” harvest with reserves with it is really a clearcut with reserves – the residual trees are not needed for shelter or for seed.

              • Along with imprecise terminology there is the habit of using different terms in different documents. So, as example, a scoping might include descriptions of multiple treatments such as two-aged ‘shelterwood with reserves’ or uneven-aged ‘irregular shelterwood’ but then later when the stands are put out for bid the method of harvest is listed as ‘shelterwood’ and so you need to go all the way back to the scoping to see what treatment was assigned to the stand. Then you are left to wonder what was actually marked in the woods.

  2. I’ll bet every national forest has logging projects similar to these ten. Here on the Bitterroot National Forest, we have several, the biggest of which is the Bitterroot Front project that proposes 55,000 acres of commercial logging. It has gone through scoping, and they are now preparing an EA to show there will be no significant impact. 86 square miles of logging will have no impact! The push to get the cut out appears to be as powerful as ever.

  3. Final Buck Project EA is here:

    Page 5: “According to the Forest Service’s FSVeg Database, there are approximately 111 acres of early successional habitat (ESH – stands aged 0-10 years), 0.54% of the [20,638 acre Buck Project analysis area (AA)], on National Forest System lands in the compartments. A total of 14,222 acres of the woody vegetation is over 80 years old, which is approximately 69% of the AA.”

    The Buck Project approved 795 acres of silvicultural treatments to increase age class and structural diversity to provide habitat for nongame and game wildlife species that depend on early successional habitat for some or all of their life cycles. Treatments would be implemented over a five to seven year period, and would result in 4.4% of the AA in the 0-10 year age class. Older stands would continue to mature during the implementation period, with 86% of the AA projected to be aged 81 and older in 2028.

    Page 115 – Section 3.15 Climate Change: “It is not expected that [the project] would substantially alter the effects of climate change in the project area. The regeneration in the areas to be harvested would provide more structural diversity to the area and establish young, vigorous stands that may be more resilient to the changes in climate than those ages 61 and older.

    “[The project] would remove biomass as a result of timber harvest. This would reduce the amount of carbon stored in the treated stands. A portion of the carbon removed would remain stored for a period of time in wood products. Regeneration harvests would reduce existing carbon stocks at the harvest sites. The harvest of live trees, combined with the increase in down dead wood, would temporarily convert stands from a carbon sink that removes more carbon from the atmosphere than it emits, to a carbon source that emits more carbon through respiration than it absorbs. These stands would remain a source of carbon to the atmosphere until carbon uptake by new trees and other vegetation exceeds the emissions from decomposing dead organic material. The stands would likely remain a carbon source for several years depending on the amount of dead biomass left onsite and new trees’ growth rates once reestablished. As the stands continue to develop, the carbon source would change to a carbon sink. The strength of the carbon sink would increase until peaking at approximately 85 years of age (Vose 2009) and then would gradually decline but remain positive.”

    Pages 251 and 252 documents how the the Forest Service considered old-growth forest into project development and worked with stakeholder groups to evaluate impacts to stands with old-growth character.

    Because young forest was abundant when the Nantahala National Forest was established, areas with old forest became a focus of both research and preservation due to their scarcity, with increasing emphasis on management practices to conserve old growth and old forest stands since the 1980s. Thomas et al. (1988) Management and Conservation of Old Growth Forest in the United States; Mary Bird Davis and colleagues (1996) Eastern Old-Growth Forests: Prospects For Rediscovery And Recovery; Greenburg, McLeod, Loftis (1997) An Old-Growth Definition for Western and Mixed Mesophytic Forests; John Shaffer (2009) and Barton and Keeton (2018) Ecology and Recovery of Eastern Old-Growth Forests provide a good introduction on the importance of old growth forest. These areas are structurally complex, supporting a mixture of trees of various ages with large standing dead snags, a rich understory, large woody debris on the forest floor, and often include undulating terrain due to tip mounds from deadfalls which provide important micro-habitats. Structural variations within old growth stands support a complex assemblage of biological diversity, including herbaceous plants (Jackson et al. 2009), salamanders (Hicks and Pearson 2003; Davic and Welsh 2004), insects (Schowalter 2017), birds (Simons et al 2006), and lichen (Sillett et al. 2000).

    The Forest Service recognizes the importance of conserving old-growth forests. The National Forests in North Carolina was among the first national forests to adopt criteria to establish a network of small, medium, and large old growth patches in the Land and Resources Management Plan (LRMP) for the Nantahala and Pisgah National Forests (pages III-26 – III-28 LRMP 1994). To further support the identification and conservation of old growth forest on National Forest System lands in the South, the agency developed Guidance for Conserving and Restoring Old-Growth Forest Communities on National Forests in the Southern Region (USDA 1997).

    As the pace and scale of Forest Service timber management slowed beginning in the 1990s, young forest habitat on the Nantahala National Forest grew into older age classes, and like old forest in the 1930s, has become scarce. Based on the most recent Forest Service data, approximately 75% of the Nantahala National Forest is over 80 years of age. In ten years, that is projected to increase to approximately 80%. By comparison, approximately 1% is in the 0 – 10 year age class, and 0.9% is in the 11 – 21 year age class. As is the case with older forest, stands between the ages of 0 and 20 years, referred to as early successional habitat (ESH), are an important component of a healthy and diverse forest.

    Research by Askins (2001), King and Schlossberg (2014), Greenberg et al (2011a), and Swanson et al. (2010) documented the rising concern among natural resource scientists and managers about decline of the many plant and wildlife species associated with ESH. Small and medium sized forest openings, which result from silvicultural treatments and natural disturbances, “function as high-quality food patches by providing abundant fruit, and nutritious foliage and flowers that attract pollinating and foliar arthropods and support high populations of small mammals that, in turn, are prey for numerous vertebrate predators” (Greenberg et al. 2011b). Interior forest ESH openings also provide habitat that is important to the 14 species of bats native to the Southern Appalachians (Loeb and O’Keefe 2011; Brooks et al, 2017), songbirds (Bulluck and Buehler 2006; Chandler et al. 2012; Margenau et al. 2018), mammals (Litvaitis 2001) as well as to ruffed grouse (Dessecker and McAuley 2001), a wide variety of non-game bird species, and to many other wildlife species (Harper 2007, Labbe and King 2014).

    In addition to the predominantly even-aged forest caused by timbering between 1890 and 1930, the loss of American chestnut between 1904 and 1940 is another challenge facing managers of Southern Appalachian forests. Chestnuts were an important source of food for a wide variety of wildlife due to both the prevalence of the species, which is estimated to have made up 25% of the forest in some areas, and because unlike early flowering, wind-pollenated oaks and hickories, it bears insect-pollenated flowers that bloom well after the last frost date (Freinkel 2009). Diamond et al. (2000) concluded that nut production in Eastern forests declined 34% due to the loss of American chestnut which negatively impacted wildlife populations. In an effort to reduce further declines in nuts and acorns – – also referred to as hard mast – – the Forest Service implements management practices to promote the growth of oaks and hickories where appropriate.

    The abundance and frequency of acorn and hickory nut crops are affected by weather events during flowering and by the age of individual trees. Prolonged, heavy rains, high humidity, strong winds, and freezing temperatures when trees are flowering can reduce the abundance of hard mast, as can summer drought events (Mercker et al.). Hickories and oaks start producing nuts around age 40, with oaks maximizing acorn production between 40 and 80 years, while the prime nut bearing age for hickories begins around age 60 and continues up to 200 years (Burns and Honkala 1990). All species of oaks and hickories continue bearing nuts beyond ages 80 and 200, respectively, but not as prolifically. Accordingly, by designating stands for harvest treatments that will move stands into the 0 – 10 year age class now, managers are also planning ahead to ensure that some stands will be entering the 40 year age class as other parts of the forest leave the 71 – 80 year age class in the future.

    Natural disturbances can provide ESH, but those events occur at irregular and unpredictable intervals. Therefore, relying on natural disturbance regimes to establish ESH instead of scheduled management activities does not ensure ESH in desired amounts and locations. Natural mortality also produces ESH as trees approach their maximum ages, begin to die, and initiate another stand replacement cycle. According to the Forest Service’s Region 8 Old-Growth Team, the estimated maximum age of trees in the dry-mesic oak forest community is 240-348 years for white oak and northern red oak, while maximum ages in the mixed mesophytic forest community ranges from 225 years for yellow poplar, 372 years for sugar maple, and 412 for beech.

    As appreciable amounts of ESH from natural stand replacement cycles will not start occurring across the Nantahala and Pisgah National Forests for another 100 years or more, forest managers cannot rely on natural disturbance and senescence processes to produce ESH in the near future. Natural processes also do not assure a regular and sustained flow of interior forest ESH habitats across the national forest through space and time, and the age class and structural diversity ESH provides, as directed in the LRMP (page III-29). The LRMP also provides direction to provide ESH in conjunction with managing suitable timber land (page III-78) and to use timber management practices as the primary tool to create desirable habitat (page III-74).

    The Nantahala National Forest implements a variety of silvicultural treatments to comply with age class, structural diversity, and habitat management directives in the LRMP. Between 2010 and 2020, the average amount of all timber management activities across the Cheoah, Nantahala, and Tusquitee ranger districts was 326 acres per year. The average amount of regeneration harvests and commercial thinning treatments, which establish ESH, was 272 acres per year, which represents 0.05% of the forest. This also means that 99.95% of the Nantahala National Forest, on average, does not receive regeneration treatments in any given year. Operating only in parts of the forest approved for active management, it would take over 976 years for managers to work across the entire forest at 272 acres per year, a pace that is approximately twice as slow as the natural life expectancy of the longest lived trees in the mixed mesophytic forest.

    • The argument for leaving trees in the ground is fundamentally that they are storing carbon NOW and the amount of carbon they store currently and will continue to sequester annually is vital to the goal of reducing atmospheric carbon overall. At some point in the future, that point being >40 years at minimum, the stand may again be sequestering carbon at a similar rate to what the stand sequesters today. But, it’s going to take at least 80 years for the new stand to store in aggregate as much carbon as is ALREADY stored. Meanwhile we’ve wasted 80 years just to end up even in the net carbon equation. Do we have that much time? The whole argument/analysis in the EA about source and sink is non-sensical to me. The problem is that globally there are too many sources and not enough sinks. Turning a sink into a source for 40+ years is not a good decision IMHO. That it costs a lot of carbon emissions in the process (road building, logging machinery, transportation, milling, etc…) makes it an even worse decision.

      • Of course, we can ‘hope and pray’ to ‘Gaia’ that she doesn’t spite us with huge wildfires, because current humans are ‘bad’. It is important to factor in all the site-specific conditions and the certainty of more intense wildfires, both human-caused and ‘naturally-ignited’.

    • “Based on the most recent Forest Service data, approximately 75% of the Nantahala National Forest is over 80 years of age. In ten years, that is projected to increase to approximately 80%. By comparison, approximately 1% is in the 0 – 10 year age class, and 0.9% is in the 11 – 21 year age class.”
      This is not helpful without also providing the natural range of variation. Also without providing the context required from other lands – do other ownerships in the same ecosystems provide sufficient ESH?

      “the rising concern among natural resource scientists and managers about decline of the many plant and wildlife species associated with ESH”
      Which of those have been designated as species of conservation concern due to risk of loss of viability on the forest? Is there also diminishing concern about decline of the species associated with old growth?

      • “Do other ownerships in the same ecosystems provide sufficient ESH?”

        Short answer is no. Private tracts do provide some young forest habitat, but it is largely confined to lower elevations – national forests in the Southern Appalachians, including the Nantahala NF are generally on ground that wasn’t well suited to row crop agriculture / subsistence farming. Young forest habitat on private lands bordering the Nantahala NF is generally fragmented, isolated, and/or adjacent to suburban development. Page 7 of the EA provides links to research that documents the importance of interior forest ESH.

        “Which of those have been designated as species of conservation concern due to risk of loss of viability on the forest?”

        Golden-winged warbler and 14 species of bats – Page 7 of the EA. All native forest dwelling species are of conservation concern in our ever-urbanizing / suburbanizing / fragmented noisy 21st Century South. Rare / absent habitats – – young and old – – are a management priority.

        “Is there also diminishing concern about decline of the species associated with old growth?”

        No. That’s one reason why the FS established an old growth network and special management areas and has management direction that limits the amount of ESH that can be implemented through active silvicultural treatments (Page 6 of the EA).

        • Golden-winged warbler (GWW) is consistently used as a species of concern and justification when establishing ESH. It’s a noble cause, but I’ve never seen any data suggesting that GWW use the ESH created by timber harvest. If the USFS does post-harvest analysis I’d love to see it. In the case of the Chunk Gal sale the closest GWW sightings of record (ebird) are 5 miles NNE on US64 and 5.8 miles NNE near Rock Gap. The Golden-winged Warbler Working Group (GWWG) recommends “Focal Areas: Management should be concentrated in the Appalachian Conservation Region, … < 5 miles (preferably < 1 mile) from known Golden-winged Warbler populations and 70 years other than 10 acres @ 30 years (1/4 mile away) and 22 acres @ <10 years 1/2 mile away (Fatback Project). It would be interesting to survey the ESH for GWW nearby there. Both these areas are in proximity to larger open lands, while Chunky Gal is far away from any other openings. The BMP published by the GWWG notes that "Within large management complexes, 15–20% of area should be maintained in a shifting mosaic of ESH, resulting in a diverse mix of forest ages and types necessary for foraging, post-fledging habitat, and needs of other wildlife." While that's an argument for ESH, the idea of turning 15-20% of forest land into ESH is pretty extreme. And I am unaware (though hopefully could be informed) that USFS maintains such a mosaic by post-harvest treatments. In the Bald Knob Sale (Pisgah District, 2018) two units were marked and cut as 'GWW treatments'. That's a significantly different treatment than shelterwood, leaving more trees overall and a less defined edge, both of which are recommendations of the GWWG. Shelterwood with 10-20 BA is significantly different than that from what I've observed. At Bald Knob, 2+ years later the shrub layer is already dominant in the GWW stands, I have no idea if there is any plan to maintain those stands for GWW in the long term. It's not a one-off treatment, it's a long term investment.

          • According to Cornell University:

            The Golden-winged Warbler is a sharply declining songbird that lives in shrubby, young forest habitats in the Great Lakes and Appalachian Mountains regions. They have one of the smallest populations of any songbird not on the Endangered Species List and are listed as Near Threatened by the IUCN. An estimated 400,000 breeding adults remain—a drop of 66% since the 1960s. In the Appalachian Mountains the situation is even worse: the regional population has fallen by 98%.

            Causes of Decline
            Breeding-ground habitat loss. Historically, natural disturbances, such as wildfires and flooding from beaver dams, created a patchwork of shrubby openings amid a largely forested landscape. But today early successional habitats are declining due to forest regeneration, changes in agricultural and forestry practices, and increased human development.

          • Please see page 7 of the Buck EA. “To help expand breeding and foraging habitat for the GWWA, the Golden-winged Warbler Working Group recommends management practices that produce ESH be conducted within the 18 defined focal areas *OR* less than five miles (preferably less than one mile) from known GWWA populations and less than one mile from other ESH patches, in elevations generally above 2,000 feet (varies with site-specific context) (Best Management Practices for Golden-winged Warbler habitats in the Appalachian Region – link below. *EMPHASIS MINE*). In a letter pertaining to the Buck Project dated May 10, 2019, biologists with the North Carolina Wildlife Resources Commission stated that the optimal elevation range for GWWA in the Buck AA is above 3,000 feet (NCWRC 2019). Positive land cover associations include 60% – 80% forest cover, 15% – 55% shrub-herbaceous cover, shrub-forest wetlands, and pasture-hay fields. Configuring habitat units in proximity to existing breeding populations is recommended because there is a high potential for successful positive response by golden-winged warblers (Roth et al. 2012). Two-age cuts typically begin being used for breeding habitat one to two years post-harvest, and the GWWA will use these areas for several years as vegetation matures and until the canopy closes.

            “The Buck Project AA is located within one of the 18 focal areas defined by the Golden-winged Warbler Working Group. Stands in compartments 104, 106, 107, 108, 109, and 110 proposed for two-age regeneration treatments in the action alternatives analyzed in detail in this EA are located above 3,000 feet in elevation and are all located within five miles of a GWWA cluster along West Old Murphy Road near U.S. Highway 64 (NCWRC 2019 & 2020). Stands in compartments 106, 107, and 109 are between three to 3.5 miles from the known GWWA populations at West Old Murphy Road. Some stands in compartments 106 and 107 fall within a GWWA Priority Area based on further analysis of the broader GWWA Focal Area. All stands proposed for treatments in these compartments have the potential to provide ESH for GWWA after implementation consistent with guidance provided in the Best Management Practices for Golden-winged Warbler Habitats in the Appalachian Region.”


            The North Carolina Wildlife Resources Commission has seen favorable response from golden-winged warblers in two age silvicultural treatment units on the Cheoah Ranger District in Graham County. The FS and NCWRC expects similar favorable response from the Buck Project. The FS is working with NCWRC biologists on establishing permanent grass/shrub openings for long-term GWWA habitat areas. Please refer to literature cited previously for the need to have oak / hickory regeneration so that there will be hard mast production in some areas of the forest when stands enter the 41 – 80 year age classes.

            • I’m familiar with the BMP by GWWG. That’s why I mentioned the known sightings are > 5miles from the stands in the Chunky Gal sale. Stands 104/13, 104/18, and 104/19 are > 5 miles, not less than as stated in the EA. The BMP defines macro landscape as “within 1.5 miles of a habitat patch” and mentions birch as part of the tree community. Birch is shown on the prospectus as a species for “Required Removal at Fixed Rates”. Silverbell is also to-be removed although its flowers are a wonderful source of bugs for various warblers.

              I’m glad to hear that NCWRC has seen positive response to two-aged treatments, I found an article about it,

              • Data on the proximity of GWWA clusters relative to treatment units in the Buck Project came from the NTMB biologist for the NCWRD who tracks GWWA populations. Also, per communication with her, the proximity to known breeding pairs is key to success outside the 18 focal areas, but is less important a factor within focal areas.

        • Thanks for that info. I know the revised forest plan hasn’t been adopted yet, but I assume this project was designed to achieve the plan’s desired conditions. It’s a little unclear but Table 3 in the plan seems to be the desired conditions for age classes. For “Young Forests, (including early successional conditions),” the desired acreage over the long-term is “60-90K (70% above 2500’).” Can you (or the EA) tell me how the current condition compares to this (overall and at high elevations)? Is there a more specific desired condition somewhere for the 0-10 and 11-20 age classes?

          The EA states on p. 108: “The LRMP states at page III-31 that the minimum amount of ESH required for MA 3B is 5% and the maximum allowed is 15%, and is not to exceed 10% in MA 4D.” This appears to be a reference to the current plan, but I didn’t see anything similar in the revised plan?

          By the way, I’ll just point out (again) that the revised plan is wrong when it says that the desired condition is not the NRV. Between the §219.9 requirement in the Planning Rule to restore ecological integrity and the definition of ecological integrity to mean NRV, desired conditions must be within NRV. So I’d like to know what the NRV is for these key ecosystem characteristics in the relevant ecosystems.

          • The Buck Project was proposed, analyzed, and released under the 1994 plan. The revised plan for the Nantahala and Pisgah National Forests has different standards. I recommend you reach out to the plan revision team at the Supervisor’s Office in Asheville to get answers to your questions about differences between the 1994 and the 202? plan relative to interior forest ESH and NRV. I was minimally involved in the revised plan process and now work on a different national forest in a neighboring state.

  4. It’s all about balance, Nick. There’s a demonstrated need for age class and structural diversity and
    young forest habitat to maintain wildlife diversity in the Southern Appalachians. Currently 4.9% (approximately 26,000 acres) of the Nantahala National Forest is in the 71-80 year age class. Those stands will move into the 81-90 year age class – – the age where carbon sequestration peaks – – during the same time period that the Buck Project will add 795 acres of critically important and rare early successional habitat to the Nantahala National Forest. From a carbon balance perspective, the rate at which the Forest Service is implementing these highly selective and well scrutinized treatments is more than offset by the aging of the stands in the 11-80 year age classes.

    • Here is the argument presented in the report: “The Forest Service claims it must cut healthy, older trees to create new, young forests needed by certain species. But young forests are created by reoccurring natural disturbances and can also be created in areas already degraded by logging.” You have argued that natural disturbances can’t do the job they used to (always a suspect sounding argument), but was there an alternative considered that would use previously logged areas for this purpose?

      • The bulk of the forest in the Buck Analysis Area is second growth forest in the 71-90 year age classes. The stands selected for silvicultural treatment fall within that age – not necessarily old forest, and stands already affected by past logging events. My argument is not that natural disturbances can’t do the job they used to do. It’s that with the bulk of the Nantahala National Forest in the 81-110 year age classes due to timber extraction between the 1890s and 1930s, and life expectancies of trees in the mixed mesophytic forest 230 – 340 years, appreciable amounts of interior forest ESH won’t result from natural mortality for at least another 100 years. Given that a secondary goal of silvicultural treatment is to produce stands with an oak / hickory component to provide hard mast, and given that hard mast peaks between ages 40 – 80 for oaks and 40 – 200 for hickories, cutting some stands in the 81-100 year age classes will produce more vigorous hard mast production for wildlife 40 years post-treatment. Finally, all stands selected for silvicultural treatment in the Buck Project were logged previously.

  5. Curious about what is going on with nearby and intermingled pvt lands as to early successional habitat? FS can’t ignore the larger context in which Nantahala exists. Did FS assess this? And, as important as this element of young forest habitat is, did the FS carefully explain its rationale in weighing competing values of old forests (relatively rare in the East) and their carbon merits?

  6. “Curious about what is going on with nearby and intermingled pvt lands as to early successional habitat? FS can’t ignore the larger context in which Nantahala exists. Did FS assess this?”

    Nearby private land is largely confined to lower elevations. Tract sizes are trending smaller as old farms are broken up for building lots to meet the demand for second homes and retirement homes. Yes, the Forest Service considered the impact of changing land use patterns on private property.

    Please see pages 5 – 10 of the EA and sections of Chapter 3 (particularly Section 3.2 – Communities, Special Habitats, and Management Indicator Species; Sections 3.3 – 3.6 – biological resources; and Section 3.15 – Climate Change) for the explanation of the rationale / weighing values of old forests in context with the need for adding a small amount of ESH to the analysis area.

  7. Jon and SO.. when I hear “natural disturbances” and “we need oaks” in the same discussion, I think “fire”. Then I think “maybe fire can’t do the job it used to” because people live there mixed among the forest. SO – what are the “natural” disturbances and how were they influenced by Native Americans in that area? Jon- I’m even wondering what is. “Natural” disturbance in the Rockies.. those done by Native Americans or pre?

    • Natural disturbances in Southern Appalachian forests include: gap phase regeneration from natural mortality, lightning strikes, etc.; insects and disease; wind storms (derechos and occasional tornadoes); flash flooding from heavy rains and hurricanes; lightning fire; and pre-contact and historic Native American burning. As well as the very occasional landslide or two, which are quite uncommon. Managers still encounter evidence of fire influenced stands which retain some primary forest trees, particularly on south and southwest facing ridges. So despite weather patterns that bring frequent rains and high humidity much of the year, these forests did experience stand-replacing and stand-maintaining fires, both from “natural” and Native American ignition events.

      Despite having relatively large blocks of land for Eastern forests, all of the national forests in the Southern Appalachians are intermixed with private tracts, resulting in wildland-urban interface situations that affect the locations conducive to “thermal thinning” with prescribed fire. Managers are making good progress increasing the Rx burning programs and work closely with TNC, Fire Learning Network, Consortium of Appalachian Fire Managers & Scientists to ensure that the frequency and seasonality of Rx burning achieves desired outcomes. Smoke management, WUI considerations, protecting at-risk species, particularly bats in the Myotis genus, limit burn locations and windows. Several FS units are also experimenting with multi-day “backcountry” Rx burns with provide a more stochastic burn mosaic and disperse the smoke load over two to three days before a rain event.

        • Agree. With regard to “natural,” it’s not my favorite term (including in NRV), but was used here by both the report opposing the project and the project proponent. I’m ok with the term including human use of fire because that is a disturbance that ecosystems have adapted to, and become resilient to, for a long time.

      • Great summary, but I do not agree with this statement, “As well as the very occasional landslide or two, which are quite uncommon.” Slides are becoming common as we have more extreme events (climate-change related). I don’t think the USFS has a good handle on remote areas where old roads, some system some just ‘existing corridor’, are not able to withstand 4-8″ of rainfall at a time or especially multiple times in several days. Western NC gets multiple 25 or 50 year events annually. Just this week there was extensive damage in the Smokies after 12-14″ of rain over a few days. The roads damaged by Fred last year have already begun to deteriorate. Last year after Fred I went upstream from several damaged roads in the Pisgah District and found slides. A new USFS road at Bald Knob Branch washed out, was repaired, and nearly slid away again last month.

        • Landslides, not road slides. Landslides are pretty uncommon, but part of the “natural” cycle. Road slides are not natural, and like you observed, seem to be increasing in frequency as the FS road network ages.

  8. The Telephone Gap project on the Green Mountain National Forest was also listed in the Report. Here’s some info on that:

    “The really interesting thing about the Telephone Gap project, the reason that we are concerned about it and that it’s featured in this report, is that the Telephone Gap project is about the oldest block of forest land on the Green Mountain National Forest.” A little over half of the project area is more than a century old, some of it quite older than even that. “There’s not a lot of it, but there’s more here in this landscape than there is in Vermont in general,” said Porter.

    According to Porter, the justification for cutting older forests has been to create what’s called early successional habitat. Some question whether more of this type of habitat is needed, and whether it’s worth losing older forests to make it.


    Here is some info on another identified project – the Fourmile Project on the Chequamegon-Nicolet National Forest.

    “Olson said more than half of timber stands set to be logged are 80 years and older. Wisconsin has nearly 17 million acres of forest land and roughly 1.5 million acres in the Chequamegon-Nicolet National Forest. State data shows old-growth forests that are 120 years or older account for a little more than 1 percent of timberland.

    In an environmental assessment, the U.S. Forest Service said the Fourmile project would help meet demand for wood products, increase public safety related to wildfire risks and enhance recreation. The review said the area proposed for logging has an overabundance of older trees, saying too many could lead to reduced resilience to insects and disease or a decline in certain species.”

    • Can somebody explain that last sentence that justifies logging by claiming that too many old trees is a problem. Yes they are likely to get sick and die; that’s not an ecological problem. Neither is “a decline in certain species” without a lot of further explanation.

      • Jon: I have no idea what an “ecological problem” might be, but I do know that dead trees can form a significant risk of burning — always bad for wildlife and air pollution — and falling onto things. A firefighter just died in western Oregon from a dead falling tree, as a recent example. I lost my best car ever by this method, too, so safety and risk are important factors. Plus, dead trees are ugly to look at for many of us. Strategic thinning can greatly prolong the lives and appearance of big, older trees, and good for wildlife, too.


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