Here We Go Again: The Mature and Old Growth Federal Register Notice, Public Comment and Webinar

It’s Friday again and time to talk about MOG (mature and old growth forests) while thinking about white oak for casks.

Here are the questions in the FS/BLM comment request, you can find the Federal Register Notice here.

Input Requested. The USDA Forest Service and the Bureau of Land Management, DOI, are seeking input on the development of a definition for old-growth and mature forests on Federal
land, and are specifically requesting input on the following questions:

• What criteria are needed for a universal definition framework that motivates mature and old-growth forest conservation and can be used for planning and adaptive management?

• What are the overarching old-growth and mature forest characteristics that belong in a definition framework?

• How can a definition reflect changes based on disturbance and variation in forest type/composition, climate, site productivity and geographic region?

• How can a definition be durable but also accommodate and reflect changes in climate and forest composition?

• What, if any, forest characteristics should a definition exclude?
Additional information about this effort, including a link to the recorded webinar, can be found at:


During our discussions of specific projects, what I found interesting about the “Mature and Old Growth” or MOG for short effort, is that in 2012 the Forest Service decided that it would manage for NRV (yes, subject to all kinds of wordy parameters, this hasn’t found its way to court yet and may not), so Forests spent all kinds of effort to analyze what NRV might look like (as I called the 2001 Planning Rule, a “full employment program for historic vegetation ecologists.”) To a greater or lesser extent informed by what Native Americans may have done with fire during various time periods. Nevertheless, here we are with forests trying to manage forest for NRV (and various wildlife species) and some projects designed for those purposes have come under attack for cutting “mature” trees. Was NRV just a analysis dead end, if the target is now “mature forest conservation”? Could everyone have just skipped that side trip? Is biodiversity for species (say oaks or western white pine, not to speak of wildlife) that require openings (and previously depended on fire) now less important than “mature forest conservation”?

Here’s my take. Certain ENGO’s have never supported cutting of trees (“logging”) for philosophical reasons. For a while, species (such as spotted owl) were a good horse to ride in pursuit of that goal. Now they are riding the “carbon” horse. However, the carbon horse has issues.

For example, as we have pointed out, old trees die. Even “mature” trees, due to bugs, fire, etc. Many people, including me, have said this. There’s even now a scientific study that says “trees may burn up or die in California and that wouldn’t be good for carbon.” I’d put my carbon money on direct air capture technologies, or if it had to be trees, then reforestation for carbon as well as meeting other objectives.

Perhaps trees and forests are going to die from climate change, so there’s that also. Climate change (may be) killing trees and forests. At least that’s the tenor of this WaPo story today. “oldest trees may not survive climate change”. Of course, these particular trees are also in one of the toughest areas for trees to start with. Time for a field trip to your local bristlecones. But if we think climate change will kill our current forests, maybe that’s not the best carbon bet.

I’m sure given all the smart people in the Forest Service, they will figure something out that makes sense. What will be more interesting is how the politics will play out across USDA, which tends to have a rather common-sensical perspective, versus the more political DOI -perhaps more beholden to the key ENGO’s, and perhaps more closely monitored by the climate folks in the White House. And the question of what an Executive Order can do vs. MUSYA and even the Planning Rule. And, of course, the timeframe for analysis, and rulemaking (?) and .. elections. Should be interesting to watch!

I wrote a song parody about the Old Growth issue for the Old Growth person’s (can’t remember his name) retirement party sometime in the 90s.. I think it was an issue in HFRA. It was to the tune of “Maria” from Paint Your Wagon.

Way out West we’ve got a place
With big and fat and old trees
We’ll draw a line around the place so they won’t become..sold trees.

Reserves.. Reserves.. we call those areas.. reserves.

But old trees die and then fall down
And we’ve got premonitions
But we’ll do fine, we’ll move the lines, or change the definitions.

If anyone’s interested in the history of old growth analysis in the 90’s, you can google “old growth forest service 1990” and find some regional documents.

39 thoughts on “Here We Go Again: The Mature and Old Growth Federal Register Notice, Public Comment and Webinar”

  1. While both sides can agree that protecting older forests that we have today doesn’t ensure those forests will be there in the future, especially because drought and fire severity continues to increase due to increases of carbon in the atmosphere. But where both sides will continue to disagree is the amount of land that’s protected from logging.

    Keyword not mentioned here is “recruitment.” It’s not enough to just protect older trees and forests, but we also need to protect areas most likely to turn into mature and older forests in decades to come. This means protecting the very best growing sites that are least likely to be destroyed in future fires, storms and droughts. And that’s in addition to protecting existing stands of already mature and old growth trees.

    In the Northwest Forests Plan (NFP) we created refugia or late successional reserves (LSRs) that were well distributed across the landscape for long-term old growth recruitment while also protecting existing old growth stands. And ever since the USFS and BLM have continued to try to log these lands in the name of improving the forest, which is a total lie most of the time.

    A failing of the LSRs distributions was they didn’t target the very best growing sites for long term forest survival, but were more interested in cutting the baby in half and giving away prime growing sites as matrix or sacrifice zones that could continue to be destroyed by logging.

    What’s more, the existing location where old growth trees and forests still stand were not chosen because these sites were superior, but quite the opposite. Again and again timber sale planners passed these sites over because they weren’t as profitable to operate in as other sites that are now entirely wiped out and turned into unsustainable tree farms.

    So after more than a century of near unfettered clearcutting we’re still looking at maps that have been defined by those who destroyed the forest rather than those who want to protect it. That legacy of wrongly placed old growth reserves means these areas won’t last as long as areas that are placed where forests are capable of thriving for as long as possible.

    Most of the this could be addressed via the NFP’s Aquatic Conservation Strategy (ACS) of stream buffers, but we’d need to massively expand the buffer beyond just perennial streams but buffer where the majority of all Salmon killing silt comes from, which is perennial streams, steep slopes, seeps and springs, unstable areas and headwalls.

    Take 1/3 or more of all currently unprotected riparian areas out of production and you’ll successfully protect older forests for centuries. Catch is these are also the best growing sites and the sense of entitlement to log these lands has to be destroyed or the legacy of the USFS and BLM will continue to be a legacy of a future that is so destroyed older thrive thriving forests won’t be positioned to be around for very long.

    • I live next to the Okanogan-Wenatchee National Forest on the east side of the Washington Cascades. I see LSRs as folly. Passive management of forests long departed from historic conditions is nothing less than assured destruction. I am all for saving old growth trees by logging out many of the young trees surrounding them. Old to some people means a century, to me it means born before 1855, that’s when treaties upended Native Americans.

  2. Why is pursuing engineered solutions bad? I have pitched that for 20 years along with cutting carbon emissions, exploring alternative energy (though solar panels and windmills are far worse for wildlife than Kentucky coal) and ALWAYS had my head bitten off by the climate mafia.

    • Something I saw elsewhere “Eveen if we succeeded in reducing the cost of carbon removal to $100/ton, which would be a major technical achievement, it would cost $22 trillion to reverse warming by 1/10th of 1 degree Celsius.”

      • 2ndLaw: Why would the “reduced cost of carbon removal” be $100/ton? “Carbon removal” used to be called “logging” and produced a profit — not a cost. By further taking this nonsense into the trillions of dollars and then somehow magically transforming those trillions into tenth-degrees of Global Warming . . . no wonder this information comes from “somewhere else.” The question is why you are posting it here? No question as to why you are using a pseudonym, though.

        Engineering solutions clearly needed — and same with critical thinking skills. Passive management and political indoctrination are not working.

        • “Carbon removal” is referring to removing it from the air, which trees would do for free (if they were not “logged” to produce a profit).

          • Are trees “logged” “to produce a profit” or to provide building products that people use to build homes and other buildings?
            In the same sense, are windfarms established to “produce a profit” or to produce energy that people use?

              • Trees are felled and then logged for a wide variety of reasons. Aesthetics, firewood, wildlife habitat enhancement, reduction of competition or ladder fuels, building materials, totem poles, etc. If it is done for commercial reasons, and efforts are successful, then a profit is produced. Logging can/should also be an important option for managing a forest for carbon, but that is one of the dumbest ideas I know of. Why would anybody even do that? To control the weather? Seriously?

              • Many restaurants struggle to stay in business and think they’re lucky if they can pay their bills. So I think it depends on how you define “profit”. If you’re not paying the bills, it would be hard to stay in business for long. What if you reinvest profits?

      • The IPCC report, “Climate Change 2021: The Physical Science Basis,” states that “Global surface temperature will continue to increase until at least mid-century under all emissions scenarios considered.” And “Many changes due to past and future greenhouse gas emissions are irreversible for centuries to millennia, especially changes in the ocean, ice sheets and global sea level.”

        As we work to reduce emissions and the atmospheric CO2 concentration, adaptation is crucial. With forests, we can either do nothing or we can manage for resilience to the coming changes. Yes, we ought to protect mature and old-growth stands, but without active management, where appropriate, they aren’t likely to survive.

    • My view: because there is the “climate problem” and decarbonization. Decarbonization is something you set engineers to fix with no drama (engineers tend to be low on drama).
      The Climate Problem is a Christmas tree for everyone to hang their favorite ornaments..
      Reducing consumption (usually other peoples’, not the writer’s)
      Getting rid of capitalism
      Telling developing countries and rural areas how to behave
      Giving up cars (even if electric) public transportation is always better
      Living outside cities
      And more.. can’t think of them all right now. As you can see some of these are only tangentially related to climate.
      If it sounds a bit like Puritanical busy-body hood, well I think there are elements of that.

      • Well, climate change is the problem and decarbonization is one of many possible solutions (like the others you listed). That’s not an argument for decarbonization. There is nothing unusual about people using any opportunity to promote their own agenda. Companies that make money with their engineers would use this opportunity to promote their profit agenda. None of this helps me get a clearer picture of the best solution.

        • Jon: From my research on the topic — and in concordance with many other scientists with far more impressive credentials than my own — “climate change” doesn’t appear to be any more of a problem than in any other time in the past, despite unsettling claims by climate modelers the past 40 years. The proven “best solution” has always been the same — “adapt.” The fear-mongers that have profited by these manufactured fears are no different than medieval priests threatening hell and damnation for non-tithers, in my opinion and experience.

          • I’ll let everyone else judge the value of your opinion based on their understanding of climate science. But I would like you to explain how and why climate modelers are “profiting” (presumably via some fraudulent activity).

            • Climate modelers are profiting by regular paychecks, job security, promotions, tenure, paid vacations, per diem allowances, and other perks, until they get retirement pay. Almost all paid for by taxpayers — and for those that want it, there is also media attention if their “predictions” are morbid or sensational enough.

              Pretty obvious — figured you would know that. I would call this set-up a racket, and not necessarily fraudulent (not sure why you would presume that), unless the modelers are being dishonest rather than honestly believing the results of their print-outs. Just like the medieval priests: believers, non-believers, and charlatans.

  3. NRV v. CO2? I don’t see that happening very often. If older trees are best for carbon conservation, we should try to retain as many of them as possible. In most places that would be consistent with NRV because in most places there’s not a problem with there being too many old trees in comparison to NRV. And could having “too many” old trees ever be a problem? There might be a few places where there’s not enough young trees, but you can make more young trees by reducing “immature” trees rather than older trees. Everybody is happy. (Except maybe those who want to make money logging big trees.)

    The real debate should be about how to “retain” older trees for as long as possible. Specifically, when (if ever) is it the best non-economic decision (carbon, ecological integrity) to remove big trees to do so. (I’m generally assuming that old trees are the focus here, but if there are big trees that are not “mature,” but still contribute to the desired conditions, that would also need to be considered.)

    • But in our NC example, there was a biodiversity concern with too much old closed forest. Isn’t biodiversity part of NRV? I thought it was species, processes, etc., but is it just vegetation?

      • I thought the NC example was about not enough young forest, and removing old closed forest was one solution. I don’t think we heard whether the existing amount of old closed forest was greater than NRV. (I’m skeptical about whether there can be a problem of “too much” old forest unless there is also “not enough” of something else that leads to ecological/species risk.)

        • I think they were talking about making openings for some species. So I don’t think that there was “too much” old forest but there was “not enough” of a certain composition that a wildlife species needs.

  4. Back in the day, say 1500, one could walk from the Mississippi River to the Atlantic Ocean and stay in M/OG pretty much the whole way. How did we get to Sharon’s point that “there was a biodiversity concern with too much old closed forest.”? With respect to eastern NF’s in particular, which exist in a larger context of “no forest/young forest/fragmented forest/logged forest”, how is it essential that they skew to creating more early successional forest as a higher priority TODAY than optimizing forest carbon? What is truly RARE in the east? OLD GROWTH of course. Biden’s Earth Day Ex Order should be seen by federal agencies as a clarion call to stop ridding the landscape of old trees and start keeping them.

    • Jim, I don’t know that that’s true at least for the southern US check out this very interesting article on fire history.

      I see you have a couple of different arguments
      (1) it used to be that way. Well not exactly.
      (2) Forests should be managed to optimize forest carbon, over other interests, say species. That may be your priority but other people have other priorities.
      (3) We should save it because it’s rare, regardless of how it used to be.

      But the problem is that I don’t see the FS “ridding the landscape of old trees” and I think they are mostly keeping them. The exceptions seem to be small unless you start defining old as say 80 or so. So I think it’s really important to use a consistent definition.

      • If the issue is when and how should we allow exceptions, let’s talk about what would be adequate justification. I could accept a situation where there is an at risk species that needs the habitat for viability and removing old trees is the only feasible way of providing it. (And I would like to see that argument made at a forest plan level rather than project by project.)

  5. Sharon “I don’t see the FS “ridding the landscape of old trees” and I think they are mostly keeping them”

    Check out FB posts by People For Sustainable Logging in BHNF then we can talk

    • Facebook???

      Why anyone still chooses to utilize that data mining ethical scourge utterly baffles me.
      Have another source, Jim?

      • Eric: I’m pretty sure this type of questioning is called “sealioning.” Not too sure if that’s a good thing or bad thing, though.

        • Sealioning (also sea-lioning and sea lioning) is a type of trolling or harassment that consists of pursuing people with relentless requests for evidence, often tangential or previously addressed, while maintaining a pretense of civility and sincerity (“I’m just trying to have a debate”), and feigning ignorance of the subject matter.
          I’m not buying it, Bob. But for you…

          Smug: having or showing an excessive pride in oneself or one’s achievements

    • Ah… you’re talking about overstory removal in the Black Hills.

      That’s about cutting the old-er trees. So are you saying that any project that involves trees above age x should not occur because it thereby “rids the landscape of old trees?”

  6. I worked on the BHNF from 71-77, and remained closely involved as Deputy Chief and in retirement. 2 step shelterwood involving overstory removal was in use at the time and up for pretty heated debate even then as “extreme”. Can we agree much has changed in past 50 years advancing more holistic forestry? Not gonna get into all that. But when you do commercial thinnings of small sawtimber (I’m fine with that) to improve beetle and fire risk, but then come back about 10-15 years later and whack all that beautiful “old-er” sawtimber that is just beginning to build on the investment of good, solid forestry… well, I cry foul. There is no rule that you need to remove overstory when all you have is seedlings. Especially when FS research paper has revealed that standing volume has declined 50% in past 20 years due to fire, beetles, and unsustainable harvest levels (Res indicates annual harvest needs to be reduced about 60%!). Time to apply the brakes. I have no objection to overstory removal, retaining several legacy trees for OG and when residual stand is well-established pole timber bearing some resemblance to a forest. Recent harvest levels and practices on BHNF are appalling. That aroma? Pure politics.

  7. There are a couple of important statements of current Department policy in this memo that are worth highlighting. Here is their framing of the problem (note it does not include “passive management” or logging as a threat):

    “More than a century of deliberate wildfire suppression strategies from Federal and state agencies and others have left many forests significantly different from their historic conditions and vulnerable to uncharacteristic and catastrophic fires. The climate crisis is exacerbating these unhealthy conditions through widespread drought, insect and disease mortality, and an increase in extreme weather events. At the same time, the number of people living in or near wildland forests has increased dramatically, creating additional challenges in protecting lives, communities, infrastructure, and natural resources from wildfire.”

    “A primary threat to old-growth stands on national forests is no longer timber harvesting, but rather catastrophic wildfire and other disturbances resulting from the combination of climate change and past fire exclusion.”

    Also an argument against arguing about it in the abstract: “The appropriate science-based practices that will sustain resilient forests and stabilize forest carbon are place specific.”

    (Note that this framing is around “stands,” and elsewhere “acres,” so this is not explicitly about individual trees, but this unit scale question should be addressed.)

    I also wanted to highlight the language related to forest planning:

    “For land management planning, this should include recommendations for how to support the explicit consideration of carbon stewardship optimization and climate adaptation in defining desired conditions, and how to evaluate whether certain National Forest System lands are appropriate for designation as “not suitable for timber production” pursuant to 16 United Status Code (U.S.C.) 1604(k), Development of land management plans, based on those considerations.”

    Also relevant to planning:

    “Wildlife Habitat and Connectivity.
    In collaboration with the Farm Production and Conservation Mission Area, state and tribal wildlife agencies, and other important partners, develop recommendations for increasing and replicating successful cross-jurisdictional partnerships and programs to foster increased biodiversity, enable wildlife migration, and enhance habitat integrity and resilience.”

  8. I also watched the webinar today (what better to do with a 100º day). Sharon asked what a “framework” for a “definition” would be. What I heard as an answer sounded like “FIA.” That is that they are going to use that data for identifying MOG (and not use anything else) so the question is what subset of FIA data would be most useful. Other interpretations? Implications?

    • I didn’t get that.. I got that a “framework” are the ideas or structures that support definitions. I just looked at how some recent forest plans handled old growth and it would be very weird to start all over with something new IMHO.

  9. With all the different species and geographic regions, my great fear is that FS will develop an incredibly complex variety of MOG definitions yielding an unwieldy, unworkable, impractical large scale maps that will not work at local levels. I say go an entirely different direction and keep things SIMPLE. Forget perfection. Strive for “pretty good” or “good enough”. For humans we use 21 and sixty five for mature and old, even though inaccurate for almost every individual. I recommend going with tree or stand AGE as a reasonable proxy for all the highly technical considerations. But what’s the right number that works pretty well? How about 80 for mature? Old growth definitions are effectively meaningless is the FS intends to conserve, protect, manage both M and OG under similar policies (they should).

    • So, will the selected age be correlated with a site-specific tree diameter, so that ‘protections’ can be applied, onsite, by the lowly timbermarkers? Will people agree upon an 80-year old site-specific average diameter? Will these diameters be broken up into individual species? It may not be simple, but it is better than a nationwide decree.


Leave a Comment

Discover more from The Smokey Wire : National Forest News and Views

Subscribe now to keep reading and get access to the full archive.

Continue reading