MOG Proposal-Soon To Come Out as Plan Amendments Not Regulation

Despite MOG not being on the regulatory agenda as I posted yesterday, within minutes I heard that it is coming out soon. Because it won’t be a regulation but rather a bunch of plan amendments, so that explains it, I guess.  I was hoping, based on climate and wildfire emergencies  for each forest to do a fire plan amendment focusing on delineating and maintaining PODs and fuelbreaks, plus fire use, so maybe there is some of that in there.

Here’s a story from E&E News.

The Biden administration is closing in on a proposal to protect old-growth forests on federal land while allowing some tree thinning and timber harvesting, groups familiar with the basic outlines of the plan said.

While the fine details of the proposal, to be published in the Federal Register within days, are closely guarded, policy groups said they expect the Forest Service to pursue forest plan amendments across the 193 million-acre national forest system that would limit — but not necessarily eliminate — logging in remaining old-growth stands.

The Forest Service referred questions to the Department of Agriculture, which didn’t immediately return a request for comment. The actions stem from an April 2022 executive order from President Joe Biden directing an inventory of mature and old-growth forest on federal land and measures to protect those areas for carbon sequestration and other purposes.
By amending forest plans — which are the guiding documents for managing each forest — the USDA would avoid the more lengthy route of proposing a formal rulemaking that would go past the current Biden administration. Still, forest plan amendments are subject to public comment periods that would stretch a few months, and there’s no guarantee that they’ll
proceed free of legal challenges that could delay or derail the process.
The environmental impact statement associated with a forest plan amendment would also take considerable staff time for an agency that’s already acknowledged being stretched.
Groups in contact with the Forest Service said they don’t expect the administration to address “mature” forests — or those that haven’t quite reached old-growth status — at length in this proposal, which would be a disappointment to environmental organizations that say those forests, too, deserve greater protections.
The administration’s actions could bring more consistency to managing old growth around the country, said Sam Evans, senior attorney with the Southern Environmental Law Center in Asheville, N.C.
“Protecting and restoring older forests is mission critical for the Forest Service. Across the board, it’s the single best way to protect rare species, store carbon, provide clean water and increase resilience to wildfire,” said Evans, who leads the organization’s national forests and parks program. Evans said forest plans are “wildly inconsistent” in how they treat areas of old growth, which can be areas that were never logged or have over time taken on similar characteristics.
The plan for the Nantahala and Pisgah national forests in North Carolina allows for logging old growth to encourage the creation of younger forest, for instance, while the Custer Gallatin National Forest in Montana requires projects to “retain old growth characteristics” while allowing projects in old-growth areas as part of meeting that objective, he said.
“There’s really no excuse for the lack of consistency. Cutting old growth in some places while protecting it in others will never make any real progress toward restoring our forests,” Evans said.
Seeking a consistent approach from one end of the country to the other presents its own challenges, advocates of a more intensive management approach say, because protecting an old-growth forest in fire- and drought-prone California, for instance, may require different approaches from protecting old growth in the rainforests of Alaska or the hardwood forests of the eastern U.S. And while some environmental groups say logging is the greatest threat to old-growth forests, the Forest Service is casting threats such as climate change and associated drought, wildfire, disease and pests as the main dangers — which can be addressed through a more intensive approach to managing forests.

In some places, the Forest Service continues to pursue timber sales in old-growth stands even though Biden pledged through an executive order to protect old-growth forests as a pillar of his climate policy.

I keep hearing this on various webinars and have asked the individuals for names of projects.  With regard to ones I’ve looked at, thinning in old forests, it’s intended to protect old trees in old-growth forests.

A lobbyist who works with the wood products industry said revising forest plans to reduce management — which can include thinning to reduce the spread of wildfire as well as larger-scale logging — misses an industry point: that healthy forests and such projects go hand in hand. “Millions of acres of forests of all ages are vulnerable to fires, insects and disease — which the Forest Service says are the leading causes of forest loss across the National Forest System,” said the lobbyist, who was granted anonymity to protect relationships with the administration. “Yet the administration is forcing the Forest Service to revise over 120 forest plans to impose further restrictions on management. This is an intentional distraction from the mission Congress has assigned to the Forest Service, which is reducing hazardous fuels and protecting communities from wildfires.”

There are lots of us out here that, again, don’t have a timber industry, but still want fuel reduction projects to go ahead.  Maybe we need to start an interest group (Wildfire Resilience Forever?) so we’ll get interviewed?

Forest plans have already become a battleground on the mature and old-growth issue, as critics of large-scale logging say the Forest Service is taking an overly permissive approach that collides with Biden’s executive order, which promised to “institutionalize climate-smart management and conservation strategies that address threats to mature and old-growth forests on Federal lands,” and will be the basis for how the Forest Service determines how and where trees can still be cut to meet the goal.

In October, for instance, the Center for Biological Diversity filed an objection to the new forest plan for the Grand Mesa, Uncompahgre and Gunnison national forests in Colorado. Among other complaints, the CBD said the forest plan — which was being developed at the time Biden issued the executive order — doesn’t do much to protect old-growth areas, although it does discuss retaining areas for wildlife habitat and says older trees store the most carbon.

On the other hand, the CBD said, the forest plan doesn’t include an accounting of how much old growth is present on the forests, and it specifically calls for removal of larger trees that the agency said may be most susceptible to beetle infestation. The Forest Service said in the forest plan, “This will temporarily reduce the live tree carbon pool but may increase the rate of carbon uptake and resilience to future disturbance.”

The idea that the GMUG didn’t count the old-growth seems unlikely to me but I will check.

However the administration proceeds, Congress will be tracking the issue as it crafts a new five-year farm bill in 2024, delayed from this year. That legislation’s forestry provisions will protect broad uses of national forests, including for timber production, House Agriculture Chair Glenn “G.T.” Thompson (R-Pa.) told E&E News on Tuesday.
“We want healthy forests, and that means regular harvesting and replanting,” Thompson said. “We’ll see what they say, and then we’ll tell them what they need to do with the farm bill.”

Can’t wait to see what they came up with!

4 thoughts on “MOG Proposal-Soon To Come Out as Plan Amendments Not Regulation”

  1. The E&E link in the post goes to an article from April 2023, not December 2023 – is there a link for the E&E article quoted in this post?

  2. “The Forest Service said in the forest plan, “This will temporarily reduce the live tree carbon pool but may increase the rate of carbon uptake and resilience to future disturbance.””

    What it didn’t say is how much of that “live tree carbon pool” will be added to the atmosphere in the short-term, which (almost) everyone seems to agree is the main problem. Is this a reasonable rationale (or does it ignore a relevant factor)? In context, this is about “larger trees that the agency said may be most susceptible to beetle infestation,” but in many places wouldn’t that just mean any larger tree?

    • Jon, I asked the GMUG for their side of the story on they are going to clarify. Also some larger trees are known to be more susceptible than others. Keen, F. P. Relative susceptibility of ponderosa pines
      beetle attack. Jour . Forestry 34:919-927, illus. 1936. I don’t think folks have changed their minds about this


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