10 thoughts on “Old Growth NOI Federal Register”

  1. I am thinking hard about the desired condition statements one and two from page sixteen. Defining the desired condition as an increase or improvement over current conditions seems …vague and unscientific maybe? A more explicit statement of desired condition would likely come with problems of its own though. The approach used in the proposal has policy support and provides somewhat useful direction to FS managers while allowing flexibility in the pace and scale of management.

    • Some people explicitly oppose Forest Service “discretion”. I would like to see the Forest Service officially define many terms, consistent throughout every Forest. There are strategies to playing these word games, to push political, economic and environmental agendas.

      I’d like to think that active forest management has site-specific science on their side. It is more important to focus on what is left, instead of worrying about what is removed (or piled, chipped or burned).

  2. Here’s the language on the “purpose” of projects – a standard: “Vegetation management within old-growth forest conditions may not be for the primary purpose of growing, tending, harvesting, or regeneration of trees for economic reasons.” I think this is kind of meaningless unless the Forest Service requires some kind of documentation of what the “primary purpose” is for each project and the rationale for it. Does someone (maybe more familiar with the budget process) know if the term “primary purpose” has a specific meaning that is defined somewhere?

    Of course I’m not sure this standard is even necessary when another standard says, “Vegetation management in old-growth forest conditions must be for the purpose of proactive stewardship, to promote the composition, structure, pattern, or ecological processes necessary for the old-growth forest conditions to be resilient and adaptable to stressors and likely future environments.” When it is written as “the purpose,” it doesn’t seem to allow for any others.

    Regarding “desired conditions,” the Planning Rule requires that “a desired condition is a description of SPECIFIC … ecological characteristics …” “Maintained or improved” obviously doesn’t meet that requirement. The expectation for plans revised under the 2012 Planning Rule was that the actual desired amount and distribution of old growth would be included as a desired condition – and that it would be within the natural range of variation. A nation-wide amendment can’t be expected to establish those conditions for each national forest. However, I would like to see them add an objective for each forest to do so within the next X years.

  3. We often hear support for “focusing on what is left instead of what is taken.”

    This confuses me, because it fails to recognize that what is taken has opportunity cost and needs to be accounted for. Thinning might leave some nice trees, but what is taken has consequences such as carbon emissions, forgone opportunity to increase forest carbon storage, and reduced long-term recruitment of snag habitat.

    • Once again, only focusing on just one thing, 2nd. Again, it is a balancing of the harms, instead of ‘hopes and prayers’ that the whole forest doesn’t die, rot and burn. Of course, you are assuming that “thinning” means ‘take the valuable trees’. Why don’t you address “thinning from below”, instead?

      We’ve already seen the ‘Whatever Happens’ style of preservationism. The results are shown in the massive firestorms of the last 20 years.


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