Why Did the Biden Admin Say No to NOGA (and Yes to So Many Others?)

Now, I was never a fan of the NOGA process.  Keeping old trees alive can be hard.  National Forest employees know where their old-growth is and forest plans already have restrictions on doing things in old-growth.  I seldom agree with Andy Kerr, but even he said that the FS doesn’t say that treatments are commercial when OG stands are treated.  Whether you believe that  “other reasons” are  mostly legitimate (as I do) or excuses to go after old-growth for sawmills (as Andy K. appears to), it doesn’t change the fact that the paperwork right now says that in very few places is cutting trees for commercial purposes allowed in old-growth.

I remember hearing from someone in the FS something along the lines that timber cutting in OG stands for commercial purposes are only allowed now in two places, Alaska and a forest in Region 1.  If others know more about this, please comment.  And remember, the same groups that wanted OG “protection” also wanted mature “protection.”  If I looked at the list of some of the supportive NGOs, it sounded like some of the same from the old “zero cut” campaign.

But there are interesting questions to be raised.  Why now? The Biden Admin recently approved the Rock Springs RMP (conservation-y, against wishes of locals and elected officials),  Lava Ridge Wind Project (developmenty- against wishes of locals and elected officials), new Monuments are coming from a conservation-y  perspectives, and there’s the Solar PEIS  (we’ll look at that one further).  Can we see a pattern of these last-minute give-aways?   Maybe the Admin has friends in the renewable and conservation world and  so is doing sometimes symbolic gestures of support, since many of them can be overturned in the next Admin.   Against that, though, we see “no” to NOGA.  Someone knows the answer, but they’re not telling, at least not now.

E&E News Story: Headline: Biden Admin Nixes Old-Growth Forest Plan

As usual, the best coverage (in terms of least biased greatest depth) is from E&E News, so thanks to reporter Marc Heller.

But proponents of old-growth protections said abandoning the plan was, in their view, a better alternative than leaving it to the next administration. Had the administration left the effort intact, the incoming Trump administration might have looked to implement it in ways counter to the outgoing administration’s goals, said Ellen Montgomery, public lands campaign director for Environment America.

My guess would be that they would stick a fork in it, not “implement it in ways counter to” Biden Admin goals.   It doesn’t add up to me.  I looked into Environment America a bit-here’s their form letter on old growth. It seems to be a c4.

Centuries-old trees are still growing across the country, but on federal forest lands many of them are vulnerable to logging. Once these ancient trees are cut down, old-growth trees will be lost forever. Our older forests are still being logged at an alarming rate — this directly undermines the Biden administration’s efforts to address climate change and protect 30% of lands and waters by 2030.

Old-growth and mature trees form the backbone of their ecosystems, absorbing carbon dioxide, maintaining genetic diversity and providing habitat for all sorts of life.

I urge you to take action to protect older forests and trees on public lands in the United States from logging, and to ensure federal agencies work to recover these carbon rich landscapes for their climate, biodiversity, and watershed benefits to our nation.

This is their 2022 list of funders, many of the usual groups and foundations:

Environment America Research & Policy Center would like to thank the following foundations and organizations for supporting our work in fiscal year 2022: 444S Foundation, American Heart Association, American Littoral Society, Bydale Foundation, CLASP, Clean and Prosperous America, Curtis and Edith Munson Foundation, Environmental Defense Action Fund, Gordon and Betty Moore Foundation, Hittman Family Foundation, Natural Resources Defense Council, Natural Resources Defense Council Action Fund, Oregon Wild, Overbrook Foundation, Park Foundation, Patagonia, Paul M. Angell Family Foundation, The New-Land Foundation, The Protection Campaign – a project of Resources Legacy Fund,  The Stone and Holt Weeks Foundation, The Tilia Fund and Weeden Foundation.

Maybe we can see through this list where the impetus was for the proposal, and maybe these folks are so high-level and anti-logging they don’t understand that many of us see tree-users as useful partners and not enemies.  Without doing a check, I’d guess many are headquartered outside dry forest country.  So that explanation doesn’t ring true to me.

I did get a chuckle out of this AP headline:

Biden administration withdraws old-growth forest plan after getting pushback from industry and GOP

Hmm. I know it’s just a headline, but a) this has been getting pushback since it was introduced, and b) the Biden Admin has been getting pushback from western elected officials on the other projects that are going through in these last days. And not just public lands, think of putting millions of offshore acres off-limits to oil and gas.

But those exceptions were not enough for the timber industry and Republicans in Congress who bitterly opposed the administration’s proposal. They said it wasn’t needed since many forested areas already are protected. And they warned it could be devastating to logging companies that rely on access to cheap timber on public lands.

I read some industry comments and I don’t think the industry folks said that.  I wish the reporter had quoted whoever said that.

Anyway, that doesn’t make sense either- Biden Admin suddenly realizes the idea is unpopular in some quarters.

How the U.S. got no old growth forest protections from the Biden Administration (commentary)

At least Dominick DellaSalla spreads the blame around in this Mongabay essay:

All sides are to blame for a failed NOGA policy that was the result of: (1) definition paralysis that delayed action; (2) rebranding strategies by the timber industry that positioned logging as the solution to all “forest health” issues rather than the problem itself; (3) questionable agency threat assessments that supported the industry narrative; and (4) the lack of a unified vision for forest protection by conservation groups. Let me break the failure to act down, piece by piece.

As more and more communities participate in fuel treatment projects, and see the impacts when fire comes toward their communities, and as more and more homeowners do mitigation themselves, the gap between the “no  cutting narrative” and peoples’ lived experience grows.  At the end of the day, people believe their own eyes and lose trust in the folks that tell them things that aren’t true.  Especially when their experience is downplayed, e.g., fuel treatments as “specious arguments.”

A similarly specious argument to save forests from burning up is being played out not only in the NOGA process but in every dry forest region of the country, as logging is rebranded as community fire protection, even as fires race across logged landscapes.

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But none of the above effectively answer the question in my mind  “why stick a fork in this before the next Admin comes in, when sister department Interior is spurting out equally, or more, unpopular decisions at a rapid rate?” My only guess would have to do with the fact that there are more politicals and fewer career folks around headquarters at the BLM, but I have to think that there is more to it than that.

Old Growth Amendment – When can you cut down large/old trees?

There are some other recent threads here that have been discussing this question, and I thought it might be helpful to post the actual language from the draft of the amendment (Table 1) that would answer this question.  It establishes criteria at the plan level that must be met by projects proposed in forests identified as old growth, as well as a guideline for removing “old trees” in other areas.   I have to say my overall impression is that there are enough exceptions that it is hard to believe the Forest Service couldn’t find one that would allow removal of large/old trees in any project it proposes.  On the other hand, this does put the burden on the Forest Service to demonstrate in the project record that the project would meet the exception, e.g. that it would in fact “reduce hazardous fuels.”  (But any wood is a “fuel,” so what makes it “hazardous?”)

I think Standard 3 is interesting.  If projects in old growth forests can not be for commercial timber production, I assume that these forests must then be classified as unsuitable for timber production?

An interesting omission:  “resilience to climate change,” which is what the 2012 Planning Rule is all about.

I’ve added a few italics to help frame the structure (and I see that the copying messed up the numbering of the criteria ….).

(The comment period closes around September 21.)

 

Standard 2.a

Where conditions meet the definitions and associated criteria

of old-growth forest, vegetation management may only be for

the purpose of proactive stewardship. For the purposes of this

standard, the term “vegetation management” includes – but is

not limited to – prescribed fire, timber harvest, and other

mechanical/non-mechanical treatments used to achieve

specific silviculture or other management objectives (e.g.

hazardous fuel reduction, wildlife habitat improvement). For

the purposes of this standard, the term “proactive stewardship”

refers to vegetation management that promotes the quality,

composition, structure, pattern, or ecological processes

necessary for old-growth forests to be resilient and adaptable

to stressors and likely future environments. Proactive

stewardship in old-growth forests shall promote one or more of

the following:

  1. reduction of hazardous fuels to reduce the risk of loss

of old-growth forests to uncharacteristic wildfire, and to

facilitate the return of appropriate fire disturbance

regimes and conditions;

  1. resilience to insect and disease outbreaks that would

result in the loss of old-growth conditions;

1. ecological conditions for at-risk species associated

with old-growth forest, including conditions needed for

the recovery of threatened and endangered species;

  1. amount, density, distribution and species composition

of old trees, downed logs, and standing snags

appropriate for the forest ecosystem type;

  1. vertical and horizontal distribution of old-growth

structures, including canopy structure and composition;

  1. patch size characteristics, percentage or proportion of

forest interior, and connectivity;

1. types, frequencies, severities, patch sizes, extent, and

spatial patterns of disturbances;

1. successional pathways and stand development;

  1. connectivity and the ability of old-growth obligate

species to move through the area and cross into

adjacent areas;

  1. culturally significant species or values, to include key

understory species;

  1. species diversity, and presence and abundance of rare

or unique habitat features associated with old-growth

forests; or

1. other key characteristics of ecological integrity

associated with old-growth forests.

 

Standard 2.b

 The cutting or removal of trees in old-growth forest for

purposes other than proactive stewardship is permitted when

(1) incidental to the implementation of a management activity

not otherwise prohibited by the plan, and (2) the area – as

defined at an ecologically appropriate scale – continues to

meet the definition and associated criteria for old-growth forest

after the incidental tree cutting or removal.

 

Standard 2.c

 Deviation from Standard 2.a and 2.b may only be allowed if

the responsible official determines that vegetation

management actions or incidental tree-cutting or removal are

necessary for the following reasons and includes the rationale

in a decision document or supporting documentation:

  1. In cases where this standard would preclude

achievement of wildfire risk management objectives

within municipal watersheds or the wildland-urban

interface (WUI) as defined in Section 101 of the

Healthy Forest Restoration Act of 2003 (16 USC

6511) and its application by the local planning unit, or

would prevent protection of critical infrastructure from

wildfire;

  1. to protect public health and safety;

1. to comply with other statutes or regulations, valid

existing rights for mineral and energy resources, or

authorizations of occupancy and use made prior to

the old-growth amendment decision;

  1. for culturally significant uses as informed by tribes or

for de minimis use for local community purposes;

  1. in areas designated for research purposes, such as

experimental forests or research natural areas; or

  1. in cases where it is determined – based on best

available science, which includes Indigenous

Knowledge – that the direction in this standard is not

relevant or beneficial to a particular species or forest

ecosystem type.

 

Standard 3

Proactive stewardship in old-growth forests shall not be for the

purpose of timber production as defined in 36 CFR 219.19.

 

Guideline 3

 

To preserve the cultural and historical value of old trees

occurring outside of old-growth forests, vegetation

management projects should retain and promote the

conservation and survivability of old trees that are rare when

compared to nearby forested conditions that are of a

noticeable younger age class or unique in their ability to

persist in the current or future environment, and are not

detracting from desired species composition or ecological

processes.

The Wonderful Wizards of OG: Looking Beyond the Abstraction Curtain

In some areas, It's harder to keep trees alive than you might think. More than one million acres of forested land in Oregon contained dead or dying fir trees, indicated by red needles atop their canopies in this photo taken in July 2022 during an aerial survey conducted by the U.S. Forest Service. U.S. Forest Service
Keeping trees alive sequestering carbon is harder than it looks.Fir die-off as observed during this year’s aerial survey in the Fremont-Winema National Forest in southern Oregon.Daniel DePinte / USFS

Before I get into the weird and wonderful world of new wildfire technologies,  I thought that this Anonymous comment was worthy of more discussion, because of the links to different scientific papers.  It’s not unrelated to our previous discussion of the “large diameter trees” aka the East Side amendment, especially if you have spent much time working in pine/true fir country.

After reading through the links, I found some general differences in framing, approach, and language that I think may help us clarify our agreements and disagreements.

1. What specific words are used (old-growth forests vs. old trees)? As we know OG forests have all kinds of spiritual and ecological dimensions. Old trees occur in all kinds of settings, like our backyards or fence rows. And old is relative. Plus small trees can be relatively old, and large trees relatively young. Then there’s “mostly” and “generally” and other words like that- the caveats that we find in many papers.  Is it generally around the planet? Generally in the Ashland, Oregon watershed?

2. What’s the goal? In some cases, it’s to maximize the area in old growth. In other cases, it’s to replicate what was in the past. Or it may be to protect some old trees from fire. Or just general forest (including conceivably, trees’) resilience to future changes. Logically, HRV can’t, by definition, be more resilient to future stressors, if climate change is unprecedented.  So the goals (states or implicit) in scientific papers may not actually line up with each other, nor do they with current statutes and regulations.

3. What disciplines and data are used to make a claim? It seems like stand prescriptions are a function of silviculture, pathology and entomology, fuels, wildlife and so on. If a statement argues some generality like “don’t cut any old trees, it’s bad for (something),”  what are the other disciplines that might be saying “it’s good for (something else). I think much of the current disagreement amounts to metascale pronouncements/abstractions versus site-specific prescriptions. Which brings us to ..

4. Where was the research done? Did they encounter forests directly and measure them, or use existing datasets?  How much can we generalize those conclusions to other part of the country? Is the ecological term “dry forests” meaningful in the same way from Montana to New Mexico and from the Eldorado to the Black Hills? Do we lose key information when we generalize?

It’s almost as if, with some of these arguments (it’s never good to cut any old trees), some folks are saying:

We (certain forest ecologists and members of certain ENGOs) actually know more about what is a good prescription (for a site we’ve never seen) than the ID team who has been there, measured things, and contributed their disciplinary input.
a) because they are bad at their work and/or
b) they have bad motivations- even where there is no timber industry to speak of, or they are not in the timber shop,
c) not yet articulated..?

The problem I see, though, with that thinking, is that there is often much more relevant and direct knowledge, and often intense interdisciplinary dialogue and challenge on an ID team (and with the public) than with a few academics in a discipline analyzing data and exchanging emails.  And if local practitioners are bad at their work, aren’t many of these researchers teaching at the same universities that award degrees in those fields? So is there some kind of technological or motivational canyon they fall into after graduation? Or possibly, no matter their continuing education and experience, they will always know less than the profs? This is a great gig for the profs, but somewhat demoralizing for everyone else.

To which my solution is “fewer abstractions, more field trips.” Anyway, back to Anonymous’s comment.

‘Removing old-growth trees is necessary for resilience’ may be your opinion, but is not where the vast majority of empirical research and expert consensus is on this issue. Some examples of forest ecologists that have emphasized this in relation to western dry forest mgmt, and there are many more —

What is an “old-growth tree” is it an “old tree”? What makes a person an expert? Certainly there are experts who are not in this “consensus.”

1.“Old-growth trees, especially large old-growth trees of all species, definitely qualify as ‘ecological keystones’ given their central roles in ecosystem function, wildlife habitat, resilience as live trees and as large persistent snags and logs after death. In general, we recommend retaining trees of all species older than 150 years of age as part of dry forest restoration projects – even if they are within the crown of an old ponderosa pine tree.” ~Franklin et al. 2013

This makes me feel like “deja vu all over again.”  In the 80’s, I remember a field trip on the Ochoco with Jerry Franklin (maybe Jim Z was there?) during which we asked him how much dead and downed (fuels) he thought was a good amount.  It was really a fuels practitioner question, or even maybe a fire ecology question, not a vegetation ecology question.  To some extent, values are imbedded in the choice of which discipline to listen to.  Meanwhile, it’s hard to argue that fuels practitioners have a secret agenda of wanting to cut big trees.

I think the “within crowns” is an interesting comment because to me that’s a tree physiology or a fuels question, not a forest ecology question at all.  Although practicing applied forest ecologists (i.e. silviculturists) have years of observational experience of how this works out in the woods in their area, e.g. big old firs under pines.

From the tree physiological perspective, does the old fir tree compete with the old pine for water?  Answer – of course. Look at growth rings after thinning, if the trees are young or healthy enough to release.  Does that impact the health of the more fire-resistant old ponderosa? Extremely likely.  From the fuels perspective, does the true fir provide a potential hot spot next to the ponderosa that could make the fire more intense or be a ladder fuel?  What happens to old true firs? They tend to die and dry out.

As in “firmageddon:”

Heavily affected areas include the Fremont, Winema, Ochoco and Malheur National Forests.

The most southerly of the forests, the Fremont National Forest, was the hardest hit, according to survey data.

“We’re calling it ‘Firmageddon,’” Daniel DePinte, who led the survey for the USFS Pacific Northwest Region Aerial Survey, told a gathering of colleagues in October. “It is unprecedented, the number of acres we have seen impacted. It’s definitely significant and it’s disturbing.”

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2.“In the context of forest restoration, we recommend that managers take the divisive issue of old tree harvest off the table, and instead focus on thinning young in-growth trees (i.e., those trees that established after Euro-American settlement) that have established around and among old trees and tree clumps. Focusing harvest on young trees will reduce competition, continuity of crown fuels, and contagion of host-specific tree enemies such as bark beetles, without causing conflict over proposed harvest of any remaining large trees. Such an approach is consistent with current guidelines for restoration and climate change adaptation in dry ponderosa pine and mixed-conifer forests.” ~Clyatt et al. 2016

If it’s this study, it was done by quantifying the historic range of variability for the Northern Rockies and specifically asked the question “how much is mortality density-dependent.” It also seems to argue that you can do more restoration if you don’t have conflicts, and some people (we know) don’t like cutting any old trees .

 Yet many old trees are found in clumps, often in medium (5–9 trees) and even large (10 or more trees) clumps, and some managers and stakeholders express concerns over the potential for competition-induced mortality in these situations, even to the point of proposing to harvest some large, old trees occurring in clumps. Conflicts over proposals to thin out groups of large, old trees can often hinder restoration efforts (e.g., DellaSala et al., 2003, DellaSala et al., 2013).

I couldn’t find out more because the study seems to be paywalled, but I’m not on board with that argument.

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3. “Enhancing forest resilience does not necessitate widespread cutting of any large-diameter tree species. Favoring early-seral species can be achieved with a focus on smaller trees and restoring surface fire, while retaining the existing large tree population.” ~Mildrexler et al. 2023

What is “widespread”..? It seem to me that a stand prescription is precisely that.. many stands won’t need any large/old trees cut, and others will.  If this is the study I think it is, it’s a science op-ed in Conservation Science and Practice, whose coauthors include Law and Moomaw.

We therefore examined how often large trees (≥53 cm DBH) of these species co-mingle on USFS FIA plots (~1 acre) across the same six eastside national forests where we previously examined carbon storage by large trees (Mildrexler et al., 2020). Drawing on the same USFS FIA measurements as our prior study, we found that large ponderosa pine, grand fir, and western larch were present on 56%, 18%, and 7% of all plots (n = 3335). Large ponderosa pine co-mingle with large grand fir about 14% of the time (259 plots), leaving 86% of plots with large ponderosa pine without large grand fir (1616 plots). Similarly, large western larch co-mingle with large grand fir about 56% of the time. Large ponderosa pine and grand fir are found together on only 8% of all plots in the region, while large larch and grand fir are found together on only 4% of all plots in the region. In other words, large ponderosa pine are by far the most common tree species found in these six National Forests and infrequently co-mingle with large grand fir at the FIA plot scale, whereas large western larch are far less

So the argument is “we looked at some FIA plots and there’s not that many where they are growing together”.  That could be true, but it’s not an argument for not cutting them when they are there, and provide ladder fuels/competition to old pondos.  Again, see the tension between the site-specific and the larger scale data.

People might wonder about juxtaposing Firmageddon and  this statement in the paper:

It is not uncommon for grand fir to reach 250 to 300 years of age (Howard & Aleksoff, 2000). Thus, large grand fir ≥53 cm DBH and <150 years of age can continue growing and play an important role in storing and accumulating carbon from the atmosphere to help abate the climate crisis.

If you remember Forplan in the 80s, the idea was to cut the ponderosa pine and promote true fir because it grows faster and produces more volume- if you assume away disease, bugs and fire.  The end goal was different (timber vs. carbon) but hoping for grand fir to grow well forever is likely to run into the same, or more problems, now as 50 years ago. Because there’s increasing drought and fire, and bugs and diseases, according to some, due to climate change. Seems like it would make it less likely that true firs would thrive.

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4. “Because old trees are rare in most frequent-fire forests of western North America, it is imperative to conserve them where they exist.” ~Fiedler et al. 2007

I wonder if that’s this paper,

There is no one-size-fits-all approach to managing frequent-fire, old-growth forests. However, there are general guidelines to follow: 1) set objectives for both structure (tree density, diameter distribution, tree species composition, spatial arrangement, amount of coarse woody debris) and function (nutrient cycling, desired tree species regeneration); 2) prioritize treatments according to ecological, economic, and social needs and risks; 3) identify the potential treatments (natural fire, prescribed fire, silvicultural cutting) that best meet the objectives and scale of the project; and 4) implement the treatment (s). We discuss each of these guidelines in this article.

I would also argue that people who might want to cut old fir next to old pines want to conserve old trees by helping make them more fire-resistant.

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5. “[Do] not thin mature and old groups of trees except to remove young trees within these groups to reduce ladder fuel.” ~Reynolds et al. 2013

I think that that is probably this GTR which talks about restoration work on the Cibola. One thing that the site did not have is true fir. I can only go by my own experience, but that is that Doug-fir isn’t likely to grow as well in the understory of a ponderosa as a true fir would, so I’m not sure that comparison is relevant.

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“Cutting larger trees in a stand is likely to create future problems and should not be done if long-term landscape health is the primary objective.” ~Perry et al. 2004

I don’t know what “long-term landscape health” is, but if involves maintaining living trees, in some cases it might involve cutting some large trees in the interests of promoting more resilient larger old trees. Also a reminder that different papers suggest different “primary objectives”.
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5. “Silvicultural activities that focus on removing dominant trees will not reduce potential fire intensities and stand mortality, nor will they contribute to creation of forest structure and composition characteristic of older forest.” ~Franklin et al. 2008

Again, “focus on removing dominants”; no one is proposing focusing on “removing dominants” they are focusing on making life easier for dominants by removing codominants.

If we go to the definition

Dominant – trees much taller than the general level of the canopy, receiving direct sunlight on all sides of their crown. Codominant – trees that form the general level of the canopy, but below the dominants, receiving sunlight from above their crown and some from the side.

It seems to me that if the fir was “getting sunlight on all sides of the crown” it would not be likely to be considered for thinning. And would not be “within the dripline” as per the earlier Franklin paper.  I’m not disagreeing with Jerry’s statement, but I would argue that’s not what we’re discussing here.

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“In management aimed at accelerating the recovery of old-growth structures, protection of all pre-Euro-American trees is needed to ensure that this restoration truly leads to old forests.” ~Baker et al. 2007

Is the point of management to “accelerate the recovery of old-growth structures” or to be “resilient to current and future stressors” and “maintain living trees on the landscape?”  Even “ecological integrity” and NRV are not uniquely focused on “old growth structures.”

And how would we decide what was “pre-Euroamerican” for a given area? Was it when the first fur trapper reached the area – 1830? Or in the Southwest, the founding of Santa Fe in 1610? A couple hundred years can make a difference. Again, sometimes you may have to sacrifice one old tree to protect another.

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I think everyone likes old trees, and old forests (except maybe dead ones, fallen and lying jack-strawed with dry fuels). The question are: how best to maintain them in different places?  That’s for the “should we cut any old trees, ever, anywhere” question. Then there’s the broader question of “what percentage of different age classes should we manage forests for?” which is more complex.

Introducing a KISS Old Growth Amendment

Let’s go back to what law prof Bagley said in yesterday’s post.

 Minimalism should be the watchword. New procedures should be greeted with suspicion and old procedures should be revisited, with an eye to cutting them back or eliminating them

When someone told me that the proposed OG amendment wasn’t pronounce OG (ahhg) but actually NOGA (nohgah, like nova), it reminded me of the word nova, or no va in Spanish.  It doesn’t go.  As proposed, IMHO,  it’s just another layer of paperwork and talk stratigraphy overlaying the possibility of … action.  To that end, I’m proposing instead, a KISS (keep it simple, stupid)  old growth amendment.

So I think we need to start the discussion with the point of the NOGA (formerly MOG) exercise.  It appears to me that someone in the Admin (likely above the Secretary of Agriculture)  is doing this work with the rationale “we want to support our friends.”  Both parties do this, and if there were a third party in office, they would do it too.  So I am not criticizing this tendency, I accept it as a fact of political life.

When I worked on Colorado Roadless, I was told that we needed to do what a certain ENGO wanted.  Their rep kept telling us “you have to give me somethin’-somethin'”.  I think of this, and wonder “was there a way to give the Key Influential Group or Groups something that didn’t require extra work from all the forests, partners, Tribes and volunteers? ” After all, setting up desired conditions and making forests and cooperators do “adaptive management strategies” makes the majority of the work float downhill.   When the titans clash, the rock pieces fall on the heads of.. Forest and District people, partners and the public at the local level. But what if we just acknowledged the reality- to paraphrase Solzhenitsyn” we know what’s going on, they know what’s going on, they know that we know what’s going on, and we know..” and so forth.  What if we all just opened up about this reality and figured out a “somethin’-somethin'” with minimal extra procedures?  Perhaps the FS, the Department and the White House have had that discussion, and it wasn’t satisfactory to the KIGGs (Key Influential Group or Groupss). Still.. we can talk about it here, or even suggest it in our comment letters.

In this particular moment, the Forest Service has paused hiring,  plus has the Congress breathing down its neck about accomplishments.    Having read and analyzed the alternatives in NOGA,  I would like to suggest one designed with the idea of possibly the groups “somethin’-somethin'” and minimizing the (extra, unnecessary) work for everyone else.

My alternative would be to simply put one new standard in the national amendment.  It would be the standard in alternative 3, no commercial harvest in OG as determined by on-site review of each forests’ OG definitions.  No other DCs, objectives or standards.  That would be the whole amendment enchilada.

What would happen with this standard ? It would cost more to do service contracts in identified OG areas.  Part of the KISS alternative would be that counties would be reimbursed for the foregone receipts from timber sales in identified OG, so they would be made whole.

The EIS analysis that would be most germane, it seems to me, would be the additional costs of doing service contracts (plus the county reimbursements)  rather than timber sales in OG.   These additional costs could be estimated, and weighed against the costs of developing Adaptive Management Strategies, as well as the opportunity costs of the work not done by the FS employees, Keystone Agreement folks, collaborators, partners and volunteers while they are developing “strategies” and working on new objectives, and all the new analyses. Based on what Travis Joseph said in his podcast, industry doesn’t want OG anyway (at least not in the NW).  So there’s that.

I went down a little bit of a sidetrail on the question of what is “commercial”, whether it’s an administrative thing (the timber sale contract or service contracts) or whether someone who received a service contract wouldn’t be allowed to sell the logs- because maybe if they were large the contractor would bid less?)  I don’t know enough about this.

I am not a fan of the objectives requiring projects to do OG improvement, when people are clamoring instead for projects to reduce risks to their homes and communities. It places the FS in a difficult situation of not doing things people want them to do, and being forced to do things people in communities, elected officials and Tribes may not see as a priority. I don’t see this as good for relationships, which over the long term,  is not good for federal forests nor people.  Nor for building support for government programs.  It’s especially not a good look to promulgate during a big wildfire season.. like this year.

This is not to be critical of the FS in any way, although the rumor is that the desired conditions and other fairly obtuse wording was contributed by a contractor with a legal background.   It reminds me a bit of the language of the 2012 Rule, which I considered notable for what I called at the time “bristling with legal hooks” and what still seems to me, a jungle of unnecessarily complex verbiage.

There are  positive ideas in NOGA about Indigenous knowledge and Tribal rights and sovereignty.  There is also, probably equal or more excellent,  language  in the NWFP FAC committee report.  Problem is, each of those is just a piece of the FS decisional pie.  Why not select a simple, easily comprehensible, better way to treat Tribes and make that a national policy?  Actually, I thought it already was.  If the point is that it needs to be part of NFMA to be enforceable, then maybe a separate Tribal amendment?

And monitoring? That doesn’t have to be in a plan, nor all plans, at all. If you want it to be national, and meaningful, just do some satellite stuff, with ground-truthing, every five years.  In fact, I would almost bet there are folks doing this already, or, if not, we could fund FIA/NOAA or whomever to do it.

So those are my thoughts. To summarize, (1) analyze a simple alternative that doesn’t require extra work for the FS and partners, except where old growth considerations are not already included in project analysis.  (2) Prepare a Tribal/Indigenous policy or plan amendment.  (3) Develop a monitoring program outside of NFMA.  There.. done!

As always, ideas, suggestions, critiques, other alternatives appreciated.

Help Wanted With National Old-Growth Amendment

 

I’m diving into the OG National Amendment this week.   At this point, it seems to me like another pointless paperworky exercise, full of obtuse verbiage, that will load down the feds so they can do less of the work that Congress gave them megabucks to do. Plus possibly waste much local time with unclear processes that may amount to reinventing the wheel, at best.  As I used to call the Wolf Creek project “Reasonable Access for Unreasonable People”, I might call this one “Consistent Frameworks for (ecologically and culturally) Inconsistent Forests”. Not that I’m critiquing the FS at all, they have been both diligent and creative in trying to make a silk purse out of a sow’s ear (IMHO).

Despite these initial impression, I’m trying to keep an open mind.  If you know of drafts of letters, and can share to my email sharon at forestpolicypub.com that would help me greatly.

Also according to the amendment webpage,

Throughout the public comment period ending on September 20, 2024, the Forest Service will be engaging with the public to provide information about the draft environmental impact statement and answer questions.

Information on public engagement sessions will be shared on this website and updated regularly. A virtual information session was held on June 28.

The agency held a series of regional field meetings across the country on July 10 and a virtual summary session will be held on July 31, 2024, at 12:00 pm ET. Registration is required for this event.

If anyone was involved in any of these public meetings, especially the “regional field meetings,”  please give me your impressions, either below or via email. I’m usually invited to suchlike but didn’t hear about ours.

If you had thoughts you can also put them in the comments.  Is anyone actually reading this? Especially volunteers?  And what parts are most important, and which do you think can be skipped?

Thanks!

Blast From the Past: Heritage Forest Campaign Yesterday, Climate Forest Campaign Today

One of the points I like to make about our forest policy world is that it is a great space for folks raising families and with other commitments. You can take a few years off (or possibly decades) and come back and not really miss much.  Thanks to the TSW reader who found this hearing from the year 2000.  If you swapped out “Climate Forest Campaign” for “Heritage Forest Campaign” and OG for Roadless, and  Biden for Clinton-Gore, and probably increased the budget figures, it sounds like the same thing, and I think the questions asked are still worth pursuing.  Sorry about the formatting.  This is just Chenoweth-Hage’s introductory statement, I didn’t read the rest, there are 128 pages. Might be other interesting stuff there.

Recently , one of the lead stories in Philanthropy magazine was about foundation funding of environmental organizations . Now , the article said that today foundations have much of the public agenda , and nowhere more so than in the area of environmentalism , where foundations collectively spend upwards of $ 500 million per year that we know of . 

Today we are here to analyze the relationship among large foundations , environmental groups , and the Federal Government in Federal public land management policy , in regards to recreation , timber harvests , mining , and other public lands issues . We will also explore the impacts of these policies on local communities . Environmental groups are relying more and more on a core of wealthy , nonprofit foundations to fund their operations . 

The largest environmental grantmaker  the $ 4.9 billion Pew Charitable Trusts gives more than $ 35 million annually to environmental groups . Other large wealthy foundations such as the Turner Foundation , W. Alton Jones , and Lucile and David Packard Foundations , are not far behind Pew in their grantmaking to environmental groups . 

Foundations have funded environmental advocacy campaigns for more wilderness , curtailing timber harvests , and mining , breaching dams , and Federal control of ecosystem planning . An example of this type of activity is the Heritage Forest Campaign , the subject of an oversight hearing on February 15 , 2000 , by the Subcommittee on Forests and Forest Health .

The Heritage Forest Campaign , a coalition whose sole purpose appears to be lobbying the Clinton- Gore administration to implement the Roadless Initiative , which would withdraw up to 60 million acres of national forest lands from multiple use . This campaign is largely organized and funded by tax free grants from charitable foundations such as the Philadelphia based Pew Charitable Trusts , with $ 4.9 billion in assets the fifth largest U.S. charitable foundation . 

Now , since September 1998 , Pew has given the National Audubon Society more than $ 3.5 million in tax  free grants to organize the Heritage Forest Campaign , a coalition of about a dozen  environmental groups . The sole objective of the campaign appears to be the creation of widespread public support for the Clinton –  Gore administration’s initiative to restrict access on 60 million acres of national forest lands . 

The Heritage Forest Campaign illustrates several potential problems with foundation  financed environmental political advocacy , namely the lack of fair , broad based representation , and the absence of accountability . Particularly disturbing is this administration’s acquiescence to the campaign in the setting of policy . 

At a recent hearing on the Roadless Initiative , I asked George Frampton , Director of the Council on Environmental Quality , for the names of all those attending any meetings he had held regardinging the development of the Roadless Initiative . The list he sent in response is a who is who in the environmental community . Even more telling is that not one individual representing recreation , industry , academia , county commissioners , or local schools were in attendance . Only representatives of the national environmental groups participated . 

Not only was the public excluded during these meetings , but so was Congress . The administration’s Roadless Initiative appears to be an attempt to bypass the role of Congress . Under Article IV , Section 3 , of the United States Constitution , Congress possesses the ultimate power over management and use of lands belonging to the United States . 

If the Roadless Initiative is universally popular , why can’t the Heritage Forest Campaign get it enacted by Congress through the normal legislative process ? Administrative directives , such as the Roadless Initiative , bypass Congress and centralize policymaking authority within the hands of unelected bureaucrats in the execu- tive branch . 

Foundation-funded advocacy groups make backroom deals , thus denying the average citizen a voice and input into the policy through their elected representatives in Congress . As a result , our Government becomes more remote and unresponsive to the needs of the average citizen . 

To whom is the Heritage Forest Campaign accountable? This campaign is put together by foundations, not the participants . The grantees are accountable to the foundations that fund them , not their own members . Foundations have no voters , no customers , and no investors . The people who run big foundations are part of an elite and insulated group . They are typically located hundreds or even thousands of miles from the communities affected by policies they advocate .

They receive little or no feedback from those affected by their decisions , nor are they accountable to anyone for promoting policies which adversely affect the well  being of rural people and local economies . Today’s witnesses will tell us how their communities are being crushed by an inaccessible and faceless movement , wielding great power and influence . 

The role of large foundations in funding environmental advocacy raises some fundamental questions . Foundation wealth shapes public policy at the expense of all counter views . Even worse , those skeptical of foundation  supported policies are often smeared by foundation funded media campaigns in an attempt to marginalize them in the debate . Even alternative environmental solutions are rejected out of hand as environmental groups mold their programs and their agenda to please the large grantmakers . 

Does foundation financed advocacy prevent full and fair public debate on public lands issues ? Is the average citizen’s voice and input in the government decisionmaking process drowned out by foundation  funded advocacy groups ? 

The most fundamental question of all is , what happens to the towns and communities affected by policies resulting from foundation  funded advocacy ? The people living in these communities are left with a ruined local economy . Their towns lack the income to provide even basic services . Their schools have no revenue to teach their children. 

The important issue here is whether the foundation strategies used to fund the environmental movement are buying undue influence for those groups on public lands policy . I believe it will become very clear during this hearing that this isn’t an issue concerning the environment , but rather one concerning power and its use for political ends , with rural communities being trampled in the process.

**********

Now, Rep. Chenoweth-Hage was appropriately concerned for rural communities as she represented Idaho.  At the same time, today, these policies influence all kinds of communities near Federal lands.  Another difference between then and now is our interest in the voices of Tribes, ethnic minorities and the poor and working class- marginalized communities.  How are these folks (say folks from poor rural communities)  represented on Boards and decision-making in these foundations?

“The important issue here is whether the foundation strategies used to fund the environmental movement are buying undue influence for those groups on public lands policy.” IMHO this question is still valid.

Finally, what is the endgame of these foundations, if they have one? Is it the same old “no oil and gas drilling, no mining, no grazing, no commercial logging, no OHV’s”?  I don’t know that we know, nor can I imagine who would have the political power to have that conversation.

Does the Old Growth Amendment Supplant or Redefine NRV?

Old growth LPP

First of all, let me say that there are probably people in the Forest Service who have thought all this through.  I’m hoping that they will help out with their explanations in the comments.

If old growth is old growth, and mature forests are on their way to old growth, and young forests are on their way to mature forests.. then it seems like there is no ceiling on the amount of old-growth needed, and no reason to ever have openings other than “natural” ones.  This can be problematic, conceptually, as some groups believe that today’s wildfires and wind events are all unnatural or caused or “supercharged by” the anthropogenic part of climate change.

And if you believe that, then does any ecosystem have “integrity”?   Or is the key thing to promote resilience (including biodiversity) in the face of climate change and protect key values of ecosystems and people from these and other dangers?  To keep diverse living trees alive on the landscape, and to protect water, wildlife and other values?  Perhaps some will say “it’s the same thing” and if it is, then perhaps the use of plain English would save time and misunderstanding.

Let’s go back to the 2012 Planning Rule Handbook:

Assessing the status of ecosystems—their level of ecological integrity—is difficult. There is no guide that provides a comprehensive protocol, and each ecosystem has a unique body of scientific information relevant to the ecological assessment. The planning rule and supporting handbook identify departure from the natural range of variation as a criterion to assess ecological integrity. The natural range of variation refers to the variation in key ecosystem characteristics produced by dominant natural disturbance regimes, usually in a pre-European influenced reference period. This method works well for ecosystems that are relatively well-studied and their natural range of variation can be estimated through ecological modeling or other methodology.

(my bold).  Now, as most readers know, I wasn’t a fan of this approach at the time.  At that time,  my thinking went along these lines… (1) there’s a great deal of pre-European time and yet a certain time has to be selected, humans have been around since glaciation;  (2) animals and plants move around and hybridize- and evolution is part of Nature, after all;  (3)  time’s arrow only goes one way, at least genetically;  and (4)  if climate is changing faster than usual, then there is no reason to think that the past is well adapted to the future. And don’t we want forests that are adapted to the future? As described in the Handbook, it unintentionally downplays the role of Indigenous fire management and the idea “natural= pre-European” only fits if Indigenous folks are part of Nature, which some now consider to be racist. It would perhaps be clearer and more accurate to say “we want to go back to Indigenous ways of managing the landscape,” if that’s really the case, but again we’d need more Indigenous people and give them authority over federal forests plus make them do not what they think best but what they think their ancestors did.  And the importance of Indigenous management and climate have only become clearer or perhaps “supercharged” in more recent discourse.

Many forests have done vegetation modeling and historic research, and came up with desired conditions of say, certain amounts of habitat with certain characteristics.  For example, x acres of early successional habitat, or y acres of  western white pine or oaks, or even the historic densities of some species.  So logically, to recreate these conditions, we may need to thin trees for density reduction and create openings for some pine and oak species to regenerate.  There are different ways of getting openings.  Depending on where you are, openings could occur due to wildfire, wind events, volcanoes, floods, trees dying from old age and/or native or introduced diseases and pests, and so on. With or without attribution to anthropogenic factors of climate change, some of these are more natural than others (fire suppression and non-native species obviously not).

Generally, the only other way is to manage is via prescribed fire or some combo of mechanical treatments (aka “logging” or “tree-cutting”) and prescribed fire.  So do we still want those carefully arrived at NRV distributions or not?  According to some, if the opening-treatments  would occur in currently mature or old-growth forests, then not.  So that leaves “natural” disturbances (affected by AGW, so then unnatural, except for volcanos?) and hoping that they get to the desired ratios; or alternatively, doing openings over and over in younger forests but not mature ones, so that they don’t go through their successional stages, which seems also unnatural.   Look who wrote about the importance of early successional  ecosystems in this 2011 paper (abstract)

Different disturbances contrast markedly in terms of biological legacies, and this will influence the resultant physical and biological conditions, thus affecting successional pathways. Management activities, such as post-disturbance logging and dense tree planting, can reduce the richness within and the duration of early-successional ecosystems . Where maintenance of biodiversity is an objective, the importance and value of these natural early-successional ecosystems are underappreciated.

So will the new OG amendment effectively replace the concept of “pre-European conditions” with “creating as much old growth as possible”?  Because we can imagine quite a possible tension between “maximizing old growth” and “ensuring diversity of tree species”,  and the latter  would be important to fulfill certain requirements of NFMA, specifically.

“provide for diversity of plant and animal communities based on the suitability and capability of the specific land area in order to meet overall multiple-use objectives, and within the multiple-use objectives of a land management plan adopted pursuant to this section, provide, where appropriate, to the degree practicable, for steps to be taken to preserve the diversity of tree species similar to that existing in the region controlled by the plan;”

My bold, Of course, trees and bark beetles, do their own things, unbothered by humans’ desire for shade or carbon credits, or even plan amendments, forest-specific or national. From the Fire Effects website:

The average lifespan of Rocky Mountain lodgepole pine is 150 to 200 years [37,170], though some Rocky Mountain lodgepole pine trees live more than 400 years

OG:- White House Announcement; More NGO Comments and Some Concern About FS Bandwidth from AFRC

Thanks to SJ for adding these ..  the White House Announcement is of particular interest. Here’s a copy of the letter to forests.  It reminds me a bit of the old “reviewing roadless projects in the WO” effort. As they say:

This letter only affects the process by which such activities are authorized. It does not alter or prescribe any substantive standards for the management of old growth forests

I always wondered about the legality of these kinds of   review processes, it seems they are designed to provide an outcome before there is a legal reason to do so.  Just saying it doesn’t prescribe anything different (perhaps on the advice of OGC?) has not, in the past, been accurate. Perhaps our legal TSW friends can clarify.

This workshop sounds interesting, and that it is joint by BLM and FS is good; after all, PJ is  the most abundant old-growth and traditionally disagreements have not been timber-war-ish.

Collaborative Efforts to Conserve Pinyon Juniper: Pinyon and juniper woodlands encompass tens of millions of acres of federal lands across the West, and have significant biodiversity, climate, and cultural values. Pinyon-juniper woodlands are the most abundant forest type in the federally managed inventory of mature and old-growth forests, and are the majority of mature and old-growth forests managed by the BLM. While much management focus has been rightly placed on pinyon-juniper encroachment onto sagebrush ecosystems, less attention has been paid to the importance of mature and old-growth pinyon-juniper ecosystems. The Forest Service and the BLM will co-host a public workshop focused on the conservation of these ecosystems in 2024. Through this effort, the Forest Service and the BLM will engage the public, Tribes, land managers, experts, and stakeholders in informed discussion around management issues, threats, trends, and opportunities for climate-smart management and conservation of mature and old-growth pinyon-juniper woodlands on federal lands.

Susan also linked to this group of ENGO’s quotes.

It seems like some of the quotes focused on  consistency across the country (Sam Evans) and a seat at the table for developing national policy (The Wilderness Society, Defenders of Wildlife), while EDF uses that other “f” word (flexibility) and notes the role of local folks:

The proposed forest plan amendment creates a rigorous, science-based process that will both protect old-growth forests and provide flexibility for managers, local communities, and tribal nations to recommend management actions to improve resilience to catastrophic wildfire and other climate change-induced threats.”

Meanwhile our friends at AFRC also have a press release. Perhaps oddly, so far they are the only ones who seem to be concerned about loading more paperworky processes on already-overburdened and difficult-to-hire federal employees. Excerpts:

 “The Forest Service’s data confirms logging poses a negligible threat to old growth forests, and existing federal environmental laws and forest plans provide direction on managing and protecting old growth. Yet the agency is now being directed to embark on a new, massive bureaucratic process – during a wildfire and forest health crisis – that will likely make forest management more complex, costly, and contentious.

 “Protecting old growth requires intentional, thoughtful action on the ground – not more paperwork.  It’s not clear how amending every single Forest Plan will help the Forest Service implement the Biden Administration’s own 10-year wildfire strategy that calls for a threefold increase in forest health treatments. Rather than giving our public lands managers the policy tools and support they need to sustain our forests and all the values they provide, this policy will force them to focus limited time and resources on more process and that will do nothing to address the real risks on the ground..

Some Groups Want the M Back in OG; WaPo Gets Five Smokeys for NOGPA Coverage

Interesting stories about the National Old Growth Plan Amendment (NOGPA). Now at this point, I haven’t seen anything the FS has written about it, and The Smokey Wire was not granted an interview with the Secretary, but what can we pick up from these stories?

First a story from the Washington Post.

I give them 5 Smokeys (out of 5) for detailed description, not characterizing it as “timber vs. enviros” and pointing out the timing problem via Chris Wood, also what’s the immediate effect.  All the things I wanted to know without any extraneous editorializing.  If you agree, consider sending the reporter a nice note:

In a phone interview, Agriculture Secretary Tom Vilsack said the effort is the first time the U.S. Forest Service has proposed simultaneously revising all 128 of its forest plans, which dictate how all 193 million acres of forests and grasslands are managed. The plan would prohibit cutting down old-growth trees for economic reasons, preventing carbon-rich forests from being clearcut at a time when scientists say they are most needed. These trees, most of which are well over 100 years old, store vast amounts of carbon. They also provide an essential habitat for hundreds of species of wildlife and are more likely to survive wildfires.

Having examine the projects alluded to in the Carbon Forests initiative, I don’t think the FS was cutting down any old growth for economic reasons. Again, as I’ve asked many NGO’s, please send me a link to the project documents where this is occurring and we can have that discussion in detail.

But it leaves open the possibility of continued cutting under certain conditions. Forest Service Deputy Chief Chris French said forest treatments the agency uses to reduce wildfire risk, such as thinning understory trees, would still be allowed in old-growth stands to protect them from out-of-control fire. In the Southeast, where the Forest Service is trying to restore the longleaf pine forests that used to blanket coastal areas, the agency could still cut down large, old loblolly pines, the main tree grown for the timber industry.

Some environmental advocates also questioned whether the policy will last, as a future administration could easily undo it. The new language about protecting old growth also won’t be finalized until the agency has completed an environmental impact statement, which it expects to finish in early 2025. “I wish they’d initiated this earlier. I wish they were doing a rulemaking,” said Chris Wood, president of the conservation group Trout Unlimited. Still, he said: “This is a big deal. This is a different agency than it was 20 years ago. The Forest Service’s appetite for going in and liquidating old growth is pretty much retired.”

It’s unclear how the new proposal will affect the agency’s planned timber sales, some of which include forest lands dotted with mature and old-growth trees.
In a letter sent to forest managers Monday, French informed them of the agency’s plans and wrote that “effective immediately” any forest management activities planned for old-growth stands in national forests would need to be reviewed and approved.

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Here’s the AP story.

I give them two Smokeys.
Apparently they had an interview with the Secretary as well.

Agriculture Sec. Tom Vilsack said the agency was adopting an “ecologically-driven” approach to older forests — an arena where logging interests have historically predominated

Does anyone remember New Perspectives and Ecosystem Management?

Past protections for older trees have come indirectly, such as the 2001 “roadless rule” adopted under former President Bill Clinton in 2001 that blocked logging on about one quarter of all federal forests.

As we know, the roadless rule didn’t actually “block logging.”

Under former President Donald Trump, federal officials sought to open up millions of acres of West Coast forests to potential logging. Federal wildlife officials reversed the move in 2021 after determining political appointees under Trump relied on faulty science to justify drastically shrinking areas of forest that are considered crucial habitats for the imperiled northern spotted owl.

Trump.. really?
***************

Here’s a press release from various ENGO groups (thanks for sending!).

Short summary.. this is a good first step but they would prefer to include mature trees.  Or “put the M back in OG.”

According to reports, the Biden administration will announce Tuesday a proposed nationwide forest plan amendment to advance protections for the last remaining old-growth trees in U.S. national forests. President Joe Biden has said these trees are critical components of the nation’s fight against the climate and extinction crises. The proposal, if adopted, would add new restrictions on logging and is a step toward fulfilling the promise of the president’s April 2022 Executive Order, which directs the Departments of Agriculture and the Interior to address threats to mature and old-growth forests on federal lands as a natural climate solution and develop policies to conserve them.

Members of the Climate Forests Campaign, a coalition of more than 120 organizations working to protect mature and old-growth trees and forests on federal land, welcomed the announcement as an important step forward while urging the Forest Service to pursue steps to protect mature trees. Both old-growth and mature forests are essential to removing climate-warming carbon pollution from the air and storing it, safeguarding wildlife, and providing clean drinking water for our communities.

The vast majority of old-growth forests have already been logged. Most that are left are largely on federally-managed public lands. As of November 2022, the Climate Forests Campaign had identified numerous timber sales targeting at least 370,000 acres of mature and old-growth forests for logging on federal land.

In addition to storing huge amounts of carbon and keeping it out of the atmosphere, mature and old-growth forests also provide essential wildlife habitats and are the most fire-resilient trees in the forest. As the world experiences record-shattering heat and widespread climate disasters, protecting these forests is critical to prevent the worst consequences of climate change.

The public will have an opportunity to weigh in on the proposal in a public comment period.

In response, environmental advocates issued the following statements:

“Protecting our old growth trees from logging is an important first step to ensure these giants continue to store vast amounts of carbon, but other older forests also need protection,” said Randi Spivak, public lands policy director with the Center for Biological Diversity. “To fulfill President Biden’s executive order and address the magnitude of the climate crisis, the Forest Service also needs to protect our mature forests, which if allowed to grow will become the old growth of tomorrow.”

“The Biden administration’s proposed plan to protect old-growth trees across the country is an important milestone for forest conservation and U.S. progress in addressing the climate crisis,” said Earthjustice senior legislative representative Blaine Miller-McFeeley. “Even as it works to complete this proposal, the Forest Service must take steps to fulfill President Biden’s executive order by also developing protections for mature trees, which are our future old-growth and exist in much greater numbers than old-growth, storing vast amounts of carbon. We look forward to working with the Forest Service to help it safeguard mature and old-growth forests. Conservation of these forests goes hand in hand with addressing the threat of wildfires as older and larger trees tend to be the most fire-resistant.”

“Americans love our forests. They’re natural playgrounds for people and wildlife alike. That’s why more than half a million people this summer asked the Forest Service to protect mature and old-growth trees and forests,” said Ellen Montgomery, Public Lands Campaign Director with Environment America. “Our mature and old-growth trees provide critical wildlife habitats, filter drinking water for communities and absorb and store tons of carbon. We’re really pleased that the Forest Service has taken this unprecedented step and we urge them to take actions to protect mature forests. To have a future where we have more old-growth, not less, it is critical to protect mature forests as well.”

“The Administration has rightly recognized that protecting America’s mature and old-growth trees and forests must be a core part of America’s conservation vision and playbook to combat the climate crisis,” said Garett Rose, senior attorney at NRDC. “This announcement is an important step toward meeting these goals. The Forest Service should move forward to develop the strongest possible safeguards for these forests.”

“Oregon Wild has been working to protect old-growth forests for 50 years. With today’s action, President Biden is taking a major step forward in protecting these national treasures,” said Lauren Anderson, Climate Forest Program Manager with Oregon Wild. “We look forward to working with his administration to implement this policy, and to ensure that mature and old-growth forests across the country are protected.”

“Our ancient forests are some of the most powerful resources we have for taking on the climate crisis and preserving ecosystems,” said Sierra Club Forests Campaign Manager Alex Craven. “We are pleased to see that the Biden administration continues to embrace forest conservation as the critical opportunity that it is. This amendment is a meaningful step towards averting climate catastrophe, safeguarding vulnerable ecosystems, and fulfilling President Biden’s commitment to preserve old-growth and mature trees across federal lands.”

“We applaud the Biden Administration for taking a significant step towards increasing protections for our nation’s endangered old-growth forests,” said Zack Porter, Executive Director of Standing Trees, an organization that works to protect and restore public lands in the six-state New England region. “But the reality is that more than 99.9% of old-growth forests in New England have already been cut down. For the climate and biodiversity, the Forest Service must put an end to destructive mature forest logging that prevents the recovery and expansion of old-growth forests across the US. We are buoyed by today’s announcement, and remain optimistic that the Forest Service will take further action to secure protections for America’s future old-growth forests.”

“Mature and old- growth forests are an essential component of a broader climate-crisis solution – but only if we protect them from logging,” said Adam Rissien, Rewilding Manager with WildEarth Guardians.  “Today’s announcement by the Forest Service establishes necessary and long-overdue protections for old growth forests, limiting when they can be cut and sold commercially. Taking the next step and developing a national rule covering both mature and old-growth would deliver on the Biden administration’s commitment to protect these trees once and for all.”