Old Growth

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: https://www.fs.usda.gov/managing-land/old-growth-forests

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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!

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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.
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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.

We’ll all need a glass or two before this one is over..

A hearty thank you to Nick Smith, who always has something interesting in his daily update. Here’s this one.

I don’t think anyone will be surprised to learn that people (wait for this…!) don’t agree on what is an old forest. In fact, we’ve discussed at least two incarnations of the same issue, during spotted owl days (1994), and HFRA development days (2002).

I got a chuckle out of this on Google.. question “What is the Northwest Forest Plan 1994?”

In 1994, the comprehensive Northwest Forest Plan (‘the Plan’) was initiated to end the impasse over management of federal forest land in the Pacific Northwest within the range of the northern spotted owl.

As my song parody went during the HFRA days (to the tune of They Call the Wind Maria, from Paint Your Wagon)

But old trees die, and then fall down,
And we’ve got premonitions-
But we’ll do fine,
We’ll move the lines,
And change the definitions!
Reserves, Reserves, we call those areas Reserves.

Fortunately they asked a knowledgeable prof, Dr. Mark Ashton from Yale who said:

Any definitions for old-growth or mature trees adopted by the Biden’s administration are “going to be subjective,” said Mark Ashton, a forestry professor at the Yale School of the Environment.

Already disagreement is emerging between the timber industry and environmentalists over which trees to count. That’s likely to complicate Biden’s efforts to protect older forests as part of his climate change fight, with key pieces stalled in Congress.

“If you were looking at ecological and academic definitions of old growth, it’s going to be very different from what the White House is thinking about,” Ashton said. “Even the word ‘mature’ is difficult to define.”

Groves of aspen, for example, can mature within a half century. For Douglas fir stands, it could take 100 years. Wildfire frequency also factors in: Ponderosa pine forests are adapted to withstand blazes as often as once a decade, compared to lodgepole pine stands that might burn every few hundred years.

There’s wide consensus on the importance of preserving the oldest and largest trees — both symbolically as marvels of nature, and more practically because their trunks and branches store large amounts of carbon that can be released when forests burn, adding to climate change.

But what exactly is “mature”? My discipline (always the underdog in any disciplinary discussion) would say “reproductive maturity.” I can almost hear the buzz.. wrong answer. Yes, a lodgepole stand might burn every two hundred years, but bark beetles often get them earlier. Once again, it seems like it’s difficult to get the mesic mindset (leave them alone) and the dry forest reality (they’ll get eaten or burn up or both) to form a coherent set of talking points.

Yay! Bipartisan agreement.

Concerns that warming temperatures, fires and disease could doom the dwindling number of ancient trees on federal forests drew a bipartisan group of lawmakers to California this month. They touted planned legislation to preserve perhaps the most iconic old growth in the U.S.: stands of massive sequoias that can tower almost 300 feet (90 meters).

Somehow I don’t think Hayes knows more about this than Ashton. Clearly he is quoting Groups Important to this Administration:

White House adviser Hayes described old growth forests generally as undisturbed stands with well-established canopies and individual trees usually over 150 years old.

“Mature forests,” he added, “are generally 80 to 150 years old and have many of the same characteristics of old-growth forests or are on their way to developing those characteristics if left undisturbed.”

Yes, “on their way to being old” would pretty much cover a lot of territory. Somehow the 80 number seems to have taken on a life of its own.

But let’s look at Hayes’ background. He’s a climate advisor with a background in environmental law. Interestingly, he was also a senior fellow at the Hewlett Foundation, who have a rather colonialist attitude toward the American West.

The vision of the Hewlett Foundation is to conserve biodiversity and protect the ecological integrity of half of the North American West for wildlife and people. Our goal is to conserve 320 million acres of public and private land across the North American West by 2035.

The Hewlett Foundation’s Environment Director also joined the Biden Admin working for John Kerry on climate. They also fund the Center for Western Priorities which has a good daily roundup of news but is run by political operatives, definitely with a partisan twist.

Fortunately, the Forest Service folks are (back) on this. Probably all the folks from the previous old growth efforts have retired.

Officials were developing a “workable definition” that would be made public, Hayes said. “Then based on a good definition, there will be the opportunity to … get real and protect these stands and safeguard them to the greatest extent we can from the threats that they face.”

Threats could include fire, drought, competition with younger trees, insect infestation and timber harvests, agency officials said in a statement. How those rank won’t be known until after the inventory.

I think the FS already knows how to deal with fire, drought, and competition.. take out smaller trees. And has gotten large chunks of change to do that, and also to figure out ways to use the material. Funded in the Bipartisan Infrastructure Bill and other places. Still, I’m not seeing many options, though, that will keep old lodgepoles from bark beetles.

Aside: one of the forests in Region 2 had a concern with Roadless that they wouldn’t be able to go in and get spruce beetle killed trees removed before they became an outbreak. I don’t think this made it into the Rule, though. Perhaps the FS will amend Roadless rules to enable more insect infestation prevention? Just kidding.

And from CBD:

They want the administration to adopt specific rules to protect those forests, rather than vague management plans that would be easier for a future Republican administration to reverse. Environmentalists also want to stop pending logging projects on federal lands in Oregon, Wisconsin, South Dakota, Montana, Idaho and other states.

“This executive order clearly calls out the need for protections,” said Randi Spivak with the environmental group Center for Biological Diversity. “I’m concerned the Forest Service will slow walk this until the clock runs out.”

Spivak acknowledged that definitions of mature may vary among different tree species, but said complexity was no excuse to avoid acting.

“If you’re looking for one age, 80 years is a good cutoff,” she said.

No whiskey for you, Dave and Randi! It’s looking like some wine is questionable also.

Note that the FS is back to being the fall person (“slowly walk this out”) when the current Administration doesn’t do what ENGOs want.. under the Trump Admin it was all Trump’s fault. And so it goes.

It’s interesting that the EO was leaked to “five individuals” who gave it to the WaPo.  So those news stories had certain spins.  After reading it, there are other items of interest. Note the actual title mentions both communities and local economies.

Here’s the link.

The Infrastructure Investment and Jobs Act (IIJA) I signed into law provides generational investments in ecosystem restoration and wildfire risk reduction.  As we use this funding, we will seek opportunities, consistent with the IIJA, to conserve our mature and old-growth forests on Federal lands and restore the health and vibrancy of our Nation’s forests by reducing the threat of catastrophic wildfires through ecological treatments that create resilient forest conditions using active, science-based forest management and prescribed fires; by incorporating indigenous traditional ecological knowledge; and by scaling up and optimizing climate-smart reforestation.

I could interpret that to mean.. where sections of the Bipartisan Infrastructure Bill say “do treatments for restoration and to protect communities” the agencies will also take into account old forests. Note that this says forests, not individual trees.  So if you need to thin individual old trees to ultimately protect the old forests, then you will.  This seems pretty innocuous.

In section 2, the EO starts to mention reforestation.  Actions are intended to

further conserve mature and old-growth forests and foster long-term United States forest health through climate-smart reforestation

I don’t exactly see how reforestation directly conserves mature and old-growth forests (more like develops replacements) but OK. And here’s the guts of the domestic land management actions:

(a)  The Secretary of the Interior and the Secretary of Agriculture (Secretaries) — the Federal Government’s primary land managers — shall continue to jointly pursue wildfire mitigation strategies, which are already driving important actions to confront a pressing threat to mature and old-growth forests on Federal lands:  catastrophic wildfires driven by decades of fire exclusion and climate change.

(b)  The Secretary of the Interior, with respect to public lands managed by the Bureau of Land Management, and the Secretary of Agriculture, with respect to National Forest System lands, shall, within 1 year of the date of this order, define, identify, and complete an inventory of old-growth and mature forests on Federal lands, accounting for regional and ecological variations, as appropriate, and shall make such inventory publicly available.

(c)  Following completion of the inventory, the Secretaries shall:

(i)    coordinate conservation and wildfire risk reduction activities, including consideration of climate-smart stewardship of mature and old-growth forests, with other executive departments and agencies (agencies), States, Tribal Nations, and any private landowners who volunteer to participate;

(ii)   analyze the threats to mature and old-growth forests on Federal lands, including from wildfires and climate change; and

(iii)  develop policies, with robust opportunity for public comment, to institutionalize climate-smart management and conservation strategies that address threats to mature and old-growth forests on Federal lands.

(d)  The Secretaries, in coordination with the heads of other agencies as appropriate, shall within 1 year of the date of this order:

(i)    develop a Federal goal that charges agencies to meet agency-specific reforestation targets by 2030, including an assessment of reforestation opportunities on Federal lands and through existing Federal programs and partnerships;

(ii)   develop, in collaboration with Federal, State, Tribal, and private-sector partners, a climate-informed plan (building on existing efforts) to increase Federal cone and seed collection and to ensure seed and seedling nursery capacity is sufficient to meet anticipated reforestation demand; and

(iii)  develop, in coordination with the Secretary of Commerce, with State, local, Tribal, and territorial governments, and with the private sector, nonprofit organizations, labor unions, and the scientific community, recommendations for community-led local and regional economic development opportunities to create and sustain jobs in the sustainable forest product sector, including innovative materials, and in outdoor recreation, while supporting healthy, sustainably managed forests in timber communities.

I can’t comment on the international parts of the EO, but there are some “nature-based solutions to tackle climate change and enhance resilience” actions as well.  “Nature-based solutions” seem to be doing good things for climate without them counting as offsets.

(a)  The Chair of the Council on Environmental Quality, the Director of the Office of Science and Technology Policy, and the Assistant to the President and National Climate Advisor shall, in consultation with the Secretary of Defense (through the Assistant Secretary of the Army for Civil Works), the Secretary of the Interior, the Secretary of Agriculture, the Secretary of Commerce (through the Administrator of the National Oceanic and Atmospheric Administration), the Secretary of Housing and Urban Development, the Secretary of Transportation, the Secretary of Energy, the Secretary of Homeland Security (through the Administrator of the Federal Emergency Management Agency), the Administrator of the Environmental Protection Agency, the Administrator of the Small Business Administration, and the heads of other agencies as appropriate, submit a report to the National Climate Task Force to identify key opportunities for greater deployment of nature-based solutions across the Federal Government, including through potential policy, guidance, and program changes.

(b)  The Director of the Office of Management and Budget shall issue guidance related to the valuation of ecosystem and environmental services and natural assets in Federal regulatory decision-making, consistent with the efforts to modernize regulatory review required by my Presidential Memorandum of January 20, 2021 (Modernizing Regulatory Review).

The stated reason to “Modernize” in the PM is:

As we do so, it is important that we evaluate the processes and principles that govern regulatory review to ensure swift and effective Federal action.  Regulations that promote the public interest are vital for tackling national priorities.

It doesn’t seem to me that adding more things to calculate would necessarily lead to increasing swiftness or effectiveness. It could simply deepen the regulatory word-swamp;.

(c)  Implementation of the United States Global Change Research Program shall include an assessment of the condition of nature within the United States in a report carrying out section 102 of the Global Change Research Act of 1990, 15 U.S.C. 2932.

An assessment of the “condition of nature within the US” sounds like it could be duplicative.

All in all, it seems like any regulatory changes would be further down the road after the inventory, and with lots of public involvement. All that is good.  More work for the poor FS and BLM who are trying to spend Infrastructure $ and do fire suppression; and start hundreds or thousands of NEPA processes.  But they might not get to the end of rulemaking before 2024, and politicians tend to be sensitive to making controversial decisions in an election year (with some notable exceptions).  So we’ll see how it all plays out.

While we’re waiting for the text of the mature/old forest EO, let’s look somewhere different than the old western wet forest/dry forest challenges. Plus it’s Friday and the weekend approaches, so…

I think that this may be the first TSW link to the Wine Enthusiast. Turns out that for barrel staves, white oak trees need to be 80 to 100 years. And some of the practices to keep white oak in the mix for future generations include “crop tree release”, which might involve cutting old trees of white oak and other species. But white oaks are important for wildlife and biodiversity, so we definitely want to keep them the mix.

Suppose that there were a policy that no 80 year old trees could be cut on the national forests that have white oak? Looks like people are seriously concerned about losing that species, due to competition from other species, as well as other factors. Yes- if you don’t cut them, they will be around longer; but it looks like if you leave the stands alone in many cases you won’t get white oak back. Suppose the old white oaks die naturally; but then the formerly understory species would be old, and you couldn’t cut them either. So adios white oak on national forests?

Anyway, for those unaware of the White Oak Initiative, IMHO those folks have done a tremendous job of bringing researchers, practitioners and landowners together to figure out what the species needs and how to manage for it. It’s really an impressive effort.  I don’t know whether any people or groups are against it. Maybe because success depends on private landowners, it’s not so ideological as our own western debates.

It’s always interesting to see how our issues as complex and convoluted as they are, are addressed by folks in the media. What struck me is that based on future definitions of mature trees and forests, we could have planted forests that now need to be protected in the west, and certainly in other parts of the country.

From the WaPo today 

While scientists agree that forests are important to slowing climate change, many say that years of wildfire suppression policies have led to dense forests that are fueling more extreme fires. Some of the strategies to address this involve thinning out small trees, clearing dry brush and intentionally setting beneficial fires. But federal agencies have also contracted with timber companies to clear land for fire breaks and cut down larger trees that they say threaten homes and communities.

Critics have argued that this approach amounts to a giveaway for timber companies who they say helped make American forests crowded by logging the largest, oldest trees. The many younger trees that sprung up in their place burn more easily and often don’t survive the more destructive wind-driven wildfires that have torn through the West in recent years.

Whose views are not incorporated in this story? Federal agencies nor the timber industry. Remember when the Trump Admin was bad and federal agency folks were good? Now the Biden Admin (new policy!)is good and things federal agencies have been doing questionable things…

Below is the rest of the article. More details tomorrow.

The president’s order, however, will not ban logging of mature and old-growth trees, they added, and the administration is not considering a nationwide prohibition. It will include initiatives aimed at curbing deforestation overseas, promoting economic development in regions with major timber industries and calculating the economic value of other natural resources such as wetlands.

While Democrats and environmentalists will likely welcome the order, it does not have the same force as legislation and could be reversed under a future president. The new order would not go as far as a bill Democratic Sen. Brian Schatz (Hawaii) and Rep. Earl Blumenauer (Ore.) have written, which would restrict the trade of commodities linked to forest clearing, such as palm oil and beef.

The move reflects the administration’s broader strategy to fight climate change by conserving more land in the United States — and more of the trees that store the most carbon. A 2020 study of six national forests in the Pacific Northwest, for example, found that just 3 percent of the largest trees contained roughly 42 percent of the carbon.

Earlier this year, more than 70 environmental groups launched a campaign calling on Biden to enact new protections for mature and old-growth trees — generally, those over 80 years old — which currently aren’t prohibited from being turned into lumber.

In November, Democratic members of Congress wrote to Secretary of Agriculture Tom Vilsack, urging him to protect older forests and warning that allowing these trees to be harvested would undermine the president’s climate goals because it would release a massive amount of planet-warming pollutants.

“Allowing logging of mature and old federal forests should become a practice of the past,” they wrote.

Scientists consider forests to be critical carbon sinks, meaning they absorb more carbon dioxide than they release into the atmosphere. Old-growth trees, such as California’s redwoods and giant sequoias or the mammoth Sitka spruce and red cedar trees in Alaska’s Tongass National Forest, collectively store billions of tons of carbon dioxide in their trunks, branches and roots. Protecting them could help avert the worst effects of climate change.

Placing safeguards on older trees could be hugely controversial.

Timber companies are likely to object to any new limits on their access to trees in federal forests, and experts will debate what counts as a mature tree. A loblolly pine in the Southeast and a ponderosa pine in the West grow at vastly different rates, complicating efforts to define maturity as a set number of years across multiple species.

In writing new policies, the administration will also have to walk a line between preserving older trees on federal land and giving managers enough flexibility to assure those forests’ health.

While scientists agree that forests are important to slowing climate change, many say that years of wildfire suppression policies have led to dense forests that are fueling more extreme fires. Some of the strategies to address this involve thinning out small trees, clearing dry brush and intentionally setting beneficial fires.

But federal agencies have also contracted with timber companies to clear land for fire breaks and cut down larger trees that they say threaten homes and communities.

Critics have argued that this approach amounts to a giveaway for timber companies who they say helped make American forests crowded by logging the largest, oldest trees. The many younger trees that sprung up in their place burn more easily and often don’t survive the more destructive wind-driven wildfires that have torn through the West in recent years.

The fight over old-growth forests has been going on for decades. In 1991, a federal judge blocked all logging of old-growth trees in the Pacific Northwest’s national forests to protect the northern spotted owl’s shrinking habitat. Republican and Democratic administrations have put in place dueling logging rules since then, and environmentalists have brought lawsuits that have curtailed several timber sales.

A tSW community member suggested a joint fact-finding discussion around the question of how much logging old-growth and clearcutting still goes on in the FS (and perhaps BLM).  One of the difficulties with this discussion is that the definitions are unclear, as we have seen, and different communities use different definitions.  So, of course, it makes sense to look at specific projects that have been proposed or carried out. What I hope to be an enlightening journey for all of us from the generic to the specific.

When I worked on Capitol Hill, one of the perks was to attend free food and drink events put on by different groups (OK, and learn about their views as well).  I remember attending a session of a nature writers’ group which was fascinating, as they talked about the same things we dealt with at work (trees, forests), but from a completely different perspective with different language.

This Orion article by a writer named Rick Bass, is a peek into that world.

When I sleep, I am not aware of the threat of doom. The thousand-year-old forest that well may not live to be 1,001. All of it, obliterated, shattered, bombed.

The fuse has been lit. The fuse is burning. The government, under the previous administration, but abetted yet by the current one, says it’s time for this thousand-year-old forest to become “resilient.” Says that logging it down to dust—effectively, a thousand-acre clearcut—is the way to teach it resilience. They’ve named this proposed project, this fever dream, a remnant zombie from the previous reign, “Black Ram.”

When a forest gets to be this old and untouched, it becomes something more than a forest. It becomes what we would think of as a mind, with history, knowledge, memory, and foresight. It has a pulse, and a spirit incomprehensible to us—but we can feel it when we’re in its presence. There aren’t many like this one left. Maybe none in Montana. Regional minor timber barons and public servants in the Forest Service’s timber shop will scoff at such an idea, but when you step into this ancient garden, you feel not just all that is above, but also so much of what lies below. It’s humbling, recognizing that, though we may be in the middle, we are not the center. Through the phenomenon of gap creation, the forest is in perfect balance, growing and rotting. Never burning. Though rot, of course, is but a slow gentle fire of its own. The circular amid the linear rot, the ancient geometry of the disassembly building a nest that is, before our eyes and all the other senses, a miracle of reassembly. Life, lived slowly; life, lived so large.

I will not tell you that the old and mature forests store 70 percent more carbon than do the monoculture plantations planned for these public lands. I will tell you instead that I can no longer go into this old forest without falling asleep. Maybe in that fashion the universe is, even now, seeking to balance itself, as it used to do once upon a time, before we broke so very many things. Maybe my sleeping creates a space for someone else to wake up. Please, God, let that person be the current president, himself but a grain of sand and gnat-blink to this forest, and to time.  

The first think I notice is the writing is absolutely beautiful.. not like a forest plan, an EIS or even most posts on TSW. The beauty of the words might make us less inclined to poke at the basis for the knowledge claims. For example, “When a forest gets to be this old and untouched, it becomes something more than a forest.” It’s OK to be a mystic. I’m a mystic in the line of Hildegard of Bingen. But mystical knowledge claims are usually hard to make in our post-Enlightenment materialist society. Or, perhaps, sometimes they are OK and sometimes not (talking to angels). Something to watch.

It’s also interesting how science fits into this in the author’s view.

If science were still revered in this country, it would possess what scientists call baseline data. But we are not going to talk about science here. Science went away in the previous administration, and we are waiting to see to what extent the current one will bring it back. We’re still waiting.

This seems a bit of an overstatement to me (think Fauci and Collins) but OK that’s what polemicists do.

Through the phenomenon of gap creation, the forest is in perfect balance, growing and rotting. Never burning.

The idea of “balance” is one of many ideas about Nature. For other ideas check out our discussion of Dan Botkin’s book “The Moon in the Nautilus Shell.” Dan was also frustrated that “the science” wasn’t coming through in policy, in terms of acknowledging that ecosystems are dynamic, and nature is not in “balance.”

On the other hand, these specific claims should be able to be investigated by reviewing the decision documents “monoculture plantations planned for these public lands” “”thousand acre clearcuts” and “thousand year old forest.”

But this post has gotten too long, and so I’ll take that up in the next post. Plenty of philosophy and science claims to discuss here, and beautiful writing to read.