Proposed National Forests Old-Growth Amendment
On June 20th, the U.S. Forest Service (USFS) released its draft Environmental Impact Statement, outlining its proposal for the conservation of old-growth forests across the National Forest system. The National Old-Growth Amendment (NOGA) proposed rule is in response to Executive Order 14072 directing the agency to “…further conserve mature and old-growth forests and foster long-term United States forest health through climate-smart reforestation for the benefit of Americans today and for generations to come…”
The NOGA is an unprecedented action that seeks to amend 128 existing federal forest plans, introducing components that claim to conserve and protect old-growth while providing “consistency” to ensure the persistence of current and future old-growth across the National Forest system.
Regrettably, despite these noble intentions, this initiative is likely to create a planning quagmire for local units, inadvertently jeopardize forest health, and erode the trust the agency has carefully built with its partners. This top-down, trickle-down approach not only fails to meet the regulatory requirements for amending forest plans but also necessitates an adaptive management plan that bypasses public input. Moreover, it overlooks the real threats of wildfire, insects, and disease, potentially leading to a decline in forest health.
Earlier in June, the USFS released its report, “Mature and Old-Growth Forests: Analysis of Threats on Lands Managed by the Forest Service and Bureau of Land Management.” This analysis revealed that since 2000, wildfires, insects, and diseases have contributed to a net decrease of over 850,000 acres of old-growth forests. In contrast, tree-cutting has led to a net decrease of just 9,000 acres over the same period. These findings underscore that the true threats to old-growth forests are natural disturbances that negatively impact our national forests. Unfortunately, due to past decisions by the USFS, our national forests are not resilient to these disturbances.
In its amendment, the USFS proposes various plan components that will influence the future management of National Forest lands. The agency claims that this trickle-down approach will create consistency in the management of old-growth across 193 million acres of National Forest lands. However, the analysis indicates that these plan components will not supersede existing old-growth management strategies. Instead, individual national forests will be required to develop adaptive management strategies for old-growth and future old-growth management, effectively creating decision documents without public input at the local level. Unfortunately, the effort to create a consistent approach to old-growth management is likely to result in a complex web of analysis requirements, ultimately reducing active management across the National Forest system and increasing the rate of disturbances that negatively impact old-growth on federally administered lands.
Beyond complicating analysis, the effort to amend 128 forest plans through a single process contradicts the 2012 Planning Rule, which requires extensive public involvement at both local and regional levels. Given the truncated timeline for this amendment, it is impossible to fully understand the social, ecological, and economic impacts these plan components will have on individual forest units and the rural forest-based communities that rely on timber harvested from federal lands.
The proposed NOGA amendment falls short of its goal to conserve old-growth and recruit future old-growth across the National Forest system. This approach will affect each forest differently, depending on their existing plan components. It does not address the actual threats to old-growth, such as fire, insects, and disease, and it disproportionately impacts the planning process by creating a regulatory nightmare. Our National Forests deserve better. Management and conservation decisions should be driven from the ground up, not imposed from the top down.
As an alternative, the Forest Service should direct individual national forests to address old-growth forest management in future planning efforts across the National Forest system. This approach would allow each forest to identify and analyze the effects of the proposed direction on their individual forests and ensure that the Forest Service is adequately protecting old-growth.
