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Prioritizing America's Old-Growth Forests

Published: March 8, 2024 by

In the closing days of 2023, the U.S. Department of Agriculture published a Notice of Intent (NOI) in the Federal Register as part of a process to amend all 128 national forest land management plans with consistent direction to manage, conserve and steward old-growth forests. This action advances a broad Mature and Old Growth Forests initiative spurred by an Executive Order from President Biden issued on Earth Day 2022, which highlights the role of these forests as nature-based climate solutions. Accordingly, federal agencies have been working to define and inventory these forests, conduct a threat assessment, and establish a nation-wide management framework.

The USDA is proposing an amendment that will prohibit vegetation management in old-growth forests for economic reasons on national forests; no traditional revenue-focused logging will be permitted except under a limited set of circumstances as outlined in the NOI. With the recent identification of 25 million acres of old-growth forests and 68 million acres of mature forests across the USDA Forest Service’s 193-million-acre land base, this amendment has far-reaching implications for economic vitality and ecological conditions at local scales and on the United States’ national carbon budget.

Reactions to this initiative and proposed amendment have predictably been charged. The Environmental Law & Policy Center reported last year that half a million people “submitted comments calling on the U.S. Forest Service to enact a rule that protects mature and old-growth forests from being chopped down,” referencing a commonly held belief that logging is a primary threat to federally-managed forests. In fact, the threat assessment conducted for forests managed by the USDA Forest Service and USDI Bureau of Land Management found that while harvesting was the foremost cause of mature and old-growth forest decline between 1950-1990, tree cutting between 2000-2020 had a minimal impact on mature and old-growth acres. The 2.5-million-acre net decline of mature forests over the past 20 years (0.28 million acres of which transitioned to old growth) was primarily caused by fire, (3.28 million acres) and insects/disease (2.042 million acres). Timber harvest on federal lands accounted for just 0.223 million acres of mature and old-growth forest loss.

Almost paradoxically, the threat analysis found that nearly half of federally-managed mature and old-growth forests exist in firesheds where mill capacity is low and environmental threats, such as severe fire, are high. These regions may therefore struggle to engage in the active forest management needed to mitigate factors posing the highest risk to these forests. In this vein, forest industry groups such as the Federal Forest Resource Coalition (FFRC) and the Society of American Foresters (SAF) have separately published statements emphasizing the need to build administrative capacity to actively manage the most imminent threats to our federal forests. These groups have urged federal agencies to take a long view when determining whether to ‘maximize’ immediate forest carbon gains using passive management or to ‘optimize’ forest carbon through expanded forest thinning and other active management options.

An Environmental Impact Statement detailing expected outcomes of the forest plan amendments will be published in May of this year, followed by a 90-day public comment period. This document will translate much of the foundational theory and research into specific practices and outcomes engendered by the prioritization of mature and old-growth forests in federal policy. The Climate Trust will continue to follow these developments and lend our voice to the national conversation where appropriate.