Top Line: The Forest Service has announced it is going to be proposing new regulations to address the “climate resilience” of the National Forest System. We can hope these will include the conservation and restoration of mature and old-growth forests and trees.
Figure 1. A very old Sitka spruce stand on the Siuslaw National Forest, Oregon. Source: Sumner Robinson (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
On the day before Earth Day 2023, an advance notice of proposed rulemaking and request for comment by the USDA Forest Service appeared in the Federal Register. Here is the summary:
The United States Department of Agriculture (USDA), Forest Service is inviting public feedback and initiating Tribal consultation on the following topic and additional questions: Given that climate change and related stressors are resulting in increasing impacts with rapid and variable rates of change on national forests and grasslands, how should the Forest Service adapt current policies to protect, conserve, and manage the national forests and grasslands for climate resilience, so that the Agency can provide for ecological integrity and support social and economic sustainability over time? [emphasis added]
This post will arm you with information you can use in making your comment.
Figure 2. Lodgepole pine matures and then enters its old-growth stage rather rapidly. The stand is renewed either by fire or insects. Notice the bald eagle in this stand on the Deschutes National Forest, Oregon. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
The Forest Service Concept of “Climate Resilience”
The Forest Service has embraced “climate resilience”—a term not found in any statutory law applying to the agency or its lands—as a new central organizing principle for the agency in administering its lands. Whether this “climate resilience” is worn as a mantle or wielded as a cudgel by the agency remains to be seen.
Figure 3. Old-growth ponderosa stand on the Fremont National Forest, Oregon. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
Interestingly, the Forest Service doesn’t expressly define climate resilience but rather says it “uses the [agency’s] Planning Rule’s definitions of ecological integrity and social and economic sustainability to structure the concept of climate resilience.”
Ecological integrity. The quality or condition of an ecosystem when its dominant ecological characteristics (for example, composition, structure, function, connectivity, and species composition and diversity) occur within the natural range of variation and can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.
Figure 4. Old-growth incense cedar on the Umpqua National Forest, Oregon. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
This definition of ecological integrity is okay. However, a problem is that a changing climate is creating conditions that are not within any “natural range of variation” that today’s ecosystems have ever encountered.
Sustainability. The capability to meet the needs of the present generation without compromising the ability of future generations to meet their needs. For purposes of this part,
• ‘‘ecological sustainability’’ refers to the capability of ecosystems to maintain ecological integrity;
• ‘‘economic sustainability’’ refers to the capability of society to produce and consume or otherwise benefit from goods and services including contributions to jobs and market and nonmarket benefits; and
• ‘‘social sustainability’’ refers to the capability of society to support the network of relationships, traditions, culture, and activities that connect people to the land and to one another, and support vibrant communities.
Figure 5. Old-growth Douglas-fir on the Umpqua National Forest, Oregon. Yes, the Forest Service thought it worth logging. Based on ring counts from nearby stumps, this tree is ~1,000 years old. Source: Umpqua Watersheds (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
Figure 5. Old-growth Douglas-fir on the Umpqua National Forest, Oregon. Yes, the Forest Service thought it worth logging. Based on ring counts from nearby stumps, this tree is ~1,000 years old. Source: Umpqua Watersheds (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
In other words, how, in the face of climate disruption, can the Forest Service manage the national forests and grasslands to produce what they have long produced? Such may be impossible.
Figure 6. Old-growth whitebark pine on the Fremont-Winema National Forest, Oregon. Source: George Wuerthner (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
The Two Components of Addressing Climate Change
It is good that the agency is addressing climate change. Such activity generally has two components, defined by NASA as follows:
Mitigation—reducing climate change—involves reducing the flow of heat-trapping greenhouse gases into the atmosphere.
Adaptation—adapting to life in a changing climate—involves adjusting to actual or expected future climate.
Regarding mitigation, a significant contributor to “the flow of heat-trapping greenhouse gases into the atmosphere” is carbon dioxide from logging. About half of any tree is carbon. Logging trees, hauling them to the mill, and then milling the logs into mostly short-lived (and the remainder midium-lived) wood products results in most of the carbon that was safely stored in long-lived forests ending up in the atmosphere. Disproportionately high amounts of carbon are stored in and sequestered by mature and old-growth forests. While the Forest Service doesn’t really grok this climatic opportunity, the White House does. The Forest Service sees it as a threat.
Figure 7. Old-growth Pacific yew tree in the Cascade Range, Oregon. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
As for adaptation, the Forest Service, basically being a culture of foresters who like to culture forests, is inclined to want to actively manipulate forests—mainly through logging—so the forests, in their view, will be better adapted to changed climatic circumstances. Just as it is for previously identified and branded problems of timber supply, forest health, forest resiliency, and/or forest fire, the Forest Service’s go-to solution to achieve climate resilience is logging. Logging for a different purpose, but logging nonetheless. (See “If Your Only Tool Is a Hammer Then Every Problem Looks Like a Nail.”)
Figure 8. Quaking aspen on the Ochoco National Forest, Oregon. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
Five Overarching Questions
In its advance notice of proposed rulemaking (ANPR), the Forest Service poses five “overarching questions.” Each is printed below in italics (starting with a bullet dot) followed by some commentary by me.
• How should the Forest Service adapt current policies and develop new policies and actions to conserve and manage the national forests and grasslands for climate resilience, so that the Agency can provide for ecological integrity and support social and economic sustainability over time?
Figure 9. Old-growth ponderosa pine on the bank of the North Fork Crooked River, Oregon. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
There is an inherent tension between “ecological integrity” and “economic sustainability.” One cannot have one’s forest and log it too. Especially in this time of climate catastrophe, preference must be given to nature over profit.
• How should the Forest Service assess, plan for and prioritize conservation and climate resilience at different organizational levels of planning and management of the National Forest System (e.g., national strategic direction and planning; regional and unit planning, projects and activities)?
Figure 10. Old-growth Sitka spruce stand on the Siuslaw National Forest, Oregon. Source: Elizabeth Feryl (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
Since 1960, with the enactment of the Multiple Use–Sustained Yield Act, the Forest Service has been authorized and required to “administer the renewable surface resources of the national forests for multiple use,” which means: “The management of all the various renewable surface resources of the national forests so that they are utilized in the combination that will best meet the needs of the American people.” It’s only been six decades, but never has the agency leadership told its field managers just what is “the combination that will best meet the needs of the American people.” The agency has long presumed that the sum total of all the decisions in the field that choose among the various statutory multiple uses (with timber and range almost always conquering watershed, fish and wildlife, and recreation) is collectively the best combination that meets the needs of the American people.
In these times of concurrent climate, biodiversity, and watershed crises, it is imperative for Forest Service leadership to tell the field what that best combination is. It is not a continuation of the status quo. Rather it is a strong statement directed to field managers to prioritize the conservation of watershed (quantity, quality, and timing), fish and wildlife (habitat and numbers), and forms of recreation compatible with such prioritization. It should deprioritize logging and domestic livestock grazing.
Figure 11. Old-growth ponderosa pine stand on the Malheur National Forest, Oregon. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
• What kinds of conservation, management or adaptation practices may be effective at fostering climate resilience on forests and grasslands at different geographic scales?
Figure 12. Old-growth ponderosa pine stand in the Blue Mountains, Oregon. Source: Leon Werdinger (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
Both historically and currently, logging, grazing, roading, mining, and similar activities impair “ecological integrity.” The most important thing the agency can do to prepare the national forests and national grasslands to cope with climate disruption is to cease the ecological irritants of logging, grazing, roading, mining, and similar activities. These irritants impede the ability of ecosystems to resist and be resilient to the forthcoming climate hell.
Figure 13. Old-growth western larch tree on the Malheur National Forest, Oregon. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
A remarkable new scientific paper entitled “The Importance of Natural Forest Stewardship in Adaptation Planning in the United States” offers guidance to forest managers. I will soon do a Public Lands Blog post on the subject. As a tease, here is the abstract of the paper:
Forests are critical to the planetary operational system and evolved without human management for millions of years in North America. Actively managing forests to help them adapt to a changing climate and disturbance regime has become a major focus in the United States. Aside from a subset of forests wherein wood production, human safety, and experimental research are primary goals, we argue that expensive management interventions are often unnecessary, have uncertain benefits, or are detrimental to many forest attributes such as resilience, carbon accumulation, structural complexity, and genetic and biological diversity. Natural forests (i.e., those protected and largely free from human management) tend to develop greater complexity, carbon storage, and tree diversity over time than forests that are actively managed; and natural forests often become less susceptible to future insect attacks and fire following these disturbances. Natural forest stewardship is therefore a critical and cost effective strategy in forest climate adaptation.
Figure 14. A very old Douglas-fir in the Valley of the Giants on Bureau of Land Management holdings in northwestern Oregon. Source: David Stone (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
I’ll be attaching the paper to my comments on the Forest Service’s ANPR.
• How should Forest Service management, partnerships, and investments consider cross-jurisdictional impacts of stressors to forest and grassland resilience at a landscape scale, including activities in the WUI?
Figure 15. Mature Brewer’s spruce in the Siskiyou Mountains of southwestern Oregon. The species is found only in the Klamath and Siskiyou Mountains of Oregon and California. Source: George Wuerthner (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
Here are a few ideas.
1. Stop funding the fighting of forest fires in states that (a) continue to allow housing development in the wildland-urban interface and (b) don’t mandate making existing buildings safe from fire.
Figure 16. Old-growth mixed-conifer (white/grand fir, western larch, ponderosa pine, Douglas-fir) stand in the Wallowa Mountains, Oregon. Source: Ric Bailey (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
2. Quit pouring most of the agency’s fire-fighting funds into late-season fires that cannot be extinguished anyway and pour the money instead into (a) allowing early- and mid-season fires to burn; (b) prescribed burns to restore fire to fire-starved ecosystems; and (c) making buildings near national forest land safe from fire so the Forest Service doesn’t waste money and risk lives protecting the houses of those who imprudently built in the wildland-urban interface.
Figure 17. Old-growth ponderosa pine stand in the Metolius Basin, Deschutes National Forest, Oregon. Source: Elizabeth Feryl (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
• What are key outcome-based performance measures and indicators that would help the Agency track changing conditions, test assumptions, evaluate effectiveness, and inform continued adaptive management?
How about acres not logged, board feet not produced, unnecessary road miles restored to be hydrologically invisible, necessary road miles made less damaging to wildlife and watershed, and acres of prescribed burns?
Figure 18. An older madrone tree in southwestern Oregon recently stressed by wildfire but recovering quite nicely. Fire is often the continuation or rebirth of a forest. Source: Ken Crocker (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
Relatedly, the Forest Service could quit rewarding its managers with financial compensation for getting out the timber cut (booked as “exceptional performance” or the like). Yes, the agency (and why, by the way, does the agency think that “Agency” is worthy of capitalization in the above question?) pays line officers for having met board-feet targets.
Figure 19. Old-growth Douglas-fir stand on the Willamette National Forest, Oregon. Source: Elizabeth Feryl (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
Save the MOG Forests
The Forest Service says its proposed rulemaking “builds on the ongoing work to implement section 2 of Executive Order 14072” (“Strengthening the Nation’s Forests, Communities, and Local Economies”). Later in the same paragraph, the Forest Service (grudgingly, I assure you) notes that
E.O. 14072 calls particular attention to the importance of Mature and Old-Growth (MOG) forests on Federal lands for their role in contributing to nature-based climate solutions by storing large amounts of carbon and increasing biodiversity.
Figure 20. Old-growth Douglas-fir stand in the proposed Douglas-Fir National Monument, Oregon. Find the northern spotted owl for scale. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
While no further reference to MOG forests can be found in the ANPR, a major need in the realm of new rulemaking is for the agency to promulgate an enduring administrative rule that conserves and restores mature and old-growth forests and trees to levels found on national forest lands before logging commenced.
Figure 21. An older mixed stand of Oregon white oak and ponderosa pine on the Mount Hood National Forest, Oregon. Source: Sandy Lonsdale (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
How You Can Help
The Climate Forests Campaign (CFC) is a coalition of conservation organizations seeking to have the Forest Service and the Bureau of Land Management protect and restore—though an enduring administrative rule—mature and old-growth forests and trees. Please go to the campaign’s “Take Action” page and take the actions recommended there. (Full disclosure: I am a member of the CFC planning committee.) The original deadline for public comments of June 20 has been extended to July 20.
Figure 22. Old-growth Douglas-fir stand on the Mount Hood National Forest, Oregon. Find the human for scale. Source: Elizabeth Feryl (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
For More Information
USDA Forest Service. April 21, 2023. “Organization, Functions, and Procedures; Functions and Procedures; Forest Service Functions: A Proposed Rule by the Forest Service.”
USDA Forest Service and USDI Bureau of Land Management. 2023. “Mature and Old-Growth Forests: Definition, Identification, and Initial Inventory on Lands Managed by the Forest Service and Bureau of Land Management: Fulfillment of Executive Order 14072, Section 2(b).”
Relevant previous Public Lands Blog posts:
May 10, 2022. “Biden’s Executive Order on Forests, Part 1: A Great Opportunity”
May 18, 2022. “Biden’s Executive Order on Forests, Part 2: Seize the Day!”
April 21, 2023. “Forests in the American East, Part 3: A Vision of the Return of Old-Growth Forests”
Figure 23. Mature and old-growth forests are not so much an inheritance from our ancestors as a loan from our successors. Source: Gary Braasch (first appeared in Oregon Wild: Endangered Forest Wilderness, Timber Press, 2004).
Bottom Line: What the Forest Service does—or does not do—to conserve and restore mature and old-growth forests to protect the climate, nature, watersheds, and scenery will have a significant impact on President Biden’s conservation legacy for this and future generations of Americans.