Top Line: The Forest Service’s announcement that it is going to amend all national forest land management plans to “conserve and steward” old-growth forests is a start, although it’s a third of a century late and the proposed amendment is as light on conservation as it is loose on stewardship. As now proposed, the amendment leaves out mature forests, and the agency would leave loopholes large enough for log trucks loaded with old-growth logs to drive through.
Figure 1. Old-growth Douglas-fir along the North Umpqua River on the Umpqua National Forest, Oregon. Source: Francis Eatherington.
Before reforming and improving public policy, a government first has to say it is going to do so. Most often, the first time—and even the second, third, and fourth times—a government says such, it does not actually mean such. But eventually, the bureaucracy is forced by politics to actually reform and improve. Such is the case with the Forest Service announcement that it is going to “conserve and steward old-growth forests” by amending all 128 of its national forest land and resource management plans at once.
Whether the Forest Service comes to mean what it says—and to do even more—will all come down to whether President Joe Biden makes that agency do what he told it to do in Executive Order 14072.
Figure 2. Old-growth hemlock, pine, and hardwoods on the Chattahoochee National Forest in South Carolina and Georgia. Source: American Forests (Alan Sandercock via Flickr).
Right Words, Wrong Wording
The Forest Service press release says the right things:
Healthy, climate-resilient old-growth forests store large amounts of carbon, increase biodiversity, reduce wildfire risks, enable subsistence and cultural uses, provide outdoor recreational opportunities and promote sustainable local economic development. . . . “Old-growth forests are a vital part of our ecosystems and a special cultural resource. This proposed nationwide forest plan amendment—the first in the agency’s history—is an important step in conserving these national treasures,” said Agriculture Secretary Tom Vilsack.
Figure 3. Vine maple in an old-growth forest on the Gifford Pinchot National Forest in Washington. Source: David Patte, US Fish and Wildlife Service.
But as always, the devil is in the details. While generally purporting that the Forest Service is going to protect old growth, the agency’s current proposal leaves open endless possibilities for mischievous logging in the name of old-growth conservation or other forest (ab)uses. Here are some examples:
• Clear-cutting of old-growth forests in Southeast Alaska would continue.
• Old-growth trees might be felled in the name of “reducing fuel hazards . . . to protect infrastructure from wildfire,” even though the only effective way to protect a building from burning in a wildfire is to treat the building itself, not the forest more than a hundred feet from it. The only way to prevent forest fires is to prevent forests.
• The Forest Service would reserve unto itself the ability to exempt its actions from the proposed plan amendment if it determines “that the direction in this amendment is not relevant or beneficial to a particular forest ecosystem type.” I am reminded of a statement made by Jim Furnish, now a recovering deputy chief of the Forest Service for the National Forest System, who, tongue firmly in cheek, characterized his former agency’s attitude as “Chainsaws are the answer; what was the question?”
• While saying, “Vegetation management within old-growth forest conditions may not be for the primary purpose of growing, tending, harvesting, or regeneration of trees for economic reasons” [emphasis added], the proposed amendment leaves room for such to be a secondary purpose. If one reads the agency paperwork on timber sales today, the sales are almost always touted in the name of things other than timber production, but down in the fine print, timber production is always a stated purpose. Did you know that agency officials often receive cash bonuses if they meet their timber quotas?
• In the production of its inventory on mature and old-growth forests, the Forest Service was adamant that it would not use modern scientifically based definitions of what constitutes an old-growth forest but rather would use the definitions it established in 1990. At the time, the agency’s unstated goal was to define “old growth” as narrowly as possible so as to limit the amount of older forest that might sometime be exempted from logging. For example, a West Virginia forest activist (and forester) has calculated that the modeled treeprints (think footprints) of the minimum twelve old-growth trees per acre needed to qualify as an old-growth forest according to the Forest Service is far greater than an acre. No wonder the Monongahela National Forest maintains that it has no old-growth forest.
Figure 4. A very small relic 120-acre grove of old-growth white pine, eastern hemlock, and beech on the Allegheny National Forest in Pennsylvania. Source: American Forests (Nicholas A Tonelli via Flickr).
Widening the Scope and Narrowing the Focus
The Forest Service is now, in the parlance of the National Environmental Policy Act, “scoping” in anticipation of preparing an environmental impact statement on its proposal. Here are a few things the agency could do to adequately meet the mandates of the president’s executive order on forests and also his executive order on 30x30 (conserving 30 percent of the nation’s lands and waters by 2030).
Modernize the Definitions of an Old-Growth Forest
One can get caught up in the minutia of what constitutes an old-growth forest. How many large/old trees per acre must it have? How many snags (standing dead trees)? How much large downed wood? Must the canopy be multilayered? Is it “old growth” if it was ever logged, no matter how intensely and/or long ago?
Or one could simply define an old-growth tree as at least 150 years old on national forests west of the 100th meridian and 120 years old east of the 100th meridian. (To easily find the 100th meridian, extend the western boundary of Oklahoma sans the panhandle north and south.) In general, forest ecosystems age earlier into an old-growth condition in the American East than in the American West.
And one could define an old-growth forest as an acre of forest that contains more than two old-growth trees.
Conserve Mature Forests and Trees
The president, in his executive order, directed the conservation of both mature and old-growth forests. The agency was rocked by the inclusion of mature forests with old-growth forests and is still reeling. The Forest Service’s response is to ignore mature forests as much as possible. Mature forests and trees are but old-growth forests and trees in waiting. If we are to have more old growth than we have now, mature stands and trees must be comparably conserved.
Provide Both Stand- and Tree-Level Protections
No old-growth tree should be logged (“cut down . . . in order to exploit the timber commercially”) for any reason. There are some rare cases where an old-growth tree needs to be cut down for reasons of public safety. But such a tree should be left in place or placed in a nearby stream to address a shortage of large wood in that stream due to previous logging.
In addition, no old-growth stand should be logged. However, it can be scientifically justified to kill, cut down, and/or remove certain problematic younger trees that are threatening old-growth trees in drier forest types due to past logging, livestock grazing, and/or fire exclusion. Again, the boles (aka “logs”) of the larger younger trees should not be allowed to enter commerce.
Contribute Toward 30x30
To contribute to the attainment of 30x30, an area of conserved land must be dedicated to the preservation of biological diversity and adequately protected from the loss of such. The Forest Service should establish all old-growth stands as “special interest areas,” its strongest possible form of administrative protection. It should also withdraw the lands from the application of the mining laws. (See the Public Lands Blog post “30x30: Biden Administration Needs to Up Its Game.”)
Figure 5. Old-growth forest in the Oregon Coast Range. Source: US Geological Survey.
And What About . . . ?
Bureau of Land Management Forested Holdings
While the mature and old-growth (MOG) inventory is a joint project of the Forest Service and the Bureau of Land Management, the Forest Service’s proposed nationwide forest plan amendment won’t affect the 12.7 and 8.3 million acres respectively of mature and old-growth forest on BLM holdings. While BLM lands are most generally known for their tree-free ecosystems, they do include 34.2 million acres of forest. (See the Public Lands Blog post “The Forested Estate of the Bureau of Land Management.”)
The BLM should soon issue a “conservation rule,” which will likely address MOG forest conservation and restoration at only a very superficial level. The BLM should designate all of its MOG forests as areas of critical environmental concern and also withdraw them from the application of the mining laws (look for a Public Lands Blog post to come).
Pinyon-Juniper Woodlands
In its December 19, 2023, fact sheet on its commitment to protect old-growth forests, the White House notes that
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 fact sheet informs us that the Forest Service and the BLM “will co-host a public workshop focused on the conservation of these ecosystems in 2024” (look for a Public Lands Blog post to come).
Figure 6. Old-growth western juniper in central Oregon. Source: Bonnie Morland (Flickr).
The End of the Beginning
The Forest Service has been forced by public opinion via pressure from the White House to say it is going to conserve old-growth forests. It will now have to be forced to actually do what it says it’s going to do. This will require the public to further share their opinions with the White House to encourage it to further direct the Forest Service to do more.
At the same time as the public lands conservation community is celebrating that the Forest Service is starting to go through the motions of conserving older forests, conservationists must keep in mind the words of that great conservationist Winston Churchill: “Now this is not the end. It is not even the beginning of the end. But it is, perhaps, the end of the beginning.” Churchill was speaking of the Second Battle of El Alamein in October and November of 1942. This marked the first time the fascists were clearly defeated in battle in World War II.
A better analogy for this point in the war to save and restore mature and old-growth forests in the United States might be the Allied invasion of Normandy in June 1944. There is much more hard fighting to come, but victory is inevitable.
What You Can Do
The Forest Service, Secretary of Agriculture, and President need to hear from you. If you are a card-carrying member of a conservation organization you will have been contacted or likely will soon contacted to take action. You should then take action. You can also take action at web pages of these organizations:
Figure 7. Old-growth ponderosa pine in the Klamath-Siskiyou ecoregion. Source: KS Wild.
For More Information
Kerr, Andy. June 5, 2023. “How Much Mature and Old-Growth Forest Does the US Have Left?” Public Lands Blog.
LeGue, Chandra. 2019. Oregon’s Ancient Forests: A Hiking Guide. Seattle: Mountaineers Books.
The White House. December 19, 2023. “FACT SHEET: Biden-Harris Administration Advances Commitment to Protect Old Growth Forests on National Forest System Lands.”
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).
USDA Forest Service. December 19, 2023. “USDA Proposes First-of-its Kind National Forest Plan Amendment to Conserve and Steward Old Growth Forests” (media release).
———. December 20, 2023. “Land Management Plan Direction for Old-Growth Forest Conditions Across the National Forest System: Notice of Intent to Prepare an Environmental Impact Statement.” Federal Register.
———. No date. Mature and Old-Growth Forests: Explore the Data (interactive heat map of relative presence or absence of mature and old-growth forest on the National Forest System).
USDI Bureau of Land Management and USDA Forest Service. No date. Pinyon-Juniper Woodlands (pdf).
Bottom Line: If President Biden wants to be remembered in history for saving the nation’s remaining mature and old-growth forests and trees for the benefit of this and future generations, the Forest Service is going to have to do significantly more than what it has proposed so far.