Need to Know:
At the national level, we have a once-in-a-lifetime opportunity to make our voices heard. As part of President Biden’s Executive Order to protect mature and old-growth forests on federal lands, the U.S. Forest Service has proposed amending management plans for all U.S. national forests to restrict the logging of old-growth and encourage the development of future old-growth forests. The National Old-Growth Amendment (NOGA) is the closest we have come to real protections for the forest!
The Draft Environmental Impact Statement (DEIS) for this proposal was released on June 21, 2024, and launched a public comment opportunity that runs through September 20, 2024. Unfortunately, in its current form, the agency’s proposal represents more greenwashing and allows continued logging of old-growth like we are seeing in the South Red Bird project.
Mature forests and trees need explicit protections. Mature forests provide the bulk of the climate benefits on federal forests and are vital for sustaining biodiversity and mitigating climate change. The country has lost most of its old-growth to over a century of logging. But we can protect what’s left and foster a future where old growth is no longer a relic of the past.
This is a monumental undertaking and an opportunity that you do not want to miss. We may not get another chance. If enough of us write in before the September 20th deadline, we could finally end the harmful practice of logging our old-growth forests for profit and chart out a new course to allow mature trees to keep growing and become the next generation of old-growth.
Renowned environmental activist Alex Haraus and cinematographers Aidan Kranz and Elena Jean spent the last year exploring some of the last remaining ancient forests on public lands in the US. These forests - mature and old-growth forests - offer one of our best natural defenses against the impacts of climate change. But these carbon-storing powerhouses are so much more than that.
As the film crew travels from the rolling hills of West Virginia to the serene valleys of Wisconsin and temperate rainforest of Oregon, they learn more about the value that these ancient ecosystems have for the communities that depend on them.
“Crown Jewels” documents a year-long journey through some of the last ancient forests on US public lands, highlighting their crucial role in protecting our land, air, and water. Beyond their environmental benefits, these forests hold deep cultural and community significance as seen across West Virginia, Wisconsin, and Oregon. Threatened by imminent logging plans by the Forest Service, these ecosystems face permanent destruction unless widespread support for their protection is mobilized. The film advocates for viewers to leverage their freedom of speech to transform federal land management together, urging those who watch to join the effort through local activism and storytelling.
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STOP CUTTING!
"Immediately stop cutting old-growth in the Daniel Boone National Forest."
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Old-Growth Management
"Any management in old-growth forests, including prescribed fire and understory management, should be the minimum necessary to support existing and future old-growth structure and function as appropriate for the community type."
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Eliminate Exceptions
"Eliminate exceptions in the plan that allow forest managers discretion to convert old-growth to young forests, or to otherwise degrade or diminish forests’ old-growth condition."
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Importance of Old-Growth
"Recognize the importance of old-growth across all forest types, including disturbance-mediated forest communities like upland and
fire-adapted oak forests and woodlands." -
Identification and Inventory
"Ensure that the inventory and identification of old-growth is scientifically sound. Make the process of identifying old-growth forests transparent, consistent, and open to public input. Involve researchers, ecologists, and other outside experts in the identification and inventory process."
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Steward Mature Growth
"Require that mature forests be managed for future old-growth in a manner that ensures a variety of patch sizes, wide distribution, and good connectivity across the Daniel Boone National Forest, improving on the deficiencies in the current Forest Plan."
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Old-Growth Network
"Develop a plan for a network of future old-growth forests through an open, participatory, and scientifically sound process."
The Deep Dive:
America’s mature and old-growth forests could be one of our greatest natural climate solutions — if we let them grow. Forests are among the most effective ways to remove and store carbon from our atmosphere, and U.S. forests sequester 13% of our carbon emissions every year.
Mature and old-growth forests are carbon storage powerhouses. And with their thicker protective bark and higher canopies, mature and old-growth trees are more resilient to wildfire. They also provide critical wildlife habitat, filter clean drinking water for communities, provide countless outdoor recreation opportunities, and capture the imaginations of Americans young and old.
On Earth Day 2022, President Biden issued Executive Order 14072, “Strengthening the Nation’s Forests, Communities, and Local Economies,” which directed federal agencies to inventory America’s mature and old-growth forests on federal lands and develop policies to conserve them as a cornerstone of U.S. climate policy. The order recognized the outsize role mature and old-growth forests play in carbon sequestration and storage and related benefits, including clean water, recreation, and sustaining plant and animal life fundamental to combating the climate and biodiversity crises.
In response, the U.S. Forest Service proposed the National Old Growth Amendment (NOGA) in December of 2023. The NOGA is a proposal to amend nearly all 128 forest land management plans to provide consistent direction to conserve old-growth forest conditions and recruit future old-growth to address the severe deficit of old-growth.
The NOGA draft environmental impact statement sets important and necessary goals for protecting the Nation’s climate-critical forests. As proposed, however, it would still allow logging of old-growth, and it does nothing to protect mature forests and trees – the old-growth of the future – from logging.
To successfully achieve protection for old-growth forests, the final NOGA must:
- Eliminate exceptions and end all logging of old-growth trees (except in rare cases for public safety and indigenous cultural uses), including in the Tongass National Forest.
- End logging in moist and infrequent fire old-growth stands. Younger trees in old-growth stands that burn on longer fire cycles do not need to be removed for ecosystem restoration or wildfire mitigation.
- Protect old-growth trees in cases when logging may be necessary in frequent fire forests. Young trees in fire suppressed old-growth stands may need to be removed, but old-growth trees should be left standing.
- Prohibit sending old-growth trees to the timber mills. The economic incentive for logging old-growth must be removed. If the logged tree cannot be sold or exchanged, it will likely
prevent all but truly rare removals of old-growth trees. - Set the stage for durable protections for mature trees and stands. This is paramount to the future of old-growth. If we do not also protect mature trees, we will fail to recover old-growth forests across the country. Mature trees will grow into old trees over the next several decades and as many of them as possible must remain standing.
- Be consistent with the need to address wildfire. Protecting older trees and forests can increase forest resilience to wildfires, and combat climate-change related impacts such as flooding and drought. Protecting our oldest trees supports the Department of Agriculture’s Wildfire Crisis Strategy.
Federal forest management continues to prioritize timber production and routinely side steps science to turn big, old trees into lumber and wood chips. Logging releases a significant amount of stored carbon, eliminates older trees’ ability to sequester additional carbon, and damages the other ecosystem services and biodiversity values these forests uniquely provide. Many older stands and trees have no enduring protection, and hundreds of thousands of acres are at risk of being logged.
Durable protections for our older forests and trees are supported by conservation groups,
leading climate and natural resource scientists, and Members of Congress. Both the National Congress of American Indians and the Affiliated Tribes of Northwest Indians have adopted resolutions calling for durable regulatory protections from logging mature and old-growth stands and trees on federal forests. Protecting mature forests from ecologically damaging logging will not impede ecologically appropriate wildfire mitigation work.
These trees are worth more standing.
- Alternative 1 is the required “no action” alternative.
- Alternative 2 is the agency’s preferred alternative. It is grounded in a theory of “proactive stewardship” of old-growth forests for “climate adaptation.” In the name of such “stewardship,” the agency retains wide discretion to log old-growth trees and send them to the mill.
- Alternative 3 restricts “timber resources and timber resource management” (commercial logging) in old growth forests, but still allows the felling of old-growth trees.
- Alternative 4 permits timber production and commercial logging in old growth forests without requiring ecological or restoration purposes .
- Alternatives 2, 3, and 4 all contain language with similar approaches for what the Forest Service is calling “Adaptive Strategies.” These strategies are the only areas that include any reference to mature forests. There are no standards protecting mature forests.
- All alternatives presume that old growth forests need to be actively stewarded in some fashion for them to persist. Active stewardship, including logging, is the presumed solution to address all threats.
- Durability: Nothing appears to stop the agency from pursuing management activities that take the forests out of old growth status, at which point any protections offered by the NOGA would no longer apply. All alternatives explicitly allow line officers the discretion to manage old growth out of existence in pursuit of “proactive stewardship” goals . The alternatives also contain ambiguous language that could be used to justify continued commercial logging of old growth in the Tongass National Forest. And line officers appear to have the discretion to modify NOGA protections in individual forest plans through the forest plan amendment or revision process.
- Mature: It is extremely disappointing that the agency has ignored public calls to adopt standards for protecting mature trees and forests. The adaptive strategy directs National Forests to look for forests for OG recruitment, but it’s all left to local discretion. Part of the “purpose and need” of this policy is ecological integrity. Without specific mature forest protections, the agency will fail to recover the abundance and distribution of old-growth forests and will undermine its ecological integrity objectives.
- Definitions: They’re using individual forest plan definitions or regional ones (where plans don’t have a definition). First, these definitions are generally narrowly witten as to exclude much forest and trees that are, in fact, old growth. Second, line officers a lot of wiggle room on how to apply the NOGA. Part of the “purpose and need” of this policy is a consistent approach to old-growth conservation. The extreme discretion and flexibility given to local managers undermines these objectives.
- De minimis: While the Tongass is no longer singled out for exemption, the “de minimis” logging of old growth language in the DEIS expands what was worrisome about the Tongass exemption to the entire National Forest System. It opens the door to a lot of old-growth trees going to the mill. There is no clarity or limiting language on what constitutes “de minimis.” Logging “de minimis” old growth can be for “local community purposes” or for “research.” (Standard 2c v)
- Old growth can still go to the mill: As written, Standard 3 in Alt 2 would still allow for a lot of old-growth trees to go to the mill. For instance, where line officers determine that the rules about proactive stewardship aren’t “relevant or beneficial” to a species or forest type under 2.c.vi, old growth trees can be logged and sent to the mill.
- Carbon and climate mitigation is largely missing from the draft proposals.
RESOURCES & NEWS MEDIA
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“Crown Jewels” documents a year-long journey through some of the last ancient forests on US public lands, highlighting their crucial role in protecting our land, air, and water.
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Protecting mature and old growth trees and forests will help the U.S. mitigate and adapt to climate change.
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National coalition of environmental activists working together to create lasting protections for our mature and old-growth forests!
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Visit the official project page of the National Old Growth Amendment and take the deep dive on the forest service technical documents. (If that's your thing.)
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Technical Guidance for Standardized Silvicultural Prescriptions for Managing Old-Growth
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Silviculture Practices, Released 8/16/24
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A photographer captures life in America's last remaining Old-Growth Forests.
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The continued logging of mature and old-growth trees and forests on Forest Service and BLM lands undermines President Biden's international leadership on forest conservation and climate change.
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U.S. Forest Service unveils plan to conserve remaining old-growth forests.
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Bruce Westerman slams Old-Growth Amendment as Misguided and Ineffective.
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Proposed National Forests Old-Growth Amendment.
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Here's How the New Old-Growth Amendment Could Put Forests at Risk.
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