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Comment now for National Old-growth Rule

Former FOC staff member Ashley Martens in front of a remarkable old-growth cedar in the Fish-Hungry Creek roadless area. Brett Haverstick photo.

Comment to Protect Ancient Forests – Due July 20th!

The Biden administration has opened a comment period on “forest service functions” that offers the public a chance to voice support for a rule protecting mature and old-growth forests (MOG) on public lands. It ends July 20th. This rule has yet to be written, so public input now could shape the rule.

Here is the question posed on the regulations.gov website:

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?

FOC has been skeptical about the effectiveness of Biden’s executive orders on public forests and this potential rule-making, and this kind of vague language doesn’t help. Additionally, the USDA data used on the regulations.gov website misinform potential commenters on the greatest threat to MOG forests. That threat, more than fires, insects, or disease, is logging.

Logging, harvest, active management, thinning, restoration, regeneration, enhancement, call it what you want, but that’s why old-growth forests, and the species that depend on them, are so rare. Older forests have, on average, bigger trees with better wood for dimensional lumber, and continue to be targeted by the USFS for logging.

Old-growth forests are not a renewable resource. As indicated in the Friends of the Clearwater 2020 paper on old-growth management in the Northern Rockies, it takes a minimum of 150 years for old-growth stands to develop, and their benefit to wildlife is deeply tied to their acreage – an old-growth landscape must be protected, not just a few old trees. In the Clearwater Basin, between 30% to 50% of forests were old-growth prior to 1900, now it is likely under 10% on public lands and even worse on private lands.

So how should you comment?

1. Demand a rule to protect all old-growth forests on public land. Here are some details that we recommend:

  • Chainsaw-free. Demand no logging, thinning, or burning, of any kind, in mature and old-growth forests, including dubious ploys for “restoration”. Logging, at any intensity, does not reduce the likelihood of wildfire.
  • Livestock-free. Protecting delicate forest soils (where 50% of forest carbon is stored) can’t be overlooked. Livestock decrease carbon stored in soils. Allotments should be reduced and costs of grazing increased.
  • Connected. Emphasize that landscapes of mature forests, not just isolated stands, should be protected.
  • Fire-inclusive. Acknowledge the role that wildfire has in forests. While very large fires can shift a forest into a younger, re-growth cycle, most older forests are cooler, wetter, less windy, and therefore more resilient to wildfire. Logging, not fire, destroys most old-growth.
  • Enforced. Many forests (like the Nez Perce-Clearwater) already have requirements for old-growth habitat and inventories that are simply not being followed. How will the executive branch ensure this rule will be different?

    2. Encourage scientifically-supported climate-smart management. That would include:

    • Prioritize carbon sequestration. Multiple-use, as a policy, has focused on logging above all other uses for half a century. Forests can act as large-scale carbon reserves if protected from extraction, and that “use” must be the priority of climate-smart management.
    • End commercial logging on public lands. Logging is the largest source of carbon emissions on forests, far beyond fire.Older, unlogged forests hold way more carbon than logged forests.
    • Preserve Roadless integrity. A total end to developing roadless forests. Current loopholes in the National, Idaho, and Colorado Roadless Rules allow for logging and roadbuilding in inventoried roadless areas, which disproportionately support older, carbon-dense forests.
    • Keep biomass production off national forests. Biomass production is not carbon-neutral, it is extremely carbon intensive, even more so than traditional fossil fuels. Recent calls for this “green energy” are misplaced.

    The comment period has been extended until July 20th, 2023. Comment on regulations.gov here.