Thousands comment on USFS amendment for old-growth forests

Laura Lundquist

(Missoula Current) The U.S. Forest Service is trying to amend almost all its forest plans to provide some protection for old-growth forests, but based on thousands of public comments, the agency doesn’t have an easy task.

A comment period closed Friday on a draft environmental study of a Forest Service amendment to protect old-growth stands on 122 national forests across the nation. The proposal received significant public interest with almost 9,800 comments submitted during the 90-day comment period, with many submitted on the last day.

The responses ran the gamut from some commenters asking for no logging of old growth stands to those insisting that logging is necessary to stop wildfires and disease.

Among the former group of commenters was the Climate Forests Campaign, a coalition of the Center for Biological Diversity, Environment America Research & Policy Center, Environmental Law & Policy Center, Earthjustice, Natural Resources Defense Council, Oregon Wild, Sierra Club, Standing Trees, WildEarth Guardians and the Yaak Valley Forest Council.

“As the Forest Service reads the comments it has received over the last 90 days, it will find a common theme. The old-growth policy proposed in June fails to meet the central mission of the executive order — it does not protect old-growth trees from logging and allows projects that would log old-growth forests out of existence through numerous loopholes. The policy also does nothing to protect mature forests, which are needed to increase the abundance and distribution of old-growth trees and forests,” the Climate Forests Campaign wrote.

Conversely, the Lincoln Board of County Commissioners asked the Forest Service to exempt the Kootenai National Forest from having to amend its 2012 Forest Management Plan, arguing the Kootenai plan already addresses old-growth.

The Kootenai National Forest has proposed five adjacent large forest projects totaling more than 300,000 acres in northwest Montana, including the Black Ram project, which was slated to log 580 acres of old-growth. The project was thrown out in federal district court, but the Forest Service has appealed.

“We see no need to change the plan when it already meets the intent of the proposed amendment. This is true not just of the Kootenai NF but of many of the Category 2 Forests, several of which are in Montana or Northern Idaho and thus support forest products infrastructure in our region,” the Lincoln County commissioners wrote.

The Montana Department of Natural Resources and Conservation argued in favor of the “No action” alternative, which would leave all national forest management plans unamended. DNRC Director Amanda Caster expressed concern that it would reduce the effectiveness of the Forest Service's Wildfire Crisis Strategy and would negatively affect the timber industry. She called the process “rushed and lacking in substantive information.”

In April 2022, President Joe Biden issued an executive order to conserve and restore old-growth forests, the ecosystems they support and the climate change benefits they provide. Also, the 2022 Inflation Reduction Act allocated $50,000,000 for old-growth protection.

Confusion was created because the 2021 Bipartisan Infrastructure Law had set aside $131 million for a Wildfire Crisis Strategy, which selected areas in the West where the Forest Service was to prioritize forest logging projects to reduce wildfire risk. The Kootenai complex in northwest Montana was one of the initial areas identified as a high-risk fireshed in 2022, so it received funding “to increase the pace and scale of vegetation treatments across the landscape.”

But some of those fast-tracked treatments included old-growth stands. The Forest Service needed to develop a consistent framework for conserving, stewarding, recruiting and monitoring old-growth forests. Scoping began in April 2023 as part of the Forest Service’s Climate Resilience rule-making, and the first public comment period garnered 92,000 comments.

The Forest Service conducted an inventory of all national forests - published in June - that found 47% of forests can be classified as mature while 18% meets the requirements for old growth. But nearly half of that old growth - about 11 million acres - is outside protected monuments, wilderness or roadless areas.

The inventory also found that “old-growth” is defined differently depending on the vegetation and history of each national forest, so the inventory was based on regional and local definitions. In addition, old-growth forests in different areas face different threats.

The Forest Service also decided that “old-growth” should depend on the quality and ecological function of an area as well as the age of the trees. The agency decided there should be no single definition and areas would not be designated as “old growth.”

In the resulting draft environmental impact study, the agency’s preferred alternative would use an adaptive strategy to manage old-growth, which allows some logging of old-growth if it would “promote the composition, structure, pattern, or ecological processes necessary for old-growth forests to be resilient and adaptable to stressors and likely future environments.” The study doesn’t elaborate on how each national forest supervisor would determine such logging is necessary.

Language was also added in the preferred alternative to encourage fuel projects to reduce the risk to old-growth forests and the Wildland Urban Interface, according to the study. Also, the Forest Service would not manage mature forests to recruit into old growth, but it could prioritize some areas of mature forest for that purpose.

“The proposed amendment recognizes the importance of proactive stewardship in order to protect old-growth forests from threats, including to reduce wildfire risk and allow for the restoration of beneficial fire in fire-adapted ecosystems, consistent with the Forest Service’s Wildfire Crisis Strategy,” according to the impact study.

The Forest Service included two other alternatives. One would prohibit all commercial logging in old-growth while the other would allow commercial harvest beyond that considered necessary for forest resilience.

The study said the old-growth amendment wouldn’t affect the timber industry because it doesn’t take federal lands out of production and most timber is currently harvested from state or private lands. In addition, few mills remain that can process the large logs of old-growth areas. The report said “no effects are expected on traditional timber industry jobs in logging, wood product manufacturing or pulp production.”

Environmental groups oppose more logging, arguing once old-growth forests are logged, they permanently lose much of their ability to provide habitat and sequester carbon from the air to fight climate change. While it is possible for trees to be replanted and regrown, reestablishing the full suite of species present in the original old-growth stands would take hundreds of years, if successful at all.

According to the Forest Service website, a decision on the final amendment is expected in January.

Contact reporter Laura Lundquist at lundquist@missoulacurrent.com.