Over a Million Public Comments Call for Old-Growth Forest Protections

The public comment period for the US Forest Service's proposed National Old Growth Amendment closed last Friday, September 20^th. Hundreds of thousands of people wrote in to critique the agency's proposal, which falls short of it's intended purpose to protect public old-growth forests for their climate and ecosystem values.

Our story begins in April of 2022 with Executive Order 14072: Strengthening the Nation's Forests, Communities, and Local Economies. This Order directs the Forest Service and the Bureau of Land Management to inventory our National Forest System and assess threats to forest health and resilience. It further directs agencies to, "Restor[e] and Conserv[e] the Nation's Forests, Including Mature and Old-Growth Forests." They then published a "request for information" to help inform the implementation of the order.

Over 144,000 public comments emphasized the need for strong protections for mature and old-growth forests and trees.

A year later, in April of 2023, the Forest Service released an "advanced notice of proposed rulemaking." This signaled the start of an administrative process to develop policy to satisfy the goals outlined in Executive Order 14072. Two main questions the notice sought to answer were, 1. How might the Forest Service use the mature and old-growth forest inventory together with analyzing threats to prioritize when, where, and how different types of management will best enable retention and expansion of mature and old-growth forests over time? And 2. Given our current understanding of the threats to the amount and distribution of mature and old-growth forest conditions, what policy, management, or practices would enhance ecosystem resilience and distribution of these conditions under a changing climate?

More than 530,000 public comments were submitted, answering those questions and calling for robust protections for mature and old-growth forests.

In December of 2023 the Forest Service released a "notice of intent" to amend nearly every forest land management plan across the nation with language to standardize management protections for old-growth forest conditions. This was the start of the National Old Growth Amendment as we know it. Mature forest protections - necessary to ensuring future old-growth forest development as mature trees age - were noticeably absent. Logging of old-growth forests and trees was also explicitly allowed, so long as economic gain was not the primary reason for work.

Over 122,000 public comments criticized these provisions and oversights, which undermine the protection and expansion of old-growth trees and forests.

The next step in this sort of agency process is the "draft environmental impact statement" whereby the Forest Service lays out several policy alternatives to achieve the purpose and need of the proposed amendment. In June of 2024, the agency released their draft, including a stated preferred alternative (or policy approach) that allows the Forest Service near-full discretion to log old-growth trees and forests to advance so-called "proactive stewardship".

Their primary rationale for needing unfettered discretion to log old-growth forests and trees is that climate change impacts on forests will necessitate extensive management. And while climate change impacts are real, old-growth forests are uniquely well suited to withstand many of the projected disturbances -- often better than younger forests.

Old-growth trees can confer fire resilience to a forest stand, thanks to their high moisture content, thick bark, and lack of ladder fuels that lead to crown fires. Older trees also help buffer forests from extreme heat and drought, with deep roots that enhance water storage and access, and cooler microclimates under the shade of their leaves. These forests provide clean drinking water to millions of Americans and remain a rarity on the landscape after centuries of aggressive timber logging. As climate change worsens, old-growth forests will become increasingly important refugia for climate stressed species. To say nothing of their role as carbon storage powerhouses.

Frustratingly, the Forest Service knows all this. Their own analysis points to the critical value of old-growth forests while in the same breath sanctioning their logging. These are highly intact systems - they became old growth by being left alone - with little need for restoration management.

We therefore recommended that the Forest Service modify their conservation focused alternative so that it ends the commercial exchange of old-growth trees; bars logging of old-growth trees, subject to very limited exceptions; and applies the same protections to infrequent-fire old-growth stands. Such guardrails would ensure that in places where management could be beneficial - such as in dry, fire prone stands with existing access roads - the largest, oldest trees are retained for these climate and ecosystem values. There is no ecological or scientific justification for sending our few remaining old-growth trees to the mill.

This past Friday, more than 295,000public comments demanded that the draft amendment be revised to meaningfully protect old-growth trees and forests from commercial logging, better satisfying the directives of EO 14072.

In addition to the outpouring of more than a million public comments throughout this process, we have seen scientists, faith leaders, elected officials, activists, and businesses take a stand to improve the Forest Service's lackluster policy. As written, the amendment offers little protections to old-growth and codifies loopholes for irreparable commercial logging.

The public has spoken. And most agree - in the age of climate change, with our most critical decades for action upon us, we simply do not have the time to regrow our ancient forests. We need old growth to sequester massive amounts of carbon, shelter imperiled species, and protect the sources of our drinking water. These are our public forests. Their benefits should be preserved for the American people to enjoy for generations to come.

Now it is up to the US Forest Service to listen.

A final environmental impact statement with a selected alternative (policy approach) is expected to be announced in January of 2025.

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