Why It Matters: Attempting to amend 121 National Forest land management plans to provide consistent direction for the management of old-growth forests, as Alternative 2, the Preferred Alternative proposed, is a misplaced policy priority and distraction from the need to address declining fish and wildlife habitat and forest health across the National Forest System. At a time when the U.S. Forest Service is facing significant budget challenges and is unable to treat the tens of millions of acres in need of management to reduce catastrophic wildfire risk, moving forward with any of the alternatives besides the no action alternative will further divert limited agency resources away from restoring the health of forests and watersheds.
Highlights:
- The U.S. Forest Service’s Mature and Old-Growth Forests: Analysis of Threats on Lands Managed by the Forest Service and Bureau of Land Management (Threat Assessment), which was required by Executive Order 14072, identified wildfire, insects, and disease as the leading threats to old-growth forests, not timber management.
- The Mature and Old-Growth Forests: Definition, Identification, and Initial Inventory on Lands Managed by the Forest Service and Bureau of Land Management, identified 68.1 million acres of mature forests and 24.7 million acres of old-growth forests. Combined with the more than half of the National Forest System that is already in no or limited management areas, the National Forest System will continue to trend towards a predominantly older age class distribution, without amending forest plans as proposed in the Draft Environmental Impact Statement.
- The Threat Assessment reported a 10% decline in mature forest in reserved areas (Wilderness Areas, Inventoried Roadless Areas, and National Monuments) whereas outside of the reserved areas, i.e., where timber management takes place, old-growth forests increased by 7.8%, demonstrating that a hands-off management approach is not always the answer.
On September 20, the Congressional Sportsmen’s Foundation (CSF) submitted comments on the U.S. Forest Service’s Draft Environmental Impact Statement for Amendments to Land Management Plans to Address Old-Growth Forests Across the National Forest System. CSF previously submitted comments in August 2022 with others in the sporting-conservation community in response to the U.S. Forest Service’s and Bureau of Land Management’s efforts to define and inventory old growth and mature forests following President Biden’s issuance of Executive Order 14072, “Strengthening the Nation’s Forests, Communities, and Local Economies.”
CSF recommended that the U.S. Forest Service adopt Alternative 1, the no action alternative. CSF expressed concerns about further straining the U.S. Forest Service’s limited staff and funding resources, the prioritization of managing for old-growth forests over other habitat needs, specifically the need to manage for a diversity of forests age classes to support diverse and robust wildlife populations, and the U.S. Forest Service’s continued failure to meet early successional habitat goals laid out in forest plans. CSF also expressed concerns about inviting litigation on approved habitat improvement projects waiting to be implemented, inconsistency with the 2012 Planning Rule local collaborative input intent, and undermining stakeholder trust and investment in recently revised forest plans.
Instead of undertaking the enormous task to amend 121 land management plans in a short time frame, CSF encouraged the U.S. Forest Service to invest in wildfire prevention efforts and prioritize restoration work to increase forest resiliency.
CSF is a strong proponent of using active forest management tools to improve wildlife habitat and access for sportsmen and women and will continue to advocate for policies that support management flexibility on federal public lands.
