Protect Old Growth Forests Before September 20

Old growth and mature forests are the backdrop for some of the most majestic outdoor experiences in America. These forests are also powerhouses for fighting climate change and providing clean air and clean water.

Once common across forested areas of North America, old growth forests are relatively rare due to more than a century of impacts from logging, development, fire exclusion, insect outbreaks, and more. The U.S. Forest Service oversees 193 million acres of national forest land.

In 2022, as part of its efforts to address climate change, the Biden administration committed that the U.S. would do more to protect and expand mature and old growth forests. Since then, the Forest Service has been laying the groundwork for a national policy to protect old growth forests. This includes completing the first-ever national definition and inventory of old growth and mature forests, which estimates that around 33 million acres of old growth forests exist across National Forests and BLM lands. More recently, the agency took a robust look at the threats facing old growth forests, and found that wildfire, insect outbreaks, and other diseases affecting trees pose a significant threat to these forests, and that climate change will exacerbate these threats over the next century.

Last winter, the Forest Service released a draft of its National Old-Growth Amendment (NOGA) to enhance conservation of mature and old growth trees across all of our national forests, and more recently released an updated version of NOGA along with a draft environmental impact statement. If finalized, NOGA would add new old growth forest protections to 122 forest plans across the country.

Outdoor Alliance supports the amendment. This approach allows for individual national forests to make decisions locally that meet the specific needs of their forests. The proposed amendment is a step in the right direction, but it needs to be significantly strengthened in order to meet its intended purpose of protecting mature and old growth forests, which are profoundly important to the outdoor recreation community. Outdoor Alliance’s high-level concerns follow two overarching themes:

First, the amendment should provide more clarity about “proactive stewardship.” Proactive stewardship is a catch-all term used to describe restoration actions like fuel treatments or wildlife habitat projects that enhance the quality or resilience of old growth forests. In some forests, particularly dry fire-adapted forests in places like California’s Sierra Nevada, proactive stewardship actions like prescribed fire can be essential for ensuring the long-term resilience of old growth forests. In other places, such as the wetter forests of the western Cascades, these same actions may not be clearly ecologically justified. NOGA should make clear that in some cases, a passive, hands-off management approach is needed for old growth conservation, and should ensure that that proactive stewardship projects (which can involve cutting trees) do not degrade old growth forest characteristics.

Second, as written, the amendment contains a long list of exceptions to its core requirements around old growth conservation. These exceptions are too broad to protect old growth forests over time. While some of these are warranted, such as an exception for protecting public safety, others could result in vast areas of the National Forest System being exempt from the national old growth policy entirely. The amendment also allows for cutting old growth trees in instances where it would be incidental to implementing other activities, including recreation infrastructure projects like trails—an exception that could be refined to allow recreation projects to move forward without compromising the ecological integrity of old growth forests.

You can read Outdoor Alliance’s joint letter with Outdoor Industry Association and The Conservation Alliance here or by clicking at right.

The Forest Service wants to hear from you before September 20. Join us by adding your voice to ask the Forest Service for stronger protections for mature and old growth forests. Your input is vital to ensuring that our old-growth forests continue to provide their many benefits for generations to come.

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