National Old-Growth Amendment

On December 19, 2023, the U.S. Department of Agriculture announced a Notice of Intent to amend all 128 national forest land management plans to conserve and steward old-growth forest conditions and recruit future old-growth conditions in light of increasing threats due to rapidly changing climate conditions.

The proposed amendment is based on information from national forests and current old-growth conditions and was informed by substantial public input. The threat analysis report of mature and old-growth forests on National Forest System and Bureau of Land Management lands suggests that current management activities may not be responsive to rapidly changing disturbances and conditions that threaten old-growth forests including wildfire, fire exclusion, insects and disease, extreme weather, climate, temperature and more.

These actions are consistent with Executive Order 14072 Strengthening the Nation's Forests, Communities, and Local Economies issued by President Biden on April 22, 2022, that required the agency to define, inventory and analyze threats to mature and old-growth forests on federal land. The executive order also directed the agency to provide policy recommendations related to the land management and changing climates.

The proposed national old-growth amendment is part of an overarching climate-informed strategy to increase forest resiliency to wildfires, combat climate-related impacts and help retain carbon. This and subsequent work on old-growth and mature forests supports the Wildfire Crisis Strategy.

The proposed amendment focuses on wildfire resilience, climate change adaptation, tribal inclusion, sustainable communities, and overall old-growth forest health. If the proposed amendment is approved, the agency will use the best available science, including Indigenous Knowledge, to provide consistent direction related to old-growth forest conditions across national forests and grasslands.

The amendment was informed by public input on several Forest Service climate change policy initiatives underway since 2021.

Following an intensive public scoping period, which closed Feb. 2, 2024, the Forest Service received and evaluated 7,300 public comments. Since then, the agency also gathered extensive input from a diverse range of audiences including tribes, states, local governments, stakeholder groups and other federal agencies.

Collectively, this information helped guide the draft Environmental Impact Statement analysis process and was incorporated into the proposed action and used to develop alternatives.

Key themes from public comments included:

• Concern over top-down approach doesn’t meet 2012 Planning Rule requirements for public engagement of local input.

• A single amendment for all plans would make more sense at a national level rather than impacting local work.

• A consistent approach is needed to address natural disturbance threats due to climate change.

• Proposed action alternatives may reduce active management and will limit the ability to manage multiple use and forest health.

• Include direction and protection for mature and old-growth forests.

The following is a snapshot of how some of the diverse and contrasting inputs were applied within the draft Environmental Impact Statement:

• Clarified or removed wording that caused confusion or misconceptions.

• Developed a detailed ‘crosswalk’ table that outlines intent and provides clarification and what has changed from what was outlined in the formal notice of intent to the proposed plan components and content.

• Specified place-based old growth definitions and associated criteria for use when identifying old-growth forests at the local, unit level.

• Added or changed standards and guidelines to clarify constraints on management actions and where there can be deviations from these, especially as it relates to achieving wildfire risk management and hazardous fuel reduction objectives.

• Clarified consideration for the recruitment of future old growth.

• Added an extensive glossary and list of acronyms to increase shared understanding of terminology.

• Explained agency compliance with applicable laws, regulations and directives.

Given the proposed amendment outlines a local forest-level approach with national-level consistency, grassroots will remain integral to this process.

Q: Why was the National Old Growth Amendment proposed? What actions led us here?
A: The proposed National Old Growth Amendment is part of an overarching climate-informed strategy to change the course of increased wildfires, combat climate-related impacts and help retain carbon. This effort responds to Executive Order 14072, Strengthening the Nation’s Forests, Communities, and Local Economies, issued by the Biden Administration on April 22, 2022, USDA Secretary Vilsack’s subsequent memo, and section 23001(a)(4) of the Inflation Reduction Act concerning the protection of old-growth forests. In addition, this work on old-growth and mature forests supports the Wildfire Crisis Strategy.

The executive order guided the agency toward a process to define, inventory and analyze threats to mature and old-growth forest conditions on federal lands and informed the proposed action for the amendment. An initial threat analysis of mature and old growth forests on National Forest System and Bureau of Land Management lands suggests that current management activities may not be responsive to rapidly changing disturbances and conditions. Mortality from wildfires is currently the leading threat to mature and old-growth forest conditions, followed by insects and disease, with tree cutting a relatively minor threat compared to climate-amplified disturbances. Past management practices, including timber harvest and fire suppression, have also contributed to current vulnerabilities in the distribution, abundance, and resilience of old-growth forest characteristics. The amount and distribution of mature forests across the National Forest System suggest that these lands have the inherent capability to sustain old-growth forest conditions into the future.

This proposed action was also informed by public feedback received on the Climate Resilience Advance Notice of Proposed Rulemaking the Forest Service initiated in April 2023 which gave the public an opportunity to provide input on how the Forest Service should respond to the changing climate through forest management activities and possibly future policies.   

Q: What is addressed in the draft environmental impact statement?
A: The draft environmental impact statement will explain the purpose of and need for action, describe the proposed action (and any modifications as informed by scoping and evolving internal understanding of the potential impacts of the amendment), any action alternatives, and explain any environmental and socioeconomic consequences. It will also include information that explains what laws and regulations apply and provide rationale that demonstrates compliance with these laws/regulations, to include but not limited to the:

• National Environmental Policy Act;

• National Forest Management Act and the associated 2012 planning rule;

• Endangered Species Act;

• National Historic Preservation Act; and

• Clean Water Act.

Through this process, the national old growth team consulted with regional, and forest/grassland subject matter experts as needed to gather place-based knowledge and local management.

Q: How did the mature and old-growth definition, inventory and threat analysis inform the old-growth proposed amendment and draft Environmental Impact Statement?
A: The initial inventory identifies the amount of mature and old-growth forests nationwide, and by region, which sets the context for local evaluation under the draft Environmental Impact Statement. The threat analysis outlines regional differences in primary threats to mature and old-growth forest conditions that informed evaluation of alternatives in the draft environmental impact statement.

Q: How would the proposed amendment impact timber harvest?
A: Timber harvest is one of the tools used to meet a wide variety of land management objectives, including fuels reduction, carbon sequestration, wildlife habitat enhancement, and scenery management. Today’s harvest methods and technologies consider the mutual benefits of timber harvest, ecological resilience and integrity, and economic and social value to communities.

The amendment would allow vegetation management (to include ecologically appropriate harvest) in old growth forests for the purpose of proactive stewardship to promote the composition, structure, pattern, or ecological processes necessary for the old-growth forest conditions to be resilient and adaptable to stressors and likely future environments, but would prohibit vegetation management within old-growth forest conditions when the purpose is to grow, tend, harvest, or regenerate trees for economic reasons. Exceptions are provided for hazardous fuel reduction in the wildland urban interface, to protect public health and safety, to comply with other statutes and regulations, to support culturally significant practices, and in cases where it is determined that the direction in this amendment is not relevant or beneficial to a particular forest ecosystem type.

As an agency we know that vibrant wood products economies are vital to forest and community health. We continue to invest in industry innovation through the Collaborative Forest Landscape Restoration Program, the Wood Innovation Grant program, the Community Wood Grant Funding Opportunity Program and Wood Products Infrastructure Assistance.

Q: Will the proposed amendment change local old-growth forest definitions?
A: Old-growth forests are defined by forest land management plans or by the region. If old growth is not defined in a forest land management plan or if definitions are incomplete or only address some but not all species/forest ecosystems found in the planning area, regional definitions are used.

Q: How can old growth definitions be applied given the diversity off forests locally, regionally?
A: Old growth definitions vary based on local forest types and conditions. As such, the draft environmental impact statement for the proposed national old growth amendment does not impose old growth definitions and will defer to local definitions. If local definitions do not exist or are incomplete regional definitions will be used.

Q: Does the draft environmental impact statement address the management of mature forests?
A: The proposed old growth amendment doesn’t restrict management on mature forests but seeks to expand a forest’s overall old growth footprint. Through active management and flexibility at the local level, land managers have the opportunity to promote forest conditions that recruit mature into old growth.

The proposed amendment is primarily about old-growth forest conditions; however, an associated management approach and guideline are being proposed to encourage proactive stewardship actions to increase amounts and improve distributions and climate resilience of future old growth conditions. The management approach and guideline apply to forested areas that do not currently meet old growth definitional conditions but that may contribute to the development of those conditions over time. There is not an existing specified amount for mature forests managed toward old growth conditions.

Q: Does the proposed amendment impact the ability for local forests to reduce hazardous fuels?
A: Safety remains the Agency’s top priority. The proposed amendment will not impact federal, state or local response to wildfires and will not pull resources away from the agency’s Wildfire Crisis Strategy implementation. The proposed amendment complements our work with the wildfire crisis strategy and work to reduce fuel hazards within the wildland urban interface to protect communities and infrastructure from wildfire.

Q: How are impacts to local economies evaluated for each land management plan and considered in the draft environmental impact statement process?
A: Old-growth forests stimulate local economies through recreation, tourism, special forest products and selective timber harvest. Economic impacts to local economies were thoroughly considered throughout the development of the draft environmental impact statement. The agency will continue to evaluate the socio-economic impact of the proposed amendment moving forward throughout the remainder of the process.

Q: How was feedback from the Notice of Intent scoping period and recent engagements used to inform changes to the proposed action, develop action alternatives and guide analysis in the draft environmental impact statement?
A: Many changes were made to the proposed action - in response to a broad range of feedback from diverse audiences. These changes are reflected in the draft environmental impact statement, some examples of these changes are:

• Clarified or removed wording that caused confusion or misconceptions.

• Developed a detailed ‘crosswalk’ table that outlines intent and provides clarification on the changes made from the notice of intent to the proposed plan components and content.

• Specified place-based old growth definitions and associated criteria for use when identifying old-growth forests at the local level.

• Modified standards and guidelines to clarify constraints on management actions and where there can be deviations from the constraints, especially as it relates to achieving wildfire risk management and hazardous fuel reduction objectives.

• Clarified consideration for the recruitment of future old growth.

• Added an extensive glossary and list of acronyms to increase shared understanding of terminology.

• Explained agency compliance with applicable laws, regulations and directives.

Q: How does the proposed amendment impact existing land management plans and those currently in revision?
A: Current land management plans remain the local guidance for ongoing management of all national forests and grasslands until a formal Record of Decision is signed. If the amendment is approved, it would amend all 128 land management plans, including those in the revision process. As stated in the Notice of Intent, this proposal is not intended to replace existing direction in plans but rather to add language that provides consistency across all plans. If existing plan direction provides more restrictive constraints on actions that may affect existing or potential old-growth forest conditions, those more restrictive constraints would govern. The amendment also outlines an adaptive management approach for the development of local strategies given old growth forests are unique based on their geographical location, cultural and socioeconomic value.

Q: If the proposed amendment is approved what happens to existing land management plans that currently allow for regeneration of old growth for economic purposes?
A: Through the analysis process for the draft environmental impact statement, several alternatives have been proposed reflecting more and less restrictive language. Alternatives will be considered and refined following the consideration of input from a 90-day public comment period.

Q: How might this amendment impact activities authorized by special use permits not directly tied to timber such as rights-of-way for utility corridors, ski management areas, as well as mining activities?
A: There are currently 127 ski area developments on National Forest System lands. Ski resorts often conduct maintenance and development actions that remove vegetation, such as clearing vegetation for new chair lifts, ski runs, parking lots, and other facilities.

The proposed amendment would not apply to permits in areas of operations outside of old-growth forests conditions or to operations that do not include tree-cutting or removal. As the Forest Service the draft environmental impact statement, and final environmental impact statement are developed we are considering the needs of developed recreation, ski areas, as well as conservation and stewardship of old-growth forest conditions.

Q: Will forest supervisors and regional foresters have the ability to make local level decisions?
A: The proposed amendment was designed to be informed by place-based knowledge. Local management is based on old-growth forests conditions gathered from regions and forests, as well as current and possible future threats to those conditions. The proposed amendment provides a framework for management and monitoring to maintain and improve old forest conditions. Forest supervisors and regional foresters will be able to make decisions and implement management actions informed by local geography, ecology and social settings.

Q: Why are some projects moving forward in areas where there is old growth?
A: Current forest land management plans provide direction and guidance on management activities, until such time a Record of Decision is signed. The proposed amendment, while not in affect yet, is not anticipated to prohibit activities in old growth conditions for ecological purposes. Projects affecting old growth are carefully reviewed at a national level.

Q: How will the mature and old growth definition, inventory and threat analysis inform the old growth proposed amendment and draft environmental impact statement? A: The initial inventory identifies the amount of mature and old growth forests nationwide, and by region, which sets the context for local evaluation under the draft environmental impact statement. The threat analysis outlines regional differences in primary threats to mature and old growth forest conditions, which also sets context for evaluation in the draft environmental impact statement. The threat analysis results also inform evaluation of alternatives in the draft environmental impact statement by framing how the alternatives in the proposed amendment might address threats to old-growth forests.

Q: Given this is an old-growth amendment, does it also provide guidance for the management of mature forest conditions?
A: Mature forests are not being included in conjunction with old growth for all aspects of the amendment. However, the amendment does place an emphasis on identifying and prioritizing areas of mature forests to be managed for future old-growth forests, particularly in the modified proposed action in the draft environmental impact statement. Specific direction to identify priority areas for the recruitment of future old-growth forest – including from mature forest – is included in the modified proposed action as part of the long-term adaptive strategy for old-growth forest conservation and in a guideline that applies to management of those areas.