SAF Addresses Mature and Old Growth Initiative in Recent Public Comment 

February 22, 2024

The Society of American Foresters recently commented on the USDA Forest Service’s notice of intent (NOI) addressing a proposed amendment to all land management plans for units of the National Forest System (NFS). This amendment aims to provide “consistent direction to conserve and steward existing and recruit future old-growth forest conditions and to monitor their condition across planning areas of the National Forest System.” 

Informed by previous agency efforts stemming from Executive Order (EO) 14072, such as the national inventory and initial threats for mature and old-growth forests, as well from public feedback received on the Climate Resilience Advance Notice of Proposed Rulemaking (ANPR), the NOI is the next step in the broader mature and old growth initiative.

The Forest Service plans to prepare a draft environmental impact statement (DEIS) to evaluate and disclose the effects of the proposed amendment, both of which are expected in May 2024 and will be accompanied by a 90-day comment period. The final DEIS is expected in January 2025.
Commenting on the current NOI, SAF emphasized two critical points to the Forest Service: (1) science-based forest management is an essential tool for promoting the long-term conservation and sustainability of forested ecosystems, including old-growth forests; and (2) changes to NFS plans must be made through local processes and with input from local expertise to reflect the large variation in regional forest types, conditions, threats, and management needs. 
As the Agency’s initial threat analysis explains, “wildfire, exacerbated by climate change and fire exclusion, is the leading threat to mature and old-growth forests, followed by insects and disease.” It is critical that efforts to conserve mature and old-growth forests be compatible with the USDA Forest Service’s Wildfire Crisis Strategy. The recommendations produced by the Wildland Fire Mitigation and Management Commission offer a comprehensive, holistic guide to wildfire management that should be incorporated into future action. In order to address these threats while continuing to provide the historic suite of benefits provided by forests, we also need a stronger workforce to implement these strategies at scale. 
SAF will leverage this comment to share more broadly with policymakers and the public the importance of forests, forest management, and forestry professionals in fostering the future health and sustainability of our nation. We encourage you to share the comment within your networks and use it in your own outreach efforts.   

Read SAF's comment here.