August 20, 2024

Fighting Climate Change by Protecting Mature & Old-Growth Forests

Urge the Forest Service to strengthen the National Old-Growth Amendment Plan

By Ben Dickerson, ELPC Intern 2024

As the climate crisis intensifies, so does the need to defend our communities from its harmful effects. We must prioritize conserving and expanding our mature and old-growth forests because they “are critically important for slowing climate change.” The United States Forest Service (USFS), however, isn’t doing enough to protect these forests.

Far from the robust response necessary to combat the climate crisis, the Forest Service’s new National Old-Growth Plan Amendment (NOGA) fails to meaningfully address misguided logging practices in our National Forests. The USFS must deprioritize logging, prioritize climate and biodiversity, and revise NOGA to better protect old growth and mature growth.

URGE THE U.S. FOREST SERVICE TO TAKE ACTION TODAY

Old Growth, New Science

“Old growth” refers to forests that have developed over 150+ years without major disturbances from logging, wildfire, human development, etc. These forests have the time to develop unique ecological biodiversity, healthy soils, and other climate benefits. Mature forests have similar ecological qualities over a shorter time period, having experienced disturbances within the last 75-150 years.

Climate scientist William R. Moomaw says mature and old-growth forests “remove huge quantities of carbon [pollution] from the atmosphere … and store [it] in trees and soils.” These forests “handle droughts, storms, and wildfires better than young [forests], and they store more carbon.” As forests age, “they absorb more carbon every year, and because [the trees in those forests] are bigger they store more carbon.” Thus, Moomaw advocates for “leaving older and middle-aged forests intact because of their superior carbon-sequestration abilities,” a theory he’s dubbed “proforestation.”

Put simply, proforestation means we “should protect big trees, and … trees that are going to become big trees.” Climate scientists agree: Per the IPCC’s 2022 climate assessment, protecting existing mature and old-growth forests is an excellent way to curb and capture carbon pollution. Proforestation, Moomaw emphasizes, also enhances “biodiversity, water and air quality, flood and erosion control, public health benefits, low impact recreation, and scenic beauty.”

Unfortunately, much American old growth, especially in the Midwest and the East, was cut down in massive-scale logging in the late 1800s and early 1900s. But the federal government can still promote proforestation by protecting the remaining old growth on federal lands, and by recruiting more mature growth to become tomorrow’s old growth.

The Road to NOGA: Planning & Posturing

In April 2022, President Joe Biden’s Executive Order 14072 called for “policies to … address threats to mature and old-growth forests on federal lands.” Shortly thereafter, the USFS began work on the National Old-Growth Plan Amendment (NOGA), an effort to create protections for old growth (but not mature growth) in our 128 National Forests.

As the first step toward NOGA, the Departments of Interior (DOI) and of Agriculture (USDA) conducted an inventory of old-growth and mature forests on federal lands. The April 2023 Inventory found that among the 178 million acres of federal forest lands, there were about 32 million acres of old-growth and about 80 million acres of mature growth woods. These surprisingly high figures were a promising start, indicating that the agencies might intend to use forests to fight climate change.

But the Departments’ January 2024 Threats Analysis claimed on its first page that logging “is currently a relatively minor threat.” It argued that across the nation, the primary threats to mature and old growth are wildfire, pests, and disease, all exacerbated by climate change. This may be true for Western forests but, by the USFS’s own admission, is far less true as applied to all 128 National Forests.

The USFS itself stated in its October 2023 Forest Carbon Assessment for Chequamegon-Nicolet National Forest that from 1990-2011, logging was the primary disturbance in all Eastern forests. The agencies argued the threats of wildfire, pests, and disease are so formidable that some logging (“proactive stewardship”) is inevitably necessary to protect our forests as climate change worsens. It became clear that this minimization of logging’s harmful environmental effects is characteristic of the USFS approach to NOGA. They champion logging as a threat response to justify continued logging of mature and old growth.

NOGA’s Fatal Flaws

Early descriptions of NOGA promised it would amend the Forest Plans of all 128 National Forests to include protections for mature and old-growth forests. But in June 2024, the USFS released the Draft Environmental Impact Statement (DEIS) for NOGA, detailing its proposed implementation and projected environmental impact. Unfortunately, the DEIS draft plan is far too weak to meet its stated goals. As currently written, NOGA fails to “foster the long-term resilience of old-growth forests,” because:

• It fails to prohibit commercial logging of old growth.

• It does not protect mature growth to ensure recruitment of future old growth.

• It does not designate any areas for protection of old growth.

• It does not create any federal protections for old growth.

• It does not establish any goals for conservation of old growth, for sequestration of carbon pollution, or for expansion of mature and old-growth forests.

Instead, NOGA provides a set of permissive parameters for individual National Forests that will create vanishingly little material change. NOGA directs National Forests to establish their own versions of these parameters using NOGA’s “Adaptive Strategies for Old-Growth Management,” but that’s a matter of theory more than practice.

There is no ban on commercial logging of mature and old growth, and NOGA provides a laundry list of circumstances under which proactive stewardship in old-growth forests is not only appropriate but encouraged. In fact, within a year of the implementation of the final NOGA, National Forests would actually need to initiate at least three logging projects for proactive stewardship in order to comply with NOGA.

NOGA also grants substantial deference to National Forests whose Forest Plans already include some old-growth management directives. In many cases, it would not change logging, and in other cases implementation will actually require the initiation of new logging projects. In other words, the draft NOGA would require, not prevent, logging in our National Forests, and it will be ineffectual in promoting old-growth conservation.

The USFS has failed to respect EO 14072’s directive to base decision-making on the “best available science.” Instead, the USFS appears to have sought out scientific reports that support continued logging, despite the scientific consensus that we must use forests to fight the climate crisis.

In revising NOGA, the USFS must take a hard look at its priorities and recalibrate them toward conservation and climate-change mitigation. This recalibration is essential if the USFS intends to produce a final NOGA with real teeth, a NOGA that backs up its promise to confront the climate crisis by fostering the long-term resilience of mature and old-growth forests.

Conclusion: Act Now

The USFS is accepting public comment on this plan until September 20. It’s our duty to let them USFS know that as it stands, NOGA is weak and insufficient. It is a symbolic but toothless show of support for conservation that will not create meaningful change in our National Forests.

A Forest Service that makes logging its priority cannot be expected to properly respond to the climate crisis. We must urge the USFS to shift its internal priorities toward conservation, and to revise NOGA to include protections for mature growth and to strengthen protections for old growth. We must demand that the final NOGA include protections for mature and old growth that stand up to the urgency of the climate crisis.

TAKE ACTION TODAY

Please tell the USFS to deprioritize logging and prioritize the conservation of our mature and old-growth forests. Tell the USFS the final NOGA must ban all commercial logging of old growth and must provide guidelines to ensure recruitment of future old growth.

Hear from ELPC’s Andy Olson in this Feature-Length Documentary