UPDATE: The USFS has withdrawn its notice of intent to prepare a final Environmental Impact Statement (EIS) for this proposal. This is an enormous success for the sustainability of our national forests and the communities that host them!
However, the email notice referred to “our future stewardship of these special forests”, so the AFA will be keeping an eye on future actions with similar intent.
The agency also listed an upcoming proposed ruled, “Climate Resilience and Carbon Stewardship on National Forest System Lands”, planned for March 2025. This sound like it may be a rebranding of the old-growth amendment combined with the USFS’ Carbon Capture and Storage rule, which is delayed while they respond to thousands of public comments. We are working with our partners to urge the incoming Agriculture Secretary to prevent the publication of this, or any similar rules.
HISTORY: On December 20, 2023, the USFS published its Land Management Plan Direction for Old-Growth Forest, which would direct a system-wide update to 128 forest management plans mandating creation of more old-growth on every forest. There was plenty to be concerned about in this proposal and a total of 5,742 comments were submitted. The AFA’s comment letter opposed the plan based on its:
- Lack of sufficient research and analysis
- Negligence of responsibility to furnish a continuous supply of timber for the needs of our nation
- Negligence of responsibility to support economic vitality of rural communities
- Inadequate stakeholder notice and time to comment
- Economic impact concerns
- Conflicts with privately owned OGM rights and lack of consideration of unique characteristics and conditions
- Conflicts with agency (USDA-USFS) research
- Threats to species diversity (trees, plants, and wildlife)
- Inappropriate burden placed on forest communities
The USFS moved forward with preparation of a 192-page Draft EIS, plus hundreds more pages of appendices and reports. It was published on June 21, 2024, with a 90-day comment window. The ANF was identified as “anticipated to experience noticeable change in terms of old growth plan direction.” In a July 31, 2024, meeting with ANF staff and a representative of the USFS Eastern Region office, we were told that the Allowable Sale Quantity and management areas would not change, but timber receipt payments and employment could be impacted.
Based on the Draft EIS, the AFA’s expectation was that harvestable acres would decrease and new recreation development, sub-surface resource owners, and lease holders could be impacted. We, again, commented against approval of the Old-Growth Amendment Plan, citing forest health and economic concerns, and objecting to the lack of required coordination with local governments and stakeholders.
In addition to submitting AFA’s comment letter, we also teamed up with the Multiple Use Alliance, a coalition of counties in western states, by contributing to the cost of and signing onto a comment letter prepared by an attorney experienced in federal land management policy and statutes who has successfully argued before the Supreme Court.
After reviewing over 300,000 comment letters, the USFS withdrew their intent to publish a final EIS on January 7, 2025.
We are watching for more on this and other threats to our national forest lands and communities, and will continue to fight such proposals. Stand with us in these efforts, and support our work by becoming a member today!