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
In addition to submitting AFA’s comment letter, the AFA 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. AFA’s contribution to the legal fees was funded by donations from AFA members and area businesses and organizations and we thank them for their support!
Fortunately, the USFS is proceeding carefully with public comment opportunities and preparation of an Environmental Impact Statement (EIS). There will be another opportunity to comment when the EIS is published in May/June.