The draft proposal released by the Forest Service outlines four potential pathways (referred to as Alternatives) that they may follow when putting together the final policy. 

• Alternative 1, in which no action is taken (no national-level old-growth policy implemented)

• Alternative 2, in which old growth forests are proactively managed for climate adaptation, which may include logging for restoration purposes; 

• Alternative 3, in which all commercial timber harvest is restricted in old growth forests; 

• Alternative 4, which permits timber production and commercial logging in old growth forests without requiring it be for ecological or restoration purposes.

Alternative 3 offers the strongest protections around old-growth forests, which are needed because of the enormous historic losses of these forests from logging over the past centuries and our dire need for their outsized climate and biodiversity benefits. We support the provision in this alternative that does not allow commercial exchange of trees. However, we recommend that the Forest Service adopt a modified Alternative 3 that:

• Reduces opportunities for the cutting of old-growth trees and in particular, the cutting of any trees in old-growth stands that are in moist forest types.

• Removes the exception for "de minimis" logging of old-growth trees, which means that some old-growth trees could still be cut for "research" or "local community purposes." This language is too vague and could leave too many old-growth trees vulnerable to being sent to the mill.

In addition to the above comments specific to Alternative 3, the entire amendment proposal should be improved to address these concerns:

• There are no measurable goals for retaining old-growth or recruiting future old-growth from mature forests. 

• “Proactive Stewardship” could allow changes to a forest that would mean it no longer meets the definition of old-growth, then removing it from being protected from this very policy. Managing these forests in a way that removes their old-growth character goes against the very spirit of the policy.  We recommend not allowing "proactive stewardship" to be applied in a way that reduces the amount of old-growth forest.

• The Technical Guidance for Standardized Silvicultural Prescriptions for Managing of Old-Growth Forests  suggests that they will need to be treated (e.g. mechanical thinning, harvest, prescribed fire) even if they already represent the desired condition. If it ain’t broke, don’t fix it!

• Additionally, that guidance document provides a pathway for old-growth forest to be cleared entirely as a last resort to "move the stand toward desired conditions and/or improve ecological integrity." Ecological integrity is not defined in these documents and could be dangerously vague. Stand-replacing cuts (clear cuts) in old-growth forest does not contribute to its health, resilience, or conservation nor is it a climate-smart practice.

Alternative 2 has been designated as the US Forest Service’s preferred Alternative, but there are serious issues with how the policy allows "proactive stewardship" to result in old-growth forests being logged and allowing the commercial sale of these trees.

Alternatives 1 and 4 don’t offer any added protections for old-growth forests and increase the threats to these forests. 

We are excited about these steps being put into place, but want to make sure that as these policies are further developed, the rationales and exceptions outlined for management activities and possibly cutting within old-growth forest stands do not undermine our ability to keep these forests intact. We encourage you to emphasize the need for the policy to eliminate commercial logging in old-growth stands, highly limit exceptions to non-commercial cutting, and expand our recruitment of future old-growth forests by protecting more mature forests now from logging. 

An effort to create policies surrounding old-growth forests on federal lands has been ongoing since 2022, when President Biden issued an executive order (EO 14072) directing the US to inventory, assess threats, and develop policies to strengthen mature and old-growth forests. We were thrilled to hear old-growth being directly addressed by the president and see the path laid for the first ever national-level old-growth protections. 

In late 2023, the US Forest Service addressed the executive order by drafting a proposal to add amendments to all national forest management plans that specify the stewardship of old-growth forests, which has been previously absent at the national level. This proposal has continued to take shape over the past few months and has reached the point in which the public can weigh in on which path forward within this proposal is best for protecting our old-growth forests. The final policy should be available in January 2025.

Watch for free here.

The film makes a case for protecting mature and old-growth forests on federal public lands and features several mature and old-growth logging projects across the US.  “Crown Jewels” documents a year-long journey through some of the last ancient forests on US public lands, highlighting their crucial role in protecting our land, air, and water. Beyond their environmental benefits, these forests hold deep cultural and community significance as seen across West Virginia, Wisconsin, and Oregon. Threatened by imminent logging plans by the Forest Service, these ecosystems face permanent destruction unless widespread support for their protection is mobilized. The film advocates for viewers to leverage their freedom of speech to transform federal land management together, urging those who watch to join the effort through local activism and storytelling.

Watch the webinar here.

A detailed overview of the Old-Growth Amendment proposal from the Great Old Broads for Wilderness, The Wilderness Society, and Environment America. View for even more helpful suggestions you can include in your comments.