ACTION ALERT: SPEAK UP FOR A HISTORIC OPPORTUNITY TO PROTECT THE NATION’S OLD-GROWTH

A Historic Opportunity

 

The Biden Administration has taken several steps to combat climate change and advance environmental stewardship, including a number of steps to preserve the nation’s old-growth.

On Earth Day, 2022, the Administration issued an Executive Order (EO) directing federal agencies to create a consistent definition for old-growth forests that accounted for regional and ecological variation and to complete an inventory of mature and old-growth forests on federal land. The EO also required the agencies to assess threats to mature and old-growth forests and develop policies to address those identified threats. Since April 2022, the Administration has released the inventory data, conducted an assessment of threats for mature and old-growth forests, and solicited public input to start developing a plan to make old-growth forests across the country more resilient.

The Administration’s effort to develop a plan to make old-growth more resilient is now nearing its final steps. The Forest Service has put forward a Draft National Old-Growth Amendment, which would revise forest plans (management plans unique to each of the country’s 154 national forests) to “establish a consistent framework for old-growth forests across the National Forest System.”

 

What the Draft Amendment Gets Wrong

 

The Draft Amendment is presented as a plan for resilient old-growth forests across the country. Judged by its stated goals, the Draft Amendment does not meet those goals and could do more harm than good. A nationwide amendment to forest plans represents a once-in-a-generation opportunity to safeguard old-growth forests, slow climate change, protect wildlife, and improve the quality of aquatic ecosystems. We need people like you to join CFC in asking the Forest Service to address the numerous flaws in the Draft Amendment by the September 20th comment deadline.

While the Draft Amendment’s stated intention to make old-growth resilient sounds positive, the proposed plan fails to adequately protect existing old-growth or recruit new old-growth.

For example, the Draft Amendment doesn’t include any language addressing the alarming deficit of old-growth on national forest lands. The Forest Service acknowledges the outsized role old-growth forests play in sequestering atmospheric carbon and their importance in preserving biodiversity, but the plan does not consider or speak to the need to create more (and more connected) old-growth by preserving and enhancing existing mature forests (those on the brink of becoming the next generation of old-growth).

Additionally, the amendment focuses on proactive stewardship (thinning, prescribed fire, and other treatments) in all old-growth types. A focus on active management for all old-growth is problematic. While proactive management to reduce wildfire risk may be appropriate in some forest types it is certainly not needed or beneficial in all. In wet forests west of the Cascade crest, these proposed management strategies could do more harm than good.  

The Draft Amendment also includes many inappropriate exceptions to the proposed standards—exceptions that could lead to meaningful losses of old-growth forests. Several of the exceptions are broad in scope. For example, an exception from the proactive stewardship requirement allows the Forest Service to ignore the stewardship standards for management in old-growth when “this standard is not relevant or beneficial to a particular forest or ecosystem type.” There is no explanation about what this means or what type of scenarios would fit, and without that explanation, it could be applied very broadly to exempt large portions of old-growth from the standards meant to protect them. While some ability to apply site-specific nuance is warranted, without parameters or explanation, this exception could easily become a large loophole.   

 

How to Comment

 

Amending each of the nation’s forest plans to protect old-growth could be a historic accomplishment, but the Draft Amendment would fail to meet this goal as currently written.

Individuals, business interests, and organizations of all viewpoints and political persuasions are currently weighing in on the Draft Amendment. It is imperative that as many voices as possible speak in favor of new meaningful protections for old-growth and urge the agency to address the fundamental flaws currently undercutting the Draft Amendment’s stated intentions. 

Take action today by submitting your comments electronically HERE by September 20th, 2024. Here are some talking points to help frame your comments.

  • I support the Draft Amendments vision of a system of resilient old-growth. The current Draft Amendment would fail to achieve that vision. 
  • The Desired Conditions should include language about increasing the amount of old-growth forests across the National Forest System since there is a deficit of old-growth currently on the landscape. 
  • Currently the plan does not consider an alternative that would require conservation of mature forests, or a portion of mature forests. I believe the Final Environmental Impact Statement should include an alternative that looks at conserving at least some portion of existing mature forests.  
  • Proactive stewardship of all old-growth forest types is inappropriate. The amendment language should be changed to acknowledge that some old-growth forests, like those west of the cascades, should be passively managed. In other words, leave old-growth west of the cascade crest alone. 
  • The standards as currently written in the preferred alternative Standard 2c. allow for too many inappropriate exceptions that could lead to meaningful loss of old-growth forests. While exceptions for tribal use are appropriate, all of the others should be removed from the plan.

If you have any questions or need help, please reach out to Ashley at ashley@cascadeforest.org.

ACTION ALERT: SPEAK OUT FOR THE ECOLOGICAL & SCIENTIFIC VALUES OF SPIRIT LAKE

Mount St. Helens, the Pumice Plain, and Spirit Lake are special places Cascade Forest Conservancy has fought to protect since our founding. Now, we need your help speaking out to preserve the ongoing ecological recovery occurring here and the scientific insights this healing volcanic landscape is providing to us. 

 

The Spirit Lake Outlet Tunnel

 

The eruption of 1980 created a debris flow that blocked the natural outlet of Spirit Lake. Scientists and engineers realized that with nowhere to go, Spirit Lake’s waters threatened to overflow and destabilize this earthen dam, potentially leading to a massive mudflow that could pose a serious danger to downstream communities.

For the safety of these communities, the US Army Corps of Engineers built an outflow tunnel to prevent the most unstable parts of the debris blockage from being breached. But the existing tunnel was never meant to last forever and it has reached the end of its life expectancy. 

Between 2018 and early 2023, CFC fought specific elements of a project to temporarily repair the outlet tunnel’s gate. We took particular issue with the Forest Service’s plan to build a road across the Pumice Plain—a protected recovering ecosystem found nowhere else on Earth and the site of important ongoing research. We argued that the road (although temporary) would do long-term damage to an otherwise pristine natural laboratory, that the Forest Service had failed to adequately consider other ways to transport workers and materials to the job site, and that the plans provided by the agency did not adequately address the impacts of the road to watersheds and wildlife at the site. Although we lost that legal case, the story is not over. More decisions impacting the Pumice Plain, Spirit Lake, and Mount St. Helens are on the way. 

 

Speak out for the ecological and scientific value of Mount St. Helens, the Pumice Plain, and Spirit Lake

 

Official planning for what to do long-term with Spirit Lake’s outlet is just beginning. The Forest Service has started a process that will inform how project planners will weigh different values further into the planning process. 

We need people like you to speak up early in the planning process to advocate for a Spirit Lake outflow tunnel replacement project that keeps downstream communities safe WHILE ALSO preserving the ecological integrity and science happening in the Mount St. Helens National Volcanic Monument.

Your voice makes a difference! Take a moment to complete and return this attached survey by August 31st. 

Download the survey as an interactive PDF HERE.  E-mail your completed questionnaire to sm.fs.spiritlake@usda.gov no later than August 31, 2024. 

Email ashley@cascadeforest.org with questions.