AFRC Submits Comments on Northwest Forest Plan, National Old Growth Amendments

The American Forest Resource Council (AFRC) today submitted formal comments to the U.S. Forest Service on amending the 30-year-old Northwest Forest Plan (NWFP) governing the management of 17 national forests and over 24 million acres in Northern California, Oregon, and Washington.

Separately, AFRC submitted formal comments in response to the Forest Service’s Notice of Intent that proposes to amend all 128 land management plans across the country with the intention of protecting old-growth forests on National Forests.

In both comments, AFRC urged the agency to take a proactive and science-based approach to address the real threats to these federal lands, and to recognize the importance of the forest sector and the use of wood products in achieving healthier forests, reducing severe wildfire risks and combatting climate change.

Northwest Forest Plan

Recognizing the consensus among scientists, stakeholders, and the Forest Service’s own Threat Assessment about catastrophic wildfire being the most significant threat to Pacific Northwest forests, AFRC underscored the need to shift to modern forest management strategies that will help meet today’s challenges and realize better outcomes for communities and wildlife, including forest health and resiliency.

“We are not interested in reigniting the ‘Forest Wars’ of the past. Our focus is on practical, realistic, and implementable solutions that improve forest health, reduce wildfire risks, protect communities, and provide socio-economic benefits to the American public,” AFRC President Travis Joseph wrote. Joseph also serves as co-chair of the Northwest Forest Plan Federal Advisory Committee.

AFRC stressed the importance of a durable NWFP amendment that provides clarity, predictability, and accountability in management to rebuild trust with Tribes, impacted communities, and businesses that are closely tied to the implementation and success of the plan. This can be accomplished by adopting targeted and accelerated management activities that include thinning, timber harvests, fuel breaks, prescribed burning, as well as improvements in wildfire detection and suppression tactics.

Furthermore, AFRC highlighted the role of active forest management in mitigating climate change, including the importance of routine timber harvests coupled with storing carbon in long-lasting wood products followed by effective reforestation. This is consistent with the findings of international climate scientists that suggest sustainable management and using more wood products can maintain or enhance forest carbon stocks while decarbonizing our buildings.

The forest products sector provides the Forest Service with needed infrastructure – including logging and milling capacity and wood markets – or “boots on the ground” to help the agency meet its conservation and stewardship goals. Managing these federal lands also offer economic benefits to rural communities and local governments.  According to Forest Economic Advisors, every million dollars in timber sales generates 12.3 direct jobs, 15.5 indirect jobs, and 7.3 induced jobs across various sectors.

AFRC remains committed to collaborating with the USFS and other stakeholders to ensure a balanced, effective NWFP amendment that addresses the challenges faced by the forests, communities, and industries in the Pacific Northwest.

“AFRC and its members, the forest products sector, and timber-dependent communities are ready for a new chapter in federal forest management in the Pacific Northwest.  We are focused on and committed to practical, realistic, implementable solutions.  We are not interested in perpetuating conflict, ideological debates not based in fact or science, or political management of dynamic forest ecosystems – all of which have dominated the public discourse over the last 30 years.”

Old Growth

AFRC’s comments to the Forest Service on old growth similarly urges the agency to take meaningful steps to address the true risks to old growth forests on National Forest System lands – specifically severe wildfires, insect infestations and disease that have already destroyed nearly 5.3 million acres of mature and old growth forests on federal lands since 2000.

Yet AFRC also questioned the agency’s process in simultaneously amending all forest plans in a single year, given the broad ecological diversity and needs of individual national forests. The Forest Service should explain and offer its legal and policy rationale for pursuing a nationwide Environmental Impact Statement (EIS) to achieve the requirements of NEPA, rather than pursuing EISs or environmental assessments at the forest plan level.

“The scope and scale of this proposed amendment is unprecedented.  To our knowledge, the Forest Service has never attempted to amend every single management plan in the nation with a single EIS to achieve ‘consistency’ on any plan element since the enactment of the National Forest Management Act (NFMA),” AFRC wrote in its comments.

“While we support the need to protect and enhance forests of all successional stages, including old growth, from wildfire, insect and disease damage, and other climatic stressors, we do not support the proposed strategy of doing so with a nationwide amendment on an aggressive timeline of less than one year.  Such an approach fails to accommodate and respond to the dynamic, geographically specific, ecologically unique forest ecosystems and tree species across the 193 million acres of federal land under the Forest Service’s stewardship.”

If sustaining and recruiting old growth forests is truly the goal, AFRC said the Forest Service should implement effective forest management strategies that are informed by science, public input and conditions on the ground:

“AFRC, its members, and the communities the forest sector supports care deeply about the health and resiliency of our National Forest System and all the values they provide to society, including the protection of old growth forests from the impacts of wildfires, disease and insects.  The best way to protect old growth on federal lands from these threats is through proactive, science-based, intentional, strategic, active management.  By definition, this approach requires tailored direction at the local level, with public input, that address the extraordinary diversity and unique threats of each national forest.  This is in direct contradiction to the Forest Service’s stated goal of creating a “consistent” national approach to protecting and recruiting old growth.”