Background and Message Points for Federal Old Growth Definition and Inventory

Request for Information: Federal Old-Growth and Mature Forests

The U.S. Forest Service (USFS) and Bureau of Land Management (BLM) are seeking public input to define and inventory “old-growth and mature forests” on federal lands in their first step toward complying with President Biden’s 2022 Earth Day executive order that identified “climate impacts, catastrophic wildfires, insect infestation, and disease” as the primary threats to all forests, including older forests. The Inflation Reduction Act recently passed by Congressional Democrats includes $50 million “for the protection of old-growth forests on National Forest System land and to complete an inventory of old growth forests and mature forests within the National Forest System.”


How to Submit Comments

Federal agencies recently announced an extension of the public comment period to August 30. Formal comments can be submitted here:



This misguided effort to define old growth and mature trees will only lead to more arbitrary policies that limit the ability of federal agencies to treat overstocked forests and will lead to less old growth on the landscape over time.  Anti-forestry groups are using this “define and inventory” process to push for more anti-forestry regulations, even though only 25 percent of the National Forest System is available for regular timber management. Anti-forestry activists point to the 2001 Roadless Rule as a model policy that restricted active forest management and road building on over 58 million acres of federal lands.


More than 37 million acres of National Forests have burned since the Clinton-era Roadless Rule was adopted, an acreage more than seven times larger than the acres where thinning and timber harvest has actually occurred during this time.  Fires are burning so hot some forests are failing to regenerate naturally.  Efforts to restrict management in “old growth and mature” forests ignore the fact that forests are dynamic ecosystems where disturbance events can reset 100- to 200-year-old forests to zero in the course of a single day.


The new directive comes as the Forest Service faces “pretty brutal” staffing shortfalls and faces fresh criticism that the wildfire prevention treatment figures it reports are “misleading, “inaccurate” and incentivize the treatment of low cost acres rather than the most effective or at-risk areas.


Rather than focusing on confronting our national wildfire and smoke crisis through climate adaptation strategies and active forest management, federal agencies must now spend time and resources developing a “universal definition framework” of old-growth and mature forests across incredibly diverse and complex forests with widely different tree species, sizes, characteristics and needs.


Nonetheless the USFS and BLM are obligated to comply with this misguided executive order and are currently seeking public input to guide their efforts.  Feedback is requested to assist with the development of a “universal definition framework” for old growth and mature forests.  Feedback is also requested to help inform a forest inventory once those definitions are finalized.


Take Action

The USFS and BLM need to hear from the public that forest successional stages cannot be defined by arbitrary attributes such as age or the size of trees.  They also need to hear that actively managing these forest types is often necessary to conserve them.  Please consider submitting comments by August 30 to help ensure this misguided, top-down policy does not further restrict science-based management of our national forests.


Key Message Points


  • It is an impossible and unscientific task to come up with a single definition of old growth that applies to many diverse forests and forest types across the United States.


  • Any single definition of old-growth and mature forests could be so general that it’s useless in guiding forest management across the nation, or so specific that it leaves out forests that some would consider mature.  In no case, should the agencies adopt a definition based on arbitrary size, age, or diameter limits.


  • At a time when we need more management on fire-prone federal lands, this is a formula for more bureaucracy and red tape that further ties the hands of our public lands managers.


  • Most lands managed by the federal government are already off-limits to logging or have restrictions that make active forest management infeasible.


  • Well-meaning but misguided efforts to define old growth and mature trees will only lead to more arbitrary policies that limit the ability of federal agencies to treat overstocked, fire-prone forests and will lead to less old-growth on the landscape over time.


  • The worst thing we could do during a climate crisis is to walk away from our public lands and decide not to use the tools available to help adapt these lands to changing conditions and reduce the risk of catastrophic wildfire.



  • This effort to “define and inventory” older forests undermines the Biden Administration’s own 10-year wildfire strategy to significantly increase forest management treatments and diverts limited resources away from our national wildfire and smoke crisis.


  • The USFS and BLM should focus on accelerating active forest management on federal lands to reduce the risks of severe wildfires and to improve our forests’ resiliency to fire, insects and disease, and to adapt these landscapes to the impacts of climate change.


  • Such treatments have helped public lands managers and firefighters save large, old and mature trees from destruction, including the iconic Giant Sequoias in California.