Hunt-Fish Old-Growth NOI Final Comments
Feb. 2, 2024
Ms. Linda Walker, Acting Director
Ecosystem Management Coordination
United States Forest Service
201 14th Street SW, Mailstop 1108
Washington, DC. 20250-1124
RE: Hunt-Fish Comments on Notice of Intent on USFS “Land Management Plan Direction for Old-Growth Forest Conditions Across the National Forest System”.
Dear Ms. Walker:
The below signed hunting, fishing, and wildlife conservation organizations work to advance the interests
of millions of American hunters and anglers. Please consider our comments and recommendations
related to the proposed USFS old growth amendment, which is intended, “to create a consistent
approach to manage for old-growth forest conditions with sufficient distribution, abundance, and
ecological integrity to be persistent over the long term, in the context of climate amplified stressors.”
The abundant public lands that make up our national forests and grasslands are of utmost importance to
our community for providing habitat for numerous fish and wildlife species and abundant recreational
opportunities valued by America’s 40 million hunters and anglers. Responsible forest management is
necessary to sustain and support fish and wildlife populations across varied landscapes. Shifting climate
conditions are contributing to more frequent and extreme weather events, uncharacteristic wildfires,
invasive species, prolonged drought, floods, disease proliferation, and creating other challenges across
America’s 193 million acres of National Forests and Grasslands.
Resilient, functioning forest ecosystems provide clean air, quality water, viable plant and animal
populations, and a range of cultural values to society. Old growth trees and forests are important
components of these ecosystems, and we appreciate the USFS effort to create a consistent approach to
conserving and managing old growth trees across our national forest system. As a community, young,
early seral, forests are also important, and we encourage the USFS to ensure that the value of early seral
forests is recognized during National Forest plan amendment processes, where appropriate.
For many forest types, having stands with both diverse age classes and a diversity of species often means
fewer invasives and disease, and reduced fuel loads, making them less susceptible to catastrophic loss
from wildfire, often leading to more carbon storage than seen in less diverse, unhealthy forests.
However, many forest types are at risk of becoming carbon sources rather than carbon sinks. Landscape-
and ecosystem-appropriate management based on the best available science is necessary to adapt to
changing climatic conditions while optimizing carbon storage. Without appropriate management
responses, these climatic changes will fundamentally affect our outdoor heritage and the annual $200
billion hunting and fishing economy and $1.1 trillion-dollar outdoor recreation economy in the U.S.
Our recommendations acknowledge and support the need for both protection and management of old
growth forests, as well as the need for management by forest-type, all while planning for overall
ecological and societal sustainability. There is no one-size-fits-all forest management strategy, but
effective site-specific strategies can range from increasing carbon sequestration through active
management that emphasizes reforestation and forest restoration, to stewarding late successional
forests with long-term historic disturbance frequencies that store large volumes of carbon in soils and
trees. Please consider our recommendations to ensure that vital habitats for a diversity of fish and
wildlife species are maintained and improved over time—supporting ecosystem resilience and
opportunities for future generations to enjoy our public lands.
Principles and Statements of Support: Specifically, we believe that any forthcoming forest management
policies for our national forests should support the following outcomes:
• Promote forest diversity. A shifting mosaic of young, middle-aged, and old growth forests
across landscapes is imperative to manage for climate resilience. To do so, we must view forests
as dynamic collections of important seral states. Climate resilience, carbon optimization, and
biodiversity are maximized when varying forest ages are interspersed across landscapes, from
young forests to old growth.
• There is broad agreement that active forest management is necessary to reduce risks of
uncharacteristic wildfire, optimize carbon outcomes, improve fish and wildlife habitat, safely
restore forests to a fire-adapted forest condition, and restore impaired ecosystem function. The
challenge is how to manage these landscapes at the scope and scale to address the increasing need.
o As a tool, active management is not a universal replacement for natural disturbances
and neither active management nor passive management are appropriate in all
situations. Additionally, many active management actions, such as thinning or
harvesting, must be accompanied by maintenance activities at regular intervals, such as
reforestation or prescribed fire to maintain the effectiveness of a thinning project.
o “Protection” or maintenance of old growth forests doesn’t necessarily mean hands-off.
Many old growth conditions can be accelerated and/or maintained through active
management, including, but not limited to, selective harvesting of trees and prescribed
fire.
• Healthy forests play a huge role in carbon storage and sequestration. One of the primary values
of old growth forests is carbon storage, as large trees store significant amounts of carbon. When
old trees die or burn, they emit carbon through decomposition and smoke. Smaller, fast growing
trees sequester carbon at a faster rate and are also important for long-term carbon storage.
Future forest management must account for the full carbon cycle and diverse forests across all
age and size classes.
• A single, one-size-fits-all approach to managing mature and old growth forests cannot conserve
mature and old growth forests given the ecological variables in play and the heterogeneity of
the resource at issue. For example, the approach to managing western red cedar must be
different than the management approach for eastern hemlock. The USFS should ensure that
management policies allow for the best available science for the wide variety of forest types and
landscapes that are our National Forests.
• The health of our forests and the sustainability of old growth forests requires flexibility and a
variety of management practices and tools. The addition of this amendment into forest plans
should not negatively affect the ability of the USFS to use the tools at their disposal to address
the forest management crisis facing our country, specifically uncharacteristically severe wildfires
in our Western forests.
• Per the science from USFS Research Stations, the Forest Service must conduct vegetation
management at much larger geographic scales (4 to 5 times greater) to restore forest health and
promote resilience, which includes an ecologically appropriate abundance and distribution of
mature and old growth forests as well as young, regenerating forests where those traits are not
yet developed.
• Wildlife research documents how wildlife diversity is greatest where diverse forest types and
ages are interspersed across landscapes, including young, middle-aged, mature, and old growth
forests across different forest types.
• As the forest service amends all 128 land use plans, we believe addressing each plan at the unit
level and utilizing other step-down processes will strengthen local decision-making authority for
each National Forest unit as they develop site specific, scientifically sound, proposed standards
and guidelines as directed through this national plan amendment process. For example, old
growth stands on the coast of Oregon tend to need less active management than an old growth
giant sequoia stand located in California. Addressing these plans at each unit level and
considering the unique ecological values of each forest across the country will enable the best
outcomes for the associated standards, guidelines, adaptive management strategy, and
monitoring plan proposed within this Notice of Intent. Importantly, within this nation-wide
framework, decisions about projects—and specifically management of areas that include old
growth—should be made at the National Forest unit level.
• We support the intent of this amendment process to complement the USFS focus on wildfire
rather than hinder it. As stated in the Notice of Intent, “Given the key threat that rapidly
changing wildfire disturbance pose to national forest ecosystems and watersheds and the old
growth forests therein, this proposed action is intended to complement the departments
continued focus on, funding, and implementation of the USFS Wildfire Crisis Strategy.” We
believe this national forest plan amendment process provides an opportunity to increase the
pace and scale to actively manage for healthy forests and complement USFS watershed
restoration work, as well as work outlined in the Wildfire Crisis Strategy and other strategic plans.
• The old growth inventory and analysis of threats completed by the USFS found that mortality
from wildfires is currently the leading threat to mature and old growth forests, followed by
insects and disease. We support management efforts focused on science-based restoration and
wildfire treatments that reduce the risk of uncharacteristic wildfire in mature and old growth as
well as other forest types.
• We support policy and actions that recognize the importance of all forest successional states,
young and old growth, and facilitate forest management to optimize carbon stewardship,
wildlife habitat, and all co-benefits. Natural Range of Variation (NRV) and Historical Range of
Variation (HRV) are useful forest planning tools to help managers understand old growth and
mature forest characteristics and their variation across community types and geographic
regions. Because NRV and HRV are adaptive to variability over time, they can accommodate
forest changes caused by climate, disturbance, and/or management. Using, and continually
improving this existing system will improve our scientific understanding of holistic forest health,
save countless hours, and millions of dollars which are important components to reverse the
declines for Species of Greatest Conservation Need.
• We support the USFS plan to establish a ‘National Old-Growth Monitoring Network’ to inform,
evaluate, and implement the effectiveness of the plan amendments that result from this
process. We encourage the USFS to carefully evaluate how to adaptively manage old growth and
other forest types across dynamic landscapes where stand level replacement events are
increasingly common. Stand replacement disturbance events in old growth can create wildlife
habitat, and efforts should be made through adaptive management to recruit old growth in
different areas of the forest.
• We support the recent advancements and expanded federal authorities and funding for the
USFS to work closely with conservation partners, states and private landowners to restore forest
and watershed health through programs such as Keystone Agreements/Shared Stewardship
Authority, Good Neighbor Authority, the Water Source Protection Program, Permit Streamlining
opportunities in the 2018 Farm Bill as well as opportunities provided through both the Inflation
Reduction Act and the Bipartisan Infrastructure Law. These programs should be utilized and
expanded to help fund and implement Forest Plan goals and the goals of these plan
amendments.
Conclusion:
Thank you for the opportunity for the sporting community to provide these comments in response to
the Forest Service’s proposed national old growth forest plan amendments. We look forward to working
with you to conserve and manage old growth forests and other forest types to enhance ecological
integrity across the National Forest System. Many of the undersigned organizations are additionally
submitting their own comments that reflect their specific knowledge in these areas. We encourage you
to incorporate their input and utilize their expertise through this rulemaking process.
Sincerely,
American Fly-Fishing Trade Association
American Woodcock Society
Angler Action Foundation
Archery Trade Association
Association of Fish and Wildlife Agencies
Backcountry Hunters & Anglers
Boone and Crockett Club
Delta Waterfowl
Fly Fishers International
Izaak Walton League of America
Montana Wildlife Federation
Mule Deer Foundation
National Bobwhite and Grassland Initiative
National Deer Association
National Wild Turkey Federation
National Wildlife Federation
New Mexico Wildlife Federation
New York State Conservation Council
North American Falconers Association
North American Grouse Partnership
North Carolina Wildlife Federation
Orion: The Hunter’s Institute
Pheasants Forever
Pope & Young
Quail Forever
Ruffed Grouse Society
Theodore Roosevelt Conservation Partnership
Trout Unlimited
Union Sportsmen’s Alliance
Wildlife Management Institute
Wildlife Mississippi
Whitetails Unlimited
