In late 2023, the U.S. Forest Service (USFS) announced intentions to implement a nationwide rule to preserve old-growth forest conditions across all 128 of its forests’ land management plans. The Rocky Mountain Elk Foundation then expressed concern that such an approach would greatly limit active forest management, thus weakening the ability to enhance wildlife habitat, and submitted official public comments along those lines.
In response to those and comments by others, USFS then made amendments to its original proposal. Below is a synopsis of RMEF’s most recent comments to the amendments:
- RMEF previously expressed concern with the purpose and need for this rulemaking since USFS recognized that practices and policies are already incorporated in its planning and NEPA to achieve components of what is outlined in the proposed amendment. The Draft EIS reported 94 percent of forest plans have old-growth plan conservation components.
- RMEF is concerned how this rulemaking compounds and interacts with the overwhelming number of laws, regulations, guidelines and case law that USFS line officers must already navigate. Forest stewardship is already impeded by complex and often redundant bureaucratic hurdles that unnecessarily delay projects and expose USFS to litigation.
- RMEF believes management directives are best determined at the unit planning level and opposes a national land management plan amendment process that necessarily precludes local involvement and geographic nuances.
- Overall, RMEF finds the proposed amendment components overly prescriptive to be applied to all forest plans and anticipates ambiguity will perpetuate inconsistent management approaches across the National Forest System. RMEF considers the exposure to litigation and constraints on projects an unacceptable cost to bear for an indiscernible benefit.
- RMEF recommends directing individual planning units found to be lacking a definition of “old growth” to develop their own, as a regional definition would not sufficiently account for the diverse ecological systems represented across USFS regions.
- RMEF suggests USFS retains only a high-level framework, deferring standards and guidelines to the forest-level. RMEF proposes the development and analysis of a new action alternative that would achieve the purpose and need through increased active management within old growth through the establishment of quantitative treatment targets, streamlining of processes and removal of bureaucratic hurdles.
As long-time partners, RMEF and USFS entered 2024 having completed 3,715 lifetime conservation and hunting heritage projects with a combined value of over $388.6 million. Those projects conserved or enhanced more than 3,861,508 acres of habitat and opened or improved public access to more than 363,370 acres.
(Photo credit: Rocky Mountain Elk Foundation)