National Old-Growth Amendment Comment Workshop
September 17
2024
Alison Gallensky
Rocky Mountain Wild
Ellen Montgomery
Environment Colorado
Rocky Smith
Forest Management Consultant
India West
Wild Connections
Topics
Welcome and Introductions
Mature and Old Growth Forests
National Old Growth Amendment
Engaging Effectively
Conclusion and Farewell
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Introductions
Alison Gallensky
Rocky Mountain Wild
Rocky Smith
Forest Management Consultant
Ellen Montgomery
Environment Colorado
India West
Wild Connections
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Upcoming Events
Community Science Projects
Colorado Pika Project: https://pikapartners.org/
Colorado Bat Watch: https://coloradobatwatch.org/
11/19 Wild and Scenic Film Festival
Denver and Virtual
https://rockymountainwild.org/wsff
9/28 National Public Lands Day North Tarryall Creek Monitoring
10/5 Volunteer Seeding Restoration Project
Puma Hills Roadless Area
10/12 Climate Education Hike at Beaver Creek
https://wildconnections.org/
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Mature and Old Growth Forests
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National Old-Growth Amendment
Overview
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National Old-Growth Amendment Overview
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National Environmental Policy Act (NEPA) Process :
National Old-Growth Amendment Process
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This graphic shows how forest plan components relate to each other.
Standards set firm management parameters, while objectives provide more flexible guidance. Both help to achieve goals, and ultimately desired future conditions.
National Forest Planning Terminology
From A Citizens’ Guide to National Forest Planning, available from https://www.fs.usda.gov/planningrule
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How to Engage
National Old-Growth Amendment
In Depth
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Old-Growth Forest Definition
Old-growth forests are dynamic systems distinguished by old trees and related structural attributes. Old-growth encompasses the later stages of stand development that typically differ from earlier stages in a variety of characteristics, which may include tree size, accumulations of large dead woody material, number of canopy layers, species composition, and ecosystem function
DEIS page S-2
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Forest Service View of Risks
[Threats analysis report] analysis found that mortality from wildfires is currently the leading threat to mature and old-growth forests, followed by insects and disease. The analysis also found that tree cutting is now a relatively minor threat compared to climate amplified disturbances such as wildfire, insects, and disease. However, past management practices, including timber harvest and fire suppression, contributed to current vulnerabilities in the distribution, abundance, and resilience of old-growth forest characteristics.
DEIS page S-4 emphasis added
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Alternatives
Alternative 1 - No Action Alternative (baseline)
Alternative 2 – Modified Proposed Action (Preferred Alternative)
Standard 3 Proactive stewardship in old-growth forests shall not be for the purpose of timber production as defined in 36 CFR 219.19.
Alternative 3 – More Restrictive Standards for Old-Growth
Standard 3 would be updated to read as: Proactive stewardship in old-growth forests shall not result in commercial timber harvest.
Alternative 4 – Less Restrictive Standards for Old-Growth
DEIS pages S-9 & S-10 & 32
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Standard 2.a Vegetation Management
Where conditions meet the definitions and associated criteria of old-growth forest, vegetation management may only be for the purpose of proactive stewardship. For the purposes of this standard, the term “vegetation management” includes – but is not limited to – prescribed fire, timber harvest, and other mechanical/non-mechanical treatments used to achieve specific silviculture or other management objectives (e.g. hazardous fuel reduction, wildlife habitat improvement). For the purposes of this standard, the term “proactive stewardship” refers to vegetation management that promotes the quality, composition, structure, pattern, or ecological processes necessary for old-growth forests to be resilient and adaptable to stressors and likely future environments.
DEIS page 29 emphasis added
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Objective 1 Adaptive Strategy
Within 2 years of the old-growth amendment record of decision, in consultation with Tribes and Alaska Native Corporations and in collaboration with interested States, local governments, industry and non-governmental partners, and public stakeholders, create or adopt an Adaptive Strategy for Old-Growth Forest Conservation based on geographically relevant data and information for the purpose of furthering old-growth forest desired conditions.
DEIS page 26
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Objective 2 Proactive Stewardship
Within one year of completing the Adaptive Strategy for Old-Growth Forest Conservation Strategy, integrate priorities identified in the Strategy into the unit’s outyear program of work and initiate at least three proactive stewardship projects/activities in the planning area to contribute to the achievement of old-growth forest desired conditions.
DEIS page 27
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Objective 3 Proactive Stewardship
Within two years of completing the Adaptive Strategy for Old-Growth Forest Conservation Strategy, initiate at least one co-stewardship project with interested Tribes for the purpose of proactive stewardship.
DEIS page 27
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Guideline 1 Future Old-Growth
In areas that have been identified in the Adaptive Strategy for Old-Growth Forest Conservation as compatible with and prioritized for the development of future old-growth forest, vegetation management projects should be for the purpose of developing those conditions.
DEIS page 33
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Questions & Answers
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Effective Engagement
The Forest Service Needs to Hear From You
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How to Engage
Comments Due Friday, September 20
For a simple way to be counted go to:
https://www.climate-forests.org/take-action
Email Rocky Smith to sign on to his comments 2rockwsmith@gmail.com
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Active Engagement
Forest Service Comment Portal:
https://cara.fs2c.usda.gov/Public//CommentInput?Project=65356
Submit comments by Thursday, September 19
Talking points coming up and at
https://rockymountainwild.org/protect-climate-forests
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Effective Comments
Start early. Don’t miss the deadline.
Write a draft before submitting.
Be on topic. Overarching platitudes fall on deaf ears.
Be concise. Help the agency get your point, don’t hide it from them.
Be respectful. Someone has to read all of these comments.
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Talking Points (1 of 3)
Identifying existing and future old growth stands must be a standard.
Existing and developing old growth stands should not be manipulated unless there is a strong reason to do so
All old growth and most developing old growth stands must be unsuitable for timber production
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Talking Points (2 of 3)
No treatments should be done in existing and future old growth areas with historically infrequent fire except:
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Talking Points (3 of 3)
Fuel reduction should only be done in old growth areas with historically frequent fire and where conditions deviate significantly from historical conditions. These treatments should be used to help restore natural conditions.
Any treatment in old growth must maintain old growth character to the maximum extent possible.
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Conclusions and Discussion
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THANK YOU!
Alison Gallensky
Rocky Mountain Wild
alison@rockymountainwild.org
rockymountainwild.org
https://rockymountainwild.org/protect-climate-forests
Rocky Smith
Forest Management Consultant
2rockwsmith@gmail.com
Ellen Montgomery
Environment Colorado
lmontgomery@
environmentamerica.org
https://environmentamerica.org/colorado/
India West
Wild Connections
india@wildconnections.org
wildconnections.org