In the final weeks of 2023, two far-reaching policy processes were unveiled by the U.S. Forest Service that will affect public forest lands across Oregon. Public comment periods are open on both until Feb. 2.

The Forest Service proposes to amend the Northwest Forest Plan, which covers more than 24 million acres of national forestlands in Oregon, Washington and northern California. 

The Northwest Forest Plan (NWFP), a compromise enacted in 1994, aimed to protect and restore old-growth forests and healthy stream habitat for threatened species while still facilitating logging on public lands. The proposed amendment process focuses on addressing changed conditions around wildfire risk, climate change, old-growth forests, tribal engagement and rural communities and workforce.

At the same time, the Biden administration has announced a new plan to protect old-growth forests by amending forest plans nationwide. This proposal comes in response to Biden’s 2022 Executive Order on conserving mature and old-growth forests as a climate solution and last year’s proposed rulemaking that garnered 500,000 public comments in support of such protections.

Forest Plans

Forest plans, required under federal law for National Forests managed by the U.S. Forest Service, may not be foremost on the mind of most people out enjoying hiking, camping or rafting on public lands; however, these plans define and affect the uses — from recreation to logging — allowed in different areas of National Forests as well as the wildlife habitat, water quality and ecosystems found there. In Oregon, most forest plans were completed in 1989-90. Plans were intended to be revised every 15 years or when conditions significantly change.  

While an official plan revision has not been done for any of Oregon’s national forests to date, a major amendment occurred with the Northwest Forest Plan in the early 1990s. Decades of logging in national forests led to old-growth forest- and stream-dependent species being listed under the Endangered Species Act (the well-known northern spotted owl, as well as marbled murrelets and Pacific salmon species). 

The NWFP was developed as an attempt to strike a balance between logging and protecting habitat these species needed to survive. The plan defined areas for protecting and restoring old-growth habitat, set aside streamside areas to protect water quality and salmon habitat, set strong standards for restoring forests and watersheds that were previously logged and set targets for ongoing timber harvest. 

Conservationists largely tout the success of the NWFP in restoring some of the damage done by decades of logging, protecting drinking water, keeping other wildlife off the endangered species list, restoring salmon runs, stabilizing the climate, and improving quality of life, which is the foundation of the growing regional economy. 

But the compromise nature of the plan also meant that logging of mature and old-growth forests is still allowed in some areas, including ecologically critical watersheds and habitats. The timber industry has argued the Northwest Forest Plan has restricted its access to extraction on public lands and that commercial logging should be ramped back up toward previous levels, while conceding that protecting some “exceptionally old” trees may be warranted.

Amending the Northwest Forest Plan

Efforts to weaken the conservation measures of the NWFP were initiated before the ink was even dry on the compromise. Eventually, opponents of the plan succeeded, and in 2016, the Bureau of Land Management removed 2 million acres from the conservation framework of the NWFP, shrinking streamside reserves to just half their previous size and allowing more intense logging even in areas reserved for habitat.

In 2015, the Forest Service began considering if and how to revise the NWFP. The USFS held public listening sessions and completed an assessment of the plan and a science synthesis to inform the revision, but the effort was then paused during the Trump administration. 

In 2023, a federal advisory committee was convened to inform potential amendments to forest plans in western Oregon, western Washington and northwest California, and in December, the USFS released official notice with an amendment proposal. Further analysis and another comment period will follow later this year. In the meantime, the federal advisory committee continues to meet periodically — including over three days in Eugene coming up from Jan. 30 through Feb. 1.

Citing “changed ecological and social conditions” and “substantial new information relevant” regarding recovery plans and critical habitat for spotted owls and executive orders around forests and climate change, the proposal focuses on change needed in five topic areas, but without a clear description of what the changes might entail: 

• Improving fire resistance and resilience across the NWFP planning area
• Strengthening the capacity of NWFP ecosystems to adapt to the ongoing effects of climate change
• Improving conservation and recruitment of mature and old-growth forest conditions, ensuring adequate habitat for species dependent upon mature and old growth ecosystems and supporting regional biodiversity
• Incorporating Indigenous knowledge into planning, project design, and implementation to achieve forest management goals and meet the agency’s general trust responsibilities
• Providing a predictable supply of timber and non-timber products, and other economic opportunities to support the long-term sustainability of communities located proximate to National Forest System lands and economically connected to forest resources.

One notable change is the inclusion of additional national forests in the Klamath and eastern Cascade regions that tend to have dryer and more fire-dependent forest ecosystems than those in the original NWFP. 

Conservation groups analyzing the proposal are concerned that the vague language of the proposed amendment leaves room for logging of mature and old-growth forests under the guise of fuel reduction, and the inclusion of more fire-dependent forests in the amendment validates those suspicions. They are also concerned that the proposal doesn’t do enough to prioritize carbon storage and sequestration to address climate change. Other concerns not addressed in the proposed amendment include the ramifications of the BLM’s exit from the NWFP in 2016 and the accelerated timeline of the proposed amendment process that could undermine the incorporation of Indigenous Knowledge and tribal involvement.

Old-growth Forest Plan Amendment

Also in December, the Biden administration announced a proposed nationwide forest plan amendment to advance protections for the remaining old-growth trees in all of the country’s National Forests. 

The proposal, and amendment when adopted, would add new restrictions on old-growth logging and is a step toward fulfilling President Biden’s Earth Day 2022 Executive Order 14072, which directed the Forest Service and Bureau of Land Management to develop policies to protect mature and old growth forests on federal lands as a natural carbon and climate solution. 

There has never before been a proposal to end commercial logging of old-growth on all national forests.

In a statement released last month, members of the Climate Forests Campaign, a coalition of more than 120 organizations working to protect mature and old-growth trees and forests on federal land, welcomed the announcement as an important step forward while urging the Forest Service to pursue steps to protect mature trees. Both old-growth and mature forests are essential to removing climate-warming carbon pollution from the air and storing it, safeguarding wildlife and providing clean drinking water for our communities. 

In the inventory and definitions of these types of forests released in April 2023 by the Forest Service, mature forests were defined as “the stage of forest development immediately before old growth.” Scientists warn that protecting these mature forests is essential for providing future old growth, which is currently severely depleted nation-wide. 

In addition to the critique of excluding mature forests from the amendment, conservationists also noted the loopholes for continued old-growth logging in the proposal. 

This national amendment could impact the proposed Northwest Forest Plan change as well, taking precedence over any guidance that might allow ongoing old-growth logging. The amendment would not, however, apply to lands managed by the Bureau of Land Management, where several Oregon timber sale projects in mature and old-growth forests are in progress. The BLM is due out with a draft Conservation Rule this spring, which may also address the issue of these forests.  

This scoping periods open now are an opportunity for the public to weigh in on the proposed amendments. Comments on both are due on or before February 2, 2024. 

More information and links for submitting comments, upcoming virtual information sessions, and the Federal Advisory Committee for the Northwest Forest Plan amendment can be found here.

Information on the nation-wide old-growth forest plan amendment can be found here or go to the Forest Service’s comment page here.

Chandra LeGue is senior conservation advocate with Oregon Wild.

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