FFRC Comments on Fed. Reg. 42493-42494 Vol. 87, No. 135 July 15, 2022

It is worth noting that in addition to the more than 56 million acres of National Forest that USDA has identified as being more than 100 years old, the National Park Service has, at a minimum, 4.8 million acres of old-growth forests on which commercial management is prohibitedⁱⁱ. This 1991 estimate for the National Park Service is substantially outdated and should be updated. Every forested acre in the National Park System will eventually “mature,” and cutting trees on National Park land is mostly prohibited, except to protect life and property. Presumably, absent natural disturbances, all forested acres within the National Park System will attain “old-growth” or at least “maturity.”

Any such inventory must also recognize that the Forest Service and Bureau of Land Management already host significant areas reserved from most active timber management. 7.7 Million Acres of National Forests are in National Monumentsⁱⁱⁱ. 17.6 Million Acres of NFS lands are in Wild & Scenic River Corridors. 36.6 Million Acres of NFS lands are in Designated Wilderness Areas. 58.2 Million Acres of NFS lands are in Inventoried Roadless Areas. While theoretically some non-commercial fuels reduction work could take place in an Inventoried Roadless Area, for all practical purposes they are off limits to commercial timber harvest, meaning, if the trees in those areas are not killed by wildfires, insects, or other disturbances, they will all achieve “old-growth” status eventually. The total area of NFS lands in these restricted land use categories is three times larger than the 40 Million Acres of NFS lands designated as “suited for timber production,” and is 27 Million Acres larger than the entire National Park System.

Similarly, forest management is extremely limited on the 85 Million Acre National Wildlife Refuge System. The National Wildlife Refuge Act states that “No person shall disturb, injure, cut, burn, destroy, or possess any real property of the United States” (trees are considered real property) on a National Wildlife Refuge^iv. Most forested lands on National Wildlife Refuges, therefore, will also grow to the maximum extent possible, subject to the natural limitations of each site and natural disturbances.

If old-growth is defined as forests that are simply allowed to grow with no management, there are at least 60.8 million acres of old-growth existent on National Forests and National Parks alone. There are an additional 14 million acres of land in State park systems, where, generally speaking, timber management is either prohibited or discouraged^v. If even half these State park areas are forested, that’s an additional 7 million acres that will not be

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managed and will eventually achieve “old-growth” status, however defined. At 67 million acres, this is an area larger than all but seven States and is 42 times larger than the State of Delaware.

Various advocates, on a local level, have suggested criteria such as age of trees, size, presence of down and decaying trees, define “old-growth.” We believe a universal definition, or even a “universal definition framework” inherently cannot be based on the best available science, limits the ability of the Forest Service to manage for specific species, and will lead to less old- growth on the landscape over time. Forests will mature, decay, and, in many cases, burn. Current trends suggest that many types of forest disturbance are becoming more common, from large fires to wind events. Without active management, stands experiencing stand-replacing disturbances will not mature into “old-growth” stands, and with no effort to control brush after such events, they may not return as forests at all.

In order to conserve forests of any successional stage, the ability to engage in adaptive management is critical. Information about typical successional processes and stages may help inform management, but it does not make it possible to stop forest succession or end disturbance regimes which will “reset forest to stand initiation phases, regardless of human management.