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We need you to tell the US Forest Service to implement strong protections for old-growth forests. Please submit a comment urging the Forest Service to strengthen NOGA by clarifying its language and better considering eastern forests. 

The Forest Service is currently seeking public comment on their proposed National Old-Growth Amendment (NOGA). The amendment, which responds to a Biden-Harris Administration executive order mandating stronger protections for old-growth forests, would require all national forest plans across the country to incorporate additional consideration of old-growth forest management needs.

This amendment is an important step towards protecting a shrinking resource, but it needs to be improved. In its current form, NOGA lacks clarity and includes loopholes that could inadvertently worsen current management practices for old-growth forests. Far from meeting its intent of protecting and restoring old-growth forests, NOGA’s current language could allow for inappropriate old-growth harvest.

Comments are due September 20th.

Old-growth forests store large amounts of carbon, clean the air we breathe, provide critical wildlife habitat, maintain and increase biodiversity, filter water, and reduce wildfire risks. The old-growth forests of the Nantahala-Pisgah National Forests are home to several endangered and threatened species, including four species of endangered bats and the imperiled Blue Ridge lineage of green salamanders. Unfortunately, across the nation, old-growth forests are in decline, facing stressors from pests, extreme weather, and commercial logging. NOGA offers an opportunity to better protect and restore old-growth forests, but only if it’s finalized and implemented properly.

Our Concerns:

• As written, NOGA fails to allow passive management as a method of preserving or enhancing old-growth characteristics. Although the Forest Service recognizes that a “hands-off” approach can better serve old-growth forests, especially in areas that are not fire-prone, NOGA currently prescribes only active management options.
  Solution: NOGA should be amended to include passive management as an option for managing old-growth forests.
• Proactive stewardship of old-growth forests has the potential to degrade the old-growth ecosystem. The ambiguity of the draft text could lead to an interpretation that degradation of old-growth forests is ok if that degradation contributes to a project meeting other goals.
  Solution: NOGA should include a non-degradation clause for cases where proactive stewardship methods are employed.
• The exceptions allowed under NOGA are unclear. This lack of clarity could lead to a situation where development within old-growth forests is permitted, so long as there is sufficient old-growth outside of the developed area to make up for some loss within the developed area.
  Solution: The Forest Service should remove the exception that allows for development at an “ecologically appropriate scale” and employ clear, already defined language to improve NOGA’s clarity.
• While old-growth forests decline, threats to old-growth increase. Simply preserving existing old-growth will not be enough to stop the decline, so recruiting mature forests into an old-growth stage is crucial to protecting these ecosystems. As written, NOGA does not offer a clear path by which the Forest Service can identify suitable mature forests and manage them to become old-growth.
  Solution: NOGA should be amended to include a clear plan for recruitment of mature forests into old-growth conditions.
• Lastly, NOGA prescribes a one-size-fits-all approach to forest management. As written, NOGA characterizes threats to old-growth forests uniformly across the country. While fire poses a risk to western forests, eastern old-growth forests are more vulnerable to improper management and commercial logging. The same management actions that benefit fire-prone western forests will not be suitable for moist eastern forests.
  Solution: NOGA should better characterize threats and more specifically prescribe management actions based on forest type and location.

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Encourage Clarity and Public Participation in GAP Restoration Project

In July, the US Forest Service released a draft environmental assessment for the Grandfather, Appalachian, Pisgah (GAP) Restoration Project. The GAP Project aims to reduce wildfire risk, restore fire-adapted ecosystems, and improve forest health over the course of roughly a decade. 

While these goals are commendable, the actions identified to achieve them lack specificity and could lead to inappropriate management of sensitive areas. This lack of site-specific information also obstructs public participation by limiting our ability to fully evaluate the project’s potential environmental impacts.

Please act now and encourage the Forest Service to clarify the GAP Project’s environmental impacts and improve collaboration with the public over the project’s duration.

Comment Deadline: August 12, 2024

• Review the locations affected by the project here: GAP Restoration Project (arcgis.com)
• Review the project website here: Forest Service (usda.gov)

Our Concerns:

• Project duration is not clearly defined: Although the GAP Project is part of the 10-year Pisgah Restoration Initiative, there is no clearly stated project duration for GAP included in the draft environmental assessment. However, the GAP Project includes annual goals for management activities such as timber harvest, prescribed burning, and temporary road construction. Without a clear project duration, the environmental impact of these and other activities is difficult to estimate.
  Recommendation: The Forest Service should state a duration for the GAP Project to help clarify its environmental impacts.

• Locations for logging activities are not clearly defined: A lack of specificity around exact locations for various management activities like burning and harvesting also creates confusion. A stated goal of the GAP Project is to reduce wildfire risk. However, the project identifies logging as a potential management activity in cove forests – moist forests that are not fire-adapted and do not pose any significant wildfire risk. The GAP Project proposes over 10,000 acres of potential timber harvest in cove forests.
  Recommendation: The Forest Service should identify cove forests in the project area and exclude them from logging activities.
• Allowable management activities are poorly defined for areas with saw timber versus areas without saw timber:  In the GAP Project proposal, the Forest Service fails to make a distinction between allowed management activities in areas with sawtimber and areas without sawtimber. Both areas over a total of 29,000 acres allow for temporary road construction, tree removal, and the same harvest methods. All of these activities have the potential to contribute to erosion and habitat disturbance.
  Recommendation: Rather than relying on the presence of sawtimber in an area, the Forest Service should make a distinction based on whether or not trees will be removed from the site – this will help avoid future confusion over which management activities are allowed in a particular site.
• Project proposes to log along the Appalachian Trail, backcountry, and in sensitive ecological areas: Unfortunately, the GAP Project proposes several controversial sites for commercial timber harvest, including 1500 acres along the Appalachian Trail, 1600 acres of backcountry, and areas with unique ecological values. Logging in these areas could damage these values through road construction and the presence of heavy machinery.
  Recommendation: The Forest Service should amend the project so as to not allow commercial timber harvest or road construction along the Appalachian Trail, in Backcountry Management Areas, or in Special Interest Areas.
• The proposal lacks specificity on what kind of management activities will happen and where: The GAP Restoration Project promotes wildfire risk reduction and habitat restoration but lacks clarity on site-specific management activities and timelines. The Forest Service seeks to approve the project before determining where roads will be built, what type of timber harvest will occur where, what the harvest methods will be, which areas will be burned, and before biological and archeological surveys have been completed.
  Recommendation: The Forest Service should provide more information and complete more analysis before approving the GAP Project.

The GAP Restoration Project has the potential to greatly benefit the Pisgah and Nantahala National Forests, but it needs clear guidance for which activities happen where. Unfortunately, as currently proposed, the project could open up sensitive ecological areas, backcountry, and areas along the Appalachian Trail to commercial logging. 

Submit your comments now, and urge the Forest Service to provide more information and complete more analysis before approving the GAP Project.