Here We Go Again: The Mature and Old Growth Federal Register Notice, Public Comment and Webinar

It’s Friday to talk about MOG (mature and old growth forests) and you’re thinking about white oak for casks.

Here are the questions in the FS/BLM comment request, you can find the Federal Register notice here.

Input requested. USDA’s Forest Service and Bureau of Land Management, DOI, are seeking input to develop a federal definition for old-growth and mature forests.
Land, and are specifically asking for input on the following questions.

• What criteria are needed for a universal definitional framework that promotes the conservation of mature and old-growth forests and enables planning and adaptation?

• What are the characteristics of old-growth and mature forests included in the interpretive framework?

• How can definition reflect changes based on forest type/composition, climate, spatial productivity and geographic range disturbance and diversity?

• How can the definition be sustainable but accommodate and reflect changes in climate and forest composition?

• If so, should forest characteristics exclude definition?
More information about this effort, including a link to the recorded webinar, can be found at


During our discussions about special projects, I found it interesting to talk about the “Maturity and Old Growth” or MOG for short effort. In 2012, the Forest Service decided that it would administer NRV (yes, subject to all sorts of wordy parameters). (This hasn’t found its way to court yet and probably won’t) so Forests has made all sorts of efforts to analyze what NRV might look like (a 2001 planning regulation, as I call it, “a full employment program for historic plant ecologists”). It is more or less known what Native Americans did with fire at different times. However, here we are with forests trying to manage forests for NRV (and various wildlife species) and some projects designed for those purposes have been attacked for cutting down “mature” trees. If the target is now “mature forest conservation”, is NRV the ultimate goal of the analysis? Could everyone skip that side trip? Are open (and formerly fire-dependent) areas for species (call it oaks or western white pine, not to mention wildlife) now less important than “dry forest preserves”?

This is my take. Some Ingos do not support the cutting down of trees (“cutting down”) for philosophical reasons. For a while, breeds (such as spotted owls) were a good horse to hit the goal. Now they are riding on the “carbon” horse. However, the carbon horse has problems.

For example, as we mentioned, old trees die. Even “mature” trees, insects, fire, etc. Many people, including me, have said this. There is still a scientific study that says “trees can burn or die in California and not sequester carbon.” I put my carbon money directly into air capture technologies, or if it has to be trees, then into carbon recycling and meeting other objectives.

Maybe trees and forests are going to die from climate change, so there’s that. Climate change may be killing trees and forests. At least today he is the landlord of this wapo story. “Big trees can’t survive climate change” Of course, these particular trees are one of the most difficult areas to start with trees. Time for a field trip to your local Bristlecon. But if we think climate change will kill our current forests, maybe that’s not the best carbon bet.

I’m sure all the smart people in the Forest Service will realize something meaningful when they give it. More interesting is how the politics play out in USDA, which is a more common-sense perspective, a more political DOI—perhaps more visible to key ENGO’s and perhaps more monitored by people in climate. The White House. And the question of what an executive order can do in comparison to the MUSYA and even the planning regulations. And, of course, time limits for analysis, and rulemaking (?) and .. choices. Should be fun to watch!

Sometime in the 90’s I wrote a song parody about the Old Growth issue for an old growth guy (can’t remember the name) retirement party.. I think it was an issue in HRFA. It was to the tune of “Maria” that painted the wagon.

We found a place on the west exit
In large and thick and old trees
We will keep a line around the area so that there are no sold trees.

Reserves.. Reserves.. We call those places.. Reserves.

But old trees die and fall
And we have preconceptions.
But we do well, we move the lines or change the meanings.

If anyone is interested in the history of old growth analysis from the 90’s, you can google “old growth forest service 1990” and find some state documents.

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