Elk NetworkRMEF Expresses Concern about USFS Old Growth Policy

General | February 8, 2024

In December 2023, the U.S. Forest Service (USFS) announced a proposal to implement a nationwide rule to preserve old-growth forest conditions. The Rocky Mountain Elk Foundation raised multiple issues about the USFS intent to amend all 128 of its forests’ land management plans that would greatly limit active forest management.  

RMEF supports efforts by the USFS to improve consistency in forest planning and practices for the benefit of elk, other wildlife species, conservation, public access and multiple uses including hunting. However, RMEF finds the proposed plan components overly prescriptive to be applied to all 128 forest plans. RMEF maintains opposition to a national definition or policy for mature and old growth forests, as it would not sufficiently account for the diverse ecological systems represented across USFS-administered lands. In addition, several components include actions that are either not possible to implement or are not measurable, thus leaving the forests open to unnecessary litigation.  

RMEF’s comment letter specifically asks the USFS to:  

  • Redact the notice of intent to prepare an environmental impact assessment until the risk analysis and all other critical documents are available to conduct a proper public review 
  • Explicitly identify gaps in existing policy and practices that fail to address the risk/threats 
  • Clarify how the Climate Risk Viewer data will or will not be used to set ‘current conditions’ or help establish other plan components 
  • Clarify the intent of proposed plan components in restricting ‘tree cutting’ or other active management actions. 
  • Improve proposed plan components, as suggested, so they are achievable across various forest types 
  • Remove suggested plan components to help forests reach desired conditions and avoid unnecessary litigation 

The nationwide public comment period closed on February 2, 2024. RMEF will continue tracking this issue and will work with the USFS to improve the proposed action.  

Since its inception in 1984, RMEF conserved or enhanced more than 8.9 million acres of North America’s most vital habitat for elk and other wildlife. In partnership with the USFS, RMEF so far conserved or enhanced more than 3.7 million acres across USFS-administered lands and opened or improved public access to more than 363,000 acres. Together, the combined value of RMEF-USFS cooperative efforts exceeds $369 million. 

(Photo credit: Rocky Mountain Elk Foundation)