Concern over old-growth forest plan

Crook County is calling for the U.S. Forest Service (USFS) to rethink its plans to amend every national forest land management in the nation to create one overall strategy for managing old-growth forests.

In a comment letter signed by the county commissioners last week, the county criticizes the one-size-fits-all approach and the USFS’s failure to include local governments in the process.

“Upon reading through it, it will affect all the National Forests in Wyoming, which includes the Black Hills; it will also include Thunder Basin National Grasslands,” said Dru Palmer, consultant for the county, at a special meeting on Thursday.

According to the USFS, this mature and old-growth forest initiative is part of an “overarching climate-informed strategy to change the course of increased wildfires, combat climate-related impacts and help retain carbon.”

Mature and old-growth forests, says the USFS, offer “biological diversity, carbon sequestration, wildlife and fisheries habitat, recreation, soil productivity, water quality and aesthetic beauty”, as well as reflecting diverse tribal, spiritual and cultural values, but are threatened by climate change.

The U.S. Department of Agriculture (USDS) published a Notice of Intent in the Federal Register on December 19 to prepare an Environmental Impact Statement (EIS) to amend all 128 national forest land management plans “to include consistent direction to manage, conserve and steward old-growth forest conditions.”

An initial threat assessment report prepared by USFS and the Bureau of Land Management (BLM) states that wildfire exacerbated by climate change and fire exclusion is the leading threat to mature and old-growth forests, followed by insects and disease.

It found that two thirds of mature and just over half of old-growth forests are vulnerable to these threats.

However, the Crook County Commission is concerned about the impact of this plan amendment on the socioeconomics, custom and culture of the county.

The county’s comment letter was prepared by Palmer in consultation with the Wyoming County Commissioners Association, the Governor’s Office and Wyoming State Forestry. It notes that the county’s economic viability is highly dependent on federally managed lands for energy development, livestock grazing, wildlife, tourism and recreation.

Palmer stated that the letter also addresses three specific concerns.

“One, none of the counties or local governments were asked to participate as cooperating agencies in this EIS,” she said.

In the letter, the county comments that this fails to reflect the overall directive of the National Environmental Policy Act (NEPA), the Councils on Environmental Quality regulations for NEPA and the 2012 Planning Rule.

“It is clear that the USFS is expected to coordinate, cooperate and consult with local governments on NEPA documents affecting the county’s jurisdiction,” states the letter, before officially requesting cooperating agency status.

“Two, it’s a top-down approach, so it’s really a one-size-fits-all approach, which doesn’t work for forest planning, I think we all understand that,” Palmer continued.

“We prefer decisions that are made closest to the forest level.”

In the letter, the commission points out that a localized approach “recognizes the vast differences between our national forests and the communities that live in and around them,” and that this amendment process is being dictated “as far from local forests as possible”.

“We’re going through a plan revision right now,” said Palmer, referring to the Black Hills National Forest Management Plan. “It makes a lot of sense to just do this while we’re going through the Black Hills and not have another national EIS amend the plan before we’ve had that opportunity.”

Thirdly, said Palmer, “They need to be consistent with your land use plan. We identified several areas in which they need to be consistent.”

With these criticisms in mind, the commission’s letter asks the USFS to rewind the process and begin again with the participation of local governments.

“We request a complete withdrawal to go back to the drawing board, reach out to counties, allow the process to work locally, work with our local forests,” Palmer said.

Commissioner Fred Devish praised the letter for the collaboration with other agencies and for capturing the point that, “They’re trying to do whatever they want without anybody else’s input.”

However, he noted that it’s difficult for local governments to be heard when it comes to top-down national plans.

Commissioners Bob Latham and Kelly Dennis agreed that the letter lays out the county’s concerns accurately.

Speaking from his long-time experience as a firefighter, Devish also spoke to the potential overall impact on preventing wildfire.

“I think treating old growth different to the rest of the forests is self-defeating anyway, because if you save all the old growth, guess what’s going to burn first,” he said. “They’re swimming upstream there, I think.”

Palmer informed the commission that she has an upcoming meeting in Washington, D.C. with the deputy forest chief and will be discussing the Black Hills and old growth.

“I look forward to providing you those updates when we get back,” she said.