New Mexico Wild has submitted comments on the U.S. Forest Service’s Draft Environmental Impact Statement (DEIS) for Amendments to Land Management Plans to Address Old-Growth Forests Across the National Forest System. While we support the Forest Service’s efforts to develop a national policy to protect old-growth forests, as directed by Executive Order 14072, we have concerns about certain aspects of the draft plan.
Our primary concerns revolve around the Forest Service’s preferred Alternative 2, which we believe fails to meet the intent of the Executive Order and the stated purpose of the nationwide forest plan amendment. Specifically, Alternative 2 retains overly broad discretion to log and commercially sell old-growth trees, both within and outside old-growth stands or forests.
We urge the Forest Service to strengthen the draft plan by adopting a modified version of Alternative 3 that would:
- Prohibit the commercial exchange of old-growth trees from all forest types
- Prohibit non-commercial logging of old-growth trees, with narrow exceptions for public safety, traditional/cultural uses, and legal compliance
- Distinguish between frequent-fire and infrequent-fire old-growth forests in management approaches
Additionally, we call on the Forest Service to include standards to protect mature trees and forests, which are absent from all current alternatives. Mature forests in New Mexico and elsewhere are critical for carbon storage, biodiversity, and ecosystem health. They represent the old growth of tomorrow if allowed to flourish.
While commending the Forest Service for recognizing the biological and cultural importance of old-growth forests, New Mexico Wild calls for these key improvements to ensure the final National Old Growth Amendment fully upholds the conservation vision outlined in Executive Order 14072 and provides meaningful protections for our nation’s oldest trees and forests.
