Amending the Northwest Forest Plan

Update (December 2024): The draft Environmental Impact Statement for this amendment was released on Nov. 15, 2024 and comments will be accepted through March 17, 2025. You can read the DEIS here and submit your comments on the DEIS here.

The U.S. Forest Service is amending the Northwest Forest Plan for the first time in 30 years. Here’s what you need to know to get involved and make your voice heard.

The U.S. Forest Service (USFS) has released a Notice of Intent (NOI) to amend the Northwest Forest Plan for the first time in 30 years! The first step in this process is a comment period on the NOI that ends on February 2nd

Below, you’ll find an outline of the NOI, sample language and suggestions you can use to get started on writing your own comments on the NOI, and numerous links to additional resources and other ways to get involved.

Need to Know

  • Read the full NOI here. 
  • Public comments on the NOI can be submitted here and are due by February 2nd (note: this deadline was extended from the original 1/29 deadline stated in the NOI).
  • A draft environmental impact statement (EIS) is expected in June 2024 and will be accompanied by a 90-day comment period. 
  • The final EIS is expected to be available for review in October 2024. 
  • Comments that are comprehensive and technical are most effective, but even just giving the Forest Service a “temperature check” on how you feel about the issues raised in the NOI can be helpful to policy makers.
  • In order to object to the final EIS, you must have submitted comments during one of the prior comment periods. 

Background and Key Takeaways from the NOI 

The Northwest Forest Plan (NWFP) was adopted in 1994 and initiated one of the most sweeping changes to forest management anywhere in the world. The NWFP amended the forest plans of all National Forests within the range of the northern spotted owl (western Washington, Oregon, and NW California) and established new guidelines that prioritized conservation of old-growth forests and the species associated with them. These protections were intended to be balanced with the Forest Service’s mandate to maintain a sustainable timber supply. 

Now, 30 years after its adoption, the Forest Service (FS) intends to amend parts of the plan to respond to changed conditions and new information relevant to NWFP areas. The NOI details how the proposed amendment will address issues in five topic areas, listed below with my commentary:  

  • Wildfire resilience
    • Growing scientific understanding suggests fire was much more common on the landscape (prior to Euro-American settlement) than was previously thought. This is, of course, something that people indigenous to the region have known for thousands of years.  
    • For the last 100+ years, the Forest Service has had a strict policy of fire suppression. The lack of fire, combined with impacts from logging and road building, has led to drastic changes in forest coverage, structure, and fire timing and behavior across many portions of the landscape. The FS now wants to see more “active management” in these forests to improve fire resiliency. 
    • “Active management” comes in many different forms, from activities like commercial logging to non-commercial activities like thinning of small diameter trees, mastication, and prescribed fire. If you follow other conservation organizations across the northwest, you’ve probably seen concerns over vague language as it relates to active management in dry forest ecosystems. The science of fire and its role in forests (often called “disturbance ecology”) can and has been misunderstood and misused by the Forest Service, leading to bad project design and decision making (remember Crystal Clear anyone?).  
    • Across many parts of the landscape, we need to take action to return beneficial fire to the ecosystem (fighting fire with fire!), but the nuance of when, where, and how can be difficult to unravel. Luckily Bark will continue to groundtruth timber projects and ensure the FS makes good decisions!  
  • Climate change adaptation
    • Climate change and its impacts were never explicitly considered during the development of the NWFP 30 years ago.
    • As the climate changes, shifts in forest type, forest coverage, and species composition are expected, but neither the NWFP nor the Mt. Hood Forest plan provide guidance for how the Agency should adapt.
    • The critical role Northwest forests play in carbon capture and storage is only mentioned twice in the NOI.
  • Conservation of old-growth ecosystems and related biodiversity
    • The late-successional reserve (LSR) strategy protected much of the remaining old-growth forests, but old-growth forests outside these reserves have little protection. This lack of protection and guidance has led to poor management decisions and consistent legal challenges brought on by environmental organizations across the region.  
    • Again, the Forest Service is arguing that “active management” is necessary to restore and conserve mature and old-growth forests in dry, fire prone ecosystems.  
  • Tribal inclusion 
    • ​​​​​​The forests within the NWFP are the ancestral homelands of diverse and varied Indigenous tribes and nations. Thousands of years of reliance on and connection to these ecosystems shaped these cultures. In turn, these cultures shaped these ecosystems.  
    • The creation of the NWFP followed the status quo of the time – little to no thought was given to include the knowledge and perspectives of Tribal Nations. In the years since, the primary authors of the plan have openly regretted this omission and have advocated for change. Bark supports this and is actively working toward a future where Indigenous communities decide what happens on their ancestral homelands.  
    • An important point about the NOI’s use of the terms “co-stewardship” and “co-management.” Under co-stewardship agreements, the FS consults with tribes during project design and planning, but the FS remains the sole authority and decision maker. With co-management, the Tribes and FS are equal partners and both have authority when making decisions. Guess which one the FS prefers…(yep, co-stewardship, which allows them to retain sole authority). 
    • According to the Fourth Assessment of Indian Forests and Forest Management in the United States, 82% of tribal members surveyed wanted more tribal involvement in the management of federal lands.  
  • Sustainble communities
    • Although logging rates before the NWFP were catastrophic and unsustainable, the adoption of the NWFP was damaging to many rural communities with economies built on harvest quantities promised by the FS. While the economic downturn in these communities cannot be solely blamed on the NWFP, it did play a part, and economic support promised to these communities by the U.S. government never came through. 
    • Bark supports rural communities with ties to Mt. Hood and advocates for a skilled and diverse workforce geared toward activities like recreation and restoration.  

The Forest Service Wants Your Feedback!

To help you get started on writing your own comments to this NOI to amend the NWFP, we’ve prepared a document with sample language and suggestions to ensure your comment is as effective as possible. We have elected not to provide a boilerplate letter, as the Forest Service considers unique comments to be more useful.