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The Healthy Forests Initiative and Healthy Forests Restoration Act
Interim Field Guide

Old-Growth and Large-Tree Retention

The old-growth and large-tree retention provisions of the HFRA only apply to “covered” projects. Covered projects, as defined in Section 102(e)(1)(B), include all projects authorized under the HFRA on NFS and BLM lands, except those carried out under Section 102(a)(4).

Old Growth

Section 102(e)(2) provides that the USDA Forest Service and DOI BLM, when carrying out covered projects using HFRA authority, are to "fully maintain, or contribute toward the restoration of, the structure and composition of old-growth stands according to the pre-fire suppression old-growth conditions characteristic of the forest type, taking into account the contribution of the stand to landscape fire adaptation and watershed health, and retaining the large trees contributing to old-growth structure."

Section 102(e)(3) provides that old-growth direction in resource management plans established on or after December 15, 1993, (so-called “newer plan direction”) is sufficient to meet the requirements of Section 102(e)(2) and will be used by agencies carrying out projects under the HFRA. December 15, 1993, refers to the date old-growth direction was adopted into the plan, which may have been after the date the current plan was originally adopted (if the plan was amended to include updated old-growth direction). For example, old-growth direction would not need to be revised in plans encompassed by the Northwest Forest Plan Record of Decision, because these plans contain old-growth standards adopted after December 15, 1993.

Any amendments or revisions to management direction for old growth made after December 3, 2003, must be consistent with Section 102(e)(2) for the purpose of carrying out “covered” projects in old-growth stands.

Resource management plan direction governing old-growth resources can take a variety of forms. For example, plans may refer to old growth or may use related terms that refer to late-successional forest conditions. In addition to the term old growth, plans may use terms such as ecological old growth, old forests, late-successional forests or reserves, late-successional habitat or vegetation, climax forest or vegetation, overmature forests, or a mature and overmature timber inventory stratum or habitat class. For the purposes of implementing the HFRA, the use of terms that are equivalent to old growth, such as those above, should be considered to be the same as old growth as used in the HFRA. In this Field Guide, the term old growth is intended to refer to the various terms that are equivalent to old growth in resource management plans.

The direction for old-growth stands contained in newer resource management plans (those issued after December 15, 1993) should guide the development of projects carried out under the HFRA within these stands. When the resource management plan is revised or amended, the direction for old-growth stands in the parent plan should be reviewed with regard to covered projects if resource managers want to continue using HFRA authorities.

To comply with Section 102(e), field units must have a process in place to identify old-growth stands or their equivalent before they use HFRA authorities. The HFRA does not mandate particular definitions of old growth or the specific process to identify old-growth stands, nor does the HFRA require that old-growth stands be mapped.

The HFRA does not require revisions or amendments to resource management plans, nor does the HFRA require a review of management direction for old-growth stands adopted before December 15, 1993, unless a unit elects to use HFRA authority. However, if units are amending or revising their resource management plans, or contemplate doing so, they should consider the benefits of being able to use the HFRA authority.

Under Section 102(e)(4), for plans containing old-growth management direction adopted before December 15, 1993, resource managers expecting to use HFRA authorities have up to 2 years or, if the plan was in the revision process as of December 3, 2003, up to 3 years, to review existing management direction for old growth. Existing old-growth management direction in the plan applies during the review period. When reviewing the older management direction, the unit should:

  • Take into account any relevant scientific information that has become available since adoption of the older management direction.

  • Determine whether the older management direction provides for maintaining and restoring old-growth stands to a pre-fire suppression condition, as provided by Section 102(e)(2).

Based on this review, the agencies will determine whether additional plan direction is needed for covered projects within old-growth stands.

If a review of older management direction is not completed within the 2- or 3-year timeframes described above, forest stands must be dropped from any HFRA project proposal if someone provides “substantial supporting evidence” during scoping that the stands are old-growth stands (Section 102(e) (4)(C)). Managers may examine whether these areas can be treated using standard legal authorities, rather than those provided in the HFRA.

Substantial supporting evidence may include maps or records identifying old-growth stands, accompanied by plot data showing that the stands meet old-growth stand attributes or criteria established by the applicable resource management plan.

The References section contains USDA Forest Service ecological old-growth definitions that may be a useful starting point for reviewing management direction in older plans (those adopted before December 15, 2003). These definitions were not necessarily developed for determining the “pre-fire suppression old-growth condition” as directed by the HFRA. Resource managers should evaluate these definitions closely to determine whether they need to be modified for identifying, maintaining, and restoring old-growth stands under the HFRA.

In making this evaluation, resource managers should consider the appropriate reference condition for old growth. While the HFRA refers to a “pre-fire suppression old-growth condition,” fire behavior patterns had been modified substantially in many areas 50 years or more before the era of active fire suppression. Such changes in fire behavior commonly were associated with the elimination of burning by native peoples and a dramatic increase in livestock numbers, which modified grasses and other fine fuels. In selected forest types where such changes occurred, it may be desirable to establish reference conditions that existed before the era of active fire suppression. The HFRA does not prohibit this. The References section provides examples of regional planning direction and assessment-level old-growth information that may be useful when evaluating resource management plan direction to maintain and restore old-growth stands to a pre-fire suppression condition.

Various approaches to amending old-growth direction in resource management plans are possible (if such amendments are deemed necessary). These include:

  • Amendments for each resource management plan

  • Project-specific amendments

  • Development of multiforest old-growth management guide­lines based on specific forest types, followed by resource management plan amendments to meet those new guidelines.

In situations where the plan does not contain old-growth management direction, if resource managers want to carry out a hazardous-fuel-reduction project (figure 13) under the HFRA, the large-tree retention requirements in Section 102(f) should be used until the plan is amended to incorporate direction in conformity with Section 102(e)(2). In these situations, if plans are not amended or revised to include old-growth management direction consistent with Section 102(e)(2) within 2 years of the HFRA’s enactment, or within 3 years if the plan was being revised at the time of the HFRA’s enactment (December 3, 2003), forest stands must be dropped from a HFRA project proposal if someone provides "substantial supporting evidence" during scoping that these stands are old growth.

Photograph of a forested area referred to as an old-growth stand.
Figure 13—Hazardous-fuel treatments authorized by the HFRA in old-growth stands
are intended to retain the “large trees contributing to old-growth structure.”
This old-growth ponderosa pine stand in the Lassen National Forest (California) was
thinned, leaving large trees. Some of the trees that were removed were large enough to
cut for lumber at a sawmill. Smaller trees were chipped and used as fuel to produce electricity.

Research studies, such as the study by Kauffman and others in dry ponderosa pine and Douglas-fir landscapes in the southern Rocky Mountains (2003, see References, Old-Growth and Large-Tree Retention, Project-Level Guidance), may provide useful insights when developing treatment strategies for maintaining or restoring old growth to pre-fire suppression conditions. Tools, such as the Vegetation Dynamics Development Tool and the Forest Vegetation Simulator, coupled with the Fire and Fuels Extension see References, Old-Growth and Large-Tree Retention, Project-Level Guidance), may also be useful when modeling prescriptions to restore or maintain pre-fire suppression old-growth conditions in particular forest types. Regional or State offices can help units accomplish these aims by hosting workshops or providing guidance for the major forest types within their region or State.

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