Tell federal agencies that our climate forests are worth more standing

An old growth spruce forest in south Crestone Canyon with Old Man's Beard lichens growing on them.
An old-growth spruce forest in south Crestone Canyon with Old Man’s Beard lichens growing on them, courtesy of Bryant Olsen (CC BY-NC 2.0)

Last Earth Day President Biden issued an executive order calling on the Forest Service and Bureau of Land Management (the Bureau) to conserve mature and old-growth forests as a climate solution. This was a momentous step towards meaningful protections, but now it’s up to us to ensure that this turns into real and lasting changes in how federal agencies manage — and protect — older forests.

In response to the executive order, the Department of Agriculture and the Department of Interior opened an official public comment period to solicit feedback on how “to define, identify, and complete an inventory of old-growth and mature forests on Federal lands.” It is critical that we demonstrate widespread, overwhelming public support from every corner of the country for urgent action to permanently protect mature and old-growth forests and trees across all federal lands. The Forest Service and the Bureau continue to log these forests and trees, badly damaging their ability to store climate pollution and preserve biodiversity — and setting a terrible precedent internationally. There are limited chances for the public to weigh in, so we need to take advantage of every opportunity.

How to Submit Your Comments

To engage in this important process, please send some version of the letter below to the Federal Register. It’s important to write in your own words. In fact, copy and paste comments don’t get counted as individual comments. Neither do simple sign-on letters. While it’s great to show that we have thousands of people supporting an issue, it doesn’t add to the information the agency uses to make a decision. Please take the time to write comments in your own words. For more information about submitting comments that stick, check out our checklist (en Español).

Where to Submit Your Comments

Comments must be received in writing by August 15. Submit your comments. More information from the USDA and Forest Service can be found here.

Sample Comment Letter

This sample comment letter is provided courtesy of the Climate Forest Campaign, of which Rocky Mountain Wild is a member. Remember to reword this letter in your own words and add your own flair.

Dear Secretary Vilsack and Secretary Haaland,

Thank you for taking the next steps to advance President Biden’s Executive Order on Strengthening the Nation’s Forests, Communities, and Local Economies. As you know, protecting our remaining mature and old-growth forests and trees on federal lands represents one of the simplest and most cost-effective climate policies the U.S. can deploy at scale. But time is running short: the climate and biodiversity crises are growing exponentially worse and it is critical that you fulfill the President’s directive to provide lasting protections for these trees.

For the purpose of protecting these climate-critical forests from logging, ‘mature’ should be defined as trees 80 years old. Using that definition as a benchmark would protect our most climate and carbon-critical forests, and only in rare and exceptional circumstances should logging of these giants be allowed. These forests collectively contain the bulk of the carbon already stored in federal forests and they continue to sequester carbon at high rates. They also provide, across forest types, vital habitat and biodiversity benefits, and important sources of drinking water for communities. Critically, protecting mature forests and trees today will provide the foundation to recover old-growth ecosystems which have largely been lost to logging across the landscape.

President Biden’s Earth Day Executive Order rightly recognized the critical role mature and old-growth forests play as a climate solution, and the urgent need to confront the threats forests face. If continued   logging of these trees is allowed, the very values that let them play a vital role will be eliminated. Losing more of our mature and old-growth trees and forests to logging will only make the climate crisis worse:  Scientific research indicates that logging of federal forests is a major source of carbon dioxide emissions to the atmosphere that is at least comparable to, and probably greater than, levels associated with wildfires. 

A recent USDA Secretarial Memorandum stated that “A primary threat to old-growth stands on national forests is no longer timber harvesting, but rather catastrophic wildfire and other disturbances resulting from the combination of climate change and past fire exclusion.” This statement represents an alarming and inaccurate assessment of threats to mature and old-growth forests. Numerous examples of logging projects across the country that target mature and old-growth trees, including projects in the name of “restoration”, “hazardous fuels reduction” and “wildfire mitigation,”  underscore this point. Not only is the threat of logging to mature and old-growth federal forests pressing, but it is also one that is entirely within federal land management agencies’ power to address. Such a rule can be readily structured to leave room for ecologically appropriate risk reduction of uncharacteristic wildfire, which is very largely driven by small trees and brush, not big, fire-resistant trees that have survived for generations. 

If the Biden administration is to do all it can — and must — to limit atmospheric carbon levels, and demonstrate international leadership, these protections must be made through binding regulations that will endure in future administrations, much as the Clinton-era Roadless Rule has done. To ensure a rule can be adopted in the necessary urgent time frame, with the opportunity for robust public engagement and environmental review, it is critical for federal agencies to initiate a rule-making process as soon as possible.

In summary, we urge the US Department of Agriculture and US Department of Interior to work together to soon initiate a rulemaking based on a definition of mature forests and trees of 80 years, to permanently end the avoidable loss of their critically important carbon, water and wildlife values to logging.  

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