Secretary Vilsack and Secretary Haaland,
We are writing on behalf of our millions of members and supporters across the country to comment specifically on how you should define—and manage— mature and old-growth trees and forests to provide the greatest climate, biodiversity, and drinking water benefits for the United States.
President Biden correctly identified these forests as critical to climate and biodiversity crises in Executive Order 14072. As these crises continue to have far-reaching impacts on communities across the country, it is essential the Biden administration do everything it can to address them. The United States has to take additional action to reduce climate pollution and position itself as an international leader in climate action if we all are to be spared the worst consequences of global warming.
Conserving mature and old-growth forests on Forest Service and Bureau of Land Management lands offers one of the most straightforward, cost-effective ways to protect existing carbon stores while allowing these forests and trees to continue to pull vast amounts of carbon from the atmosphere — an essential climate strategy that scientists recognize must be implemented alongside cutting greenhouse gas emissions. Several scientific studies demonstrate that logging generates as much, and likely more, climate pollution than forest fires, while also degrading drinking watersheds and essential wildlife habitat. This threat must be addressed as part of any durable policy to protect mature and old-growth forests. As demonstrated by numerous projects across the country, mature and old-growth forests are still being logged for timber production, and require additional protections.
For purposes of addressing the climate and biodiversity threats posed by logging, we recommend that you define old-growth and mature forests to include all stands and trees 80 years or older. These 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 they are the building blocks for recovering much-needed old-growth ecosystems across the country.
A rule protecting these forests and trees can be readily structured to leave room for ecologically appropriate management that addresses fire and other non-commercial objectives, in particular because older, larger trees are more resistant to wildfires.
As the Biden administration looks to show international leadership and make a lasting difference, these changes must be memorialized in binding regulations that will endure in future administrations, much as the 2001 Roadless Rule has done. To ensure a rule can be adopted on the necessary urgent time frame, with time for robust public engagement and environmental review, it is critical for your agencies to initiate a rule-making process quickly.
In summary, we urge you, for purposes of permanently ending logging threats to the climate and biodiversity values of federal forests, to adopt a definition of “mature and old-growth” that includes all forests and trees older than 80 years. It is critical that your agencies move quickly to propose a rule that would protect these trees and forests from logging, with whatever exceptions can be shown to be necessary to preserve their values, allow for necessary wildlife management, honor government commitments, and safeguard the public.
Sincerely,
| 50 Eugene 350 PDX 350 Salem OR 350 Seattle 350 Wenatchee Alaska Wilderness League Bark Battle Creek Alliance & Defiance Canyon Raptor Rescue California Environmental Voters California Wilderness Coalition (CalWild) Cascadia Climate Action Now Cascadia Wildlands Center for Biological Diversity Central Oregon LandWatch Climate Reality, Baltimore Chapter Climate Reality, Portland Chapter Coalition to Protect America's National Parks Coast Range Association Conservation Lands Foundation Cottonwood Environmental Law Center Creation Justice Ministries Disabled Hikers Earth Ethics, Inc. Healthy Ocean Coalition I Heart Pisgah Inland Ocean Coalition John Muir Project of Earth Island Institute Kentucky Heartwood Kettle Range Conservation Group Kitsap Environmental Coalition Kitsap Environmental Coalition Klamath Forest Alliance League of Conservation Voters League of Women Voters of the United States Los Padres ForestWatch Massachusetts Forest Watch Metro Climate Action Team (MCAT) National Parks Conservation Association Natural Resources Council of Maine Natural Resources Defense Council Natural Resources Law New Jersey Forest Watch New Jersey Highlands Coalition New Mexico Wild Northcoast Environmental Center Northeast Forest Watch Northeastern Minnesotans for Wilderness Ohio Environmental Council Okanogan Highlands Alliance Old-Growth Forest Network Oregon Environmental Council Oregon Wild Partnership for Policy Integrity Patagonia Portland Youth Climate Strike Rachel Carson Council RESTORE: The North Woods Rocky Mountain Wild Safe Alternatives for our Forest Environment Save the Yellowstone Grizzly Sheep Mountain Alliance Sierra Club Soda Mountain Wilderness Council South Umpqua Rural Community Partnership | Earthjustice EcoFlight Endangered Species Coalition Environment America Environmental Action Environmental Law & Policy Center Environmental Protection information Center- EPIC Extinction Rebellion PDX Forest Keeper Forest Web Foundation Earth Friends of Big Ivy Friends of Blackwater, Inc. Friends of Douglas Fir National Monument Gallatin Wildlife Association Gallatin Yellowstone Wilderness Alliance Georgia ForestWatch Great Old Broads for Wilderness Central Oregon Bitterbrush Broads Great Old Broads for Wilderness, Willamette Valley Broadband Green Cove Defense Committee GreenLatinos Greenpeace USA Southern Utah Wilderness Alliance Standing Trees Sunrise Beaverton Sunrise PDX Sustainable Rogue Valley The Enviro Show The Forest Advocate The Lands Council The Ocean Project Thurston Climate Action Team TreeKeepers of Washington County (Oregon) Umpqua Natural Leadership Science Hub Umpqua Watersheds United Plant Savers Urban Nature Partners PDX Waterway Advocates Wenatchee Valley Climate Advocates Wendell State Forest Alliance Wild Heritage, a project of Earth Island Institute WildEarth Guardians Williams Community Forestry Project Women's Earth and Climate Action Network (WECAN) Yaak Valley Forest Council |