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.


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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
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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
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
Endangered Species Coalition Environment America
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Forest Keeper
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Gallatin Yellowstone Wilderness Alliance Georgia ForestWatch
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Great Old Broads for Wilderness, Willamette Valley Broadband
Green Cove Defense Committee GreenLatinos
Greenpeace USA
Southern Utah Wilderness Alliance Standing Trees
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The Ocean Project
Thurston Climate Action Team TreeKeepers of Washington County (Oregon)
Umpqua Natural Leadership Science Hub Umpqua Watersheds
United Plant Savers
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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