To: The Honorable Randy Moore, U.S. Forest Service Chief Re: USDA Old-Growth Initiative

February 1st, 2024

Dear Chief Moore,

Thank you for starting a process that we hope will end with meaningful protections for existing old-growth forests and trees across the United States, and increase abundance and distribution of old-growth in the future. The undersigned organizations represent millions of Americans who care deeply about mature and old-growth tree and forest conservation across all national forests.

The severe loss of biodiversity and the worsening impacts of climate change require solutions that match the magnitude of the threats we face. We need transformational change, not the status quo or incremental steps towards future outcomes. Done properly, this Nationwide Forest Plan amendment could have a meaningful, near-term impact on confronting the climate crisis and on addressing the loss of biodiversity, and we look forward to working with the agency to see this potential realized.

The EIS must analyze alternatives with significantly strengthened protections of old growth. As written, the amendment would still allow for numerous unacceptable exceptions for commercial logging of old-growth. The Forest Service should, with very limited exceptions, end felling of old-growth trees everywhere and cutting in old-growth stands where fire is infrequent. And, in all events, the amendment language must be strengthened to completely eliminate the commercial exchange of old-growth trees. We also urge the Forest Service to remove the Tongass old-growth logging exemption from any further analysis in the upcoming EIS. Any financial incentive to log these trees will undermine the goals of the amendment and the desired climate and conservation outcomes of EO 14072.

We also urge consideration of provisions to preclude reliance on arbitrarily restrictive definitions that artificially limit the amount of old-growth forests ultimately protected by the proposed action. The Forest Service should ensure the amendment requires definitions that are fully inclusive of all old growth conditions, simple, and easily operationalized in the field.

And, consistent with the recognition in the notice of the importance of expanding the distribution and abundance of old growth forests, we encourage you to consider in the EIS process alternatives for conserving mature forests and trees, including their value as future old growth. National forests in certain geographic areas, for example national forests east of the 100th meridian, have virtually no old growth left due to logging which makes protecting mature forests all the more important. While there are certainly other threats to our older forests to be addressed (such as wildfire), the agency-acknowledged threat of ecologically inappropriate logging remains wholly and directly under USFS’s control.

The national forest plan amendment must also incorporate strong monitoring and accountability measures to track the abundance and distribution of mature and old-growth forests; ensure their value as a natural carbon sink is optimized over time; and reduce the nature gap by ensuring that frontline communities and nature-deprived communities directly benefit from the proposed amendments, including through the development of an “equity layer” to the United States Forest Service Climate Risk Viewer that demonstrates these benefits across the landscape and across diverse communities.

Thank you for the opportunity to provide feedback on this important effort. Given the outstanding role mature and old-growth trees and forests play in fighting the climate and biodiversity crises, it is vital that America establish the strongest possible safeguards for their conservation. We encourage the Forest Service to maintain its timeline for this amendment process, and robustly engage with Tribal Nations, the public, and other stakeholders.

Sincerely,

1000 Grandmothers for Future Generations
350 Bay Area Action
350 Eugene
350 Humboldt
350 Mass
350 Sacramento
350 Salem, Oregon
350 Seattle
350PDX
Alabama Interfaith Power & Light
Alaska Wilderness League
Alpine Lakes Protection Society
American Bird Conservancy
Bark
Biofuelwatch
Black Hills Sierra Group
California Environmental Voters
California Native Plant Society
Californians for Western Wilderness
Cottonwood Environmental Law Center Creation Justice Ministries
Dogwood Alliance
DPO Environmental Caucus
Earth Ethics, Inc.
Earth Law Center
Earth Neighborhood Productions
Earthjustice
EcoFlight
Endangered Species Coalition
Environment America
Environmental Action
Environmental Law & Policy Center Environmental Protection Information Center Extinction Rebellion Vermont
Federation of Western Outdoor Clubs
First Christian Church, Bloomington
Forest Keeper
Forests Forever
Foundation Earth
Franciscan Action Network
Friends of Blackwater, Inc.
Friends of Douglas-Fir National Monument Friends of Miller Peninsula State Park
Friends of the Bitterroot
Friends of the Ferdinand State Forest
Friends of the Inyo
Friends of White's Woods, Inc.
Gallatin Wildlife Association
Georgia Interfaith Power and Light
Grand Canyon Trust
Great Old Broads for Wilderness
Great Old Broads for Wilderness, Cascade-Volcanoes Chapter
Great Old Broads for Wilderness, Central Oregon Bitterbrush Chapter
Great Old Broads for Wilderness, Nor’easter Broadband
Great Old Broads for Wilderness, Northern San Juan Chapter
Great Old Broads for Wilderness, Polly Dyer Seattle Chapter
Great Old Broads for Wilderness, SW Utah Broadband
Ohio Environmental Council
Old-Growth Forest Network
Olympic Climate Action
Olympic Forest Coalition
Oregon Unitarian Universalist Voices for Justice
Oregon Wild
Pilchuck Audubon Society
Portland Audubon
Portland Audubon, Ten Mile Creek Sanctuary
Presbyterian Church USA
Protect Our Woods
Resource Renewal Institute
RESTORE: The North Woods
Rio Grande Indivisible, NM
Rocky Mountain Wild
Safe Alternatives for our Forest Environment (SAFE)
Sage Steppe Wild
San Francisco Bay Physicians for Social Responsibility
San Juan Citizens Alliance
San Luis Valley Ecosystem Council
Santa Cruz Climate Action Network
Santa Fe Forest Coalition
Save Our Wild Salmon Coalition
Save Our Woods
Sierra Club
Sierra Foothills Audubon Society
South Umpqua Rural Community Partnership
Southeast Alaska Conservation Council
Southern Utah Wilderness Alliance
Speak For The Trees Too, WV
Spokane Audubon Society
Standing Trees
Cascadia Climate Action Now
Catoctin Forest Alliance
Center for Biological Diversity
Center for Responsible Forestry
Central Oregon LandWatch
Chattooga Conservancy
Church of the Brethren, Office of Peacebuilding and Policy
Citizens' Climate Lobby
Clean Black Lake Alliance
Climate Action California
Climate Communications Coalition
Climate Reality Project, Portland Chapter
Climate Writers
Coalition on the Environmental and Jewish Life
Coalition to Protect America's National Parks
Connecticut River Defenders
Conservación ConCiencia
Conservation Northwest
Great Old Broads for Wilderness, Willamette Valley Broadband
Great Old Broads for Wilderness, Yavapai- Prescott Broadband
Green Snohomish
GreenFaith Wy'East
GreenLatinos
Hartland Community 4 Youth and Families (HC4YF)
Healthy Ocean Coalition
Heartwood
High Country Conservation Advocates
Indiana Forest Alliance
Indigenous Environmental Network
Interfaith EarthKeepers
Interfaith Power & Light
Interreligious Eco-Justice Network/CT Interfaith Power & Light
Keep the Woods
Kentucky Heartwood
Kentucky Resources Council, Inc.
Kentucky Student Environmental Coalition
Kettle Range Conservation Group
Klamath Forest Alliance
Klamath-Siskiyou Wildlands Center
Lake Tarleton Coalition
Latino Outdoors
Laudato Si Movement
League of Conservation Voters
Legacy Forest Defense Coalition
Mason County Climate Justice
Minnesota Interfaith Power & Light
Mobilizing Climate Action Together (MCAT)
Montana Interfaith Power & Light
National Parks Conservation Association
Natural Resources Council of Maine
Natural Resources Defense Council (NRDC)
Natural Resources Law
New Jersey Forest Watch
New Mexico Sportsmen
New Mexico Wild
Northcoast Environmental Center
Northeastern Minnesotans for Wilderness
Occupy Bergen County
Student Public Interest Research Groups (PIRGs)
The Enviro Show
The Forest Advocate
The Forest Restoration Group
The Ocean Project
The People’s Justice Council
Thurston Climate Action Team (TCAT)
Trout Unlimited - South Coast
Tualatin Riverkeepers
Turtle Island Restoration Network
Umpqua Natural Leadership Science Hub Umpqua Watersheds
Unitarian Universalists for a Just Economic Community
Unite the Parks
United Church of Christ
United Plant Savers
Upper Gila Watershed Alliance
Water League
Wendell State Forest Alliance
Western Environmental Law Center Western Slope Conservation Center
Western Watersheds Project
Whatcom Million Trees Project
Wild Watershed
WildEarth Guardians
Wilderness Workshop
Wildlands Network
Williams Community Forest Project
Women's Earth and Climate Action Network
Wyoming Wilderness Association
Yaak Valley Forest Council