Strengthen protections for older forests to curb climate chaos and species loss!

Dear Chief Moore:

I am writing to submit herewith my comment on the Land Management Plan Direction for Old-Growth Forest Conditions Across the National Forest System, Project #65356.

This Draft Environmental Impact Statement (DEIS) has the potential to simultaneously advance our progress in combatting the climate and biodiversity (species-extinction) crises by greatly curtailing the logging of old growth in U.S. national forests. But it can only accomplish this if several significant changes are made.

I strongly urge you to realize the intent and the potential of President Biden's Executive Order (E.O.) 14072 by ending commercial logging of old growth and by putting into place strong protections for mature trees and forests from the threat of logging. These steps will constitute a key pillar of U.S. climate policy and reinforce America's international climate leadership.

Safeguarding and expanding carbon-rich forests on Forest Service lands is the most cost-effective and one of the most important, timely approaches we can take to fight the climate crisis. Mature and old-growth trees store and continually absorb large amounts of carbon while at the same time providing the public with abundant clean water, habitat for imperiled wildlife, and unparalleled and economically valuable recreational opportunities. Larger, older trees are also more fire resistant than younger trees, providing a key buffer against wildfire's spread to homes and communities.

Unfortunately, mature and old growth forests currently are threatened by many logging projects, both proposed and already underway. Logging is the main threat to old-growth and mature forests, not wildfire. The DEIS does not do enough to protect these precious forests. We need to ensure that both old-growth and mature trees on federal lands, remain standing to mitigate climate change and to maintain their many benefits for future generations.

The final record of decision should adopt a modified Alternative 3 in order to: 1) End the cutting of old-growth trees in all national forests and all forest types and end the cutting of any trees in old-growth stands in moist forest types. 2) End any commercial exchange of old-growth trees. Even in the rare circumstances where an old-growth tree may be cut (e.g. public safety), that tree should not be sent to the mill. (Alternative 3 includes a "no commercial exchange" provision.) 3) Remove the exception that allows for "de minimis" logging of old-growth trees. 4) Eliminate agency discretion to manage old growth out of existence in pursuit of "proactive stewardship" goals.

The final rule also needs to be clearer about protection of the nation's old-growth crown jewel—the Tongass National Forest in Alaska. The draft correctly removes a specific Tongass exemption but includes vague language that could be used to justify continued commercial logging of old growth there.

Last but not least, please strengthen protections for mature forests—our future old growth.

Thank you for your leadership on these important issues.