ACTION ALERT: Help define how President Biden protects old growth forests

ACTION ALERT: Help define how President Biden protects old growth forests 1024 768 California Wilderness Coalition


On Earth Day 2022, President Biden issued an Executive order calling on the Forest Service and Bureau of Land Management 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 conservationists to ensure that this first step turns into real and lasting changes in how federal agencies manage older forests. 

Old growth Douglas fir.

In response to the President’s Executive Order, the US Department of Agriculture, which oversees the US Forest Service, opened an official public comment period to solicit public 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 for permanent protections.

Use the sample text below to submit your comment through this link

Your comments can help achieve lasting protections for the public forests that are most important in the fight against the climate and biodiversity crises. Your voice matters in this process, and each comment submitted represents support for following President Biden’s leadership to protect our remaining mature & old-growth forests and trees . We know from past experience that for true change to happen, public demand must be overwhelming, and the nationwide effort to submit comments has almost reached its goal of 100,000 comments! Help us make sure we hit the mark.

Template Comment Letter (feel free to adapt)

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 trees and forests from logging, “mature” should be defined as 80 years and older. By setting logging limits using this definition, federal agencies will establish a safety net that assures minimum protection of the ecological and carbon benefits these older forest elements provide for future generations. These older forests and big trees collectively contain the bulk of the carbon already stored in federal forests and they continue to sequester carbon at high rates far into the future. 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 & 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 on 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, I 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 as 80 years and older, to permanently end the avoidable loss of their critically important carbon, water and wildlife values to logging.

For more information

Read the Registry Notice. Read the Worth More Standing report here.

Thank you for all you do to protect our forests and climate, and for helping to create this opportunity!