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USDA and DOI request for old-growth comments

The Forest Service is inviting public comment on President Biden’s Executive Order 14072, which calls for the Department of Agriculture and the Department of the Interior to “define, identify, and complete an inventory of old-growth and mature forests on Federal lands…” The agencies want input on defining old growth. Comments are due August 30, 2022.

Old-growth forest, Jeff Juel (glove for scale).

Friends of the Clearwater has reviewed the notice above, including its list of questions. The Forest Service is asking the wrong questions. The agencies’ philosophy embedded in these questions assumes the need for actions such as “adaptive management” and “wildfire risk reduction activities,” which are euphemisms for logging. And logging emits three times more carbon than the fire it purports to reduce. (Logging to reduce fire risk is scientifically dubious because climate and weather drive severe fires, and previously logged areas can actually increase wildfire risk.) So, logging old growth will contribute to global warming and will also increase the climate threat to remaining old growth. Logging is the number one threat to old growth forests.

Furthermore, while President Biden called for the definition, identification, and inventory of old growth on public lands, both of the forest plans for the Nez Perce and Clearwater National Forests, finalized in 1987, defined old growth and required the Forest Service to inventory it starting in 1987. According to the documentation FOC obtained, this inventory still isn’t complete. When FOC asked to meet about this, the Forest Service first sent the wrong experts to the meeting, and then refused to meet with us at all. FOC recently won a lawsuit on two massive timber sales because the Forest Service, after 30 years, still doesn’t have an old-growth inventory.


Talking points

* Insist that the USDA and DOI define old growth on a landscape level and an ecosystem scale.

* Tell the USDA and DOI that logging is more of a threat to old growth and mature forests than fire is, and urge the departments to issue a moratorium on logging.

The sole way to comment is through the agencies’ online portal: https://cara.fs2c.usda.gov/Public/CommentInput?project=NP-3239. Feel free to copy the below suggested text and make it your own. Thanks for taking action!


Dear USDA and DOI,

Define old-growth forests at a landscape scale and at an ecosystem scale. One acre of forest that meets a tree-by-tree definition for large trees will not confer the benefits of a 300-acre landscape, for example, where an intact ecosystem and its natural disturbances have been at play for a century. The legacy effects of wildfire, insects, and disease, commonly occur in mosaics across a landscape. The ecosystem time-scale involved is long—it includes time for disturbances to kill trees, and for those trees to fall to the forest, cycling nutrients back to the soil and providing openings where new trees and shrubs can grow to create a multi-story structure.

Logging is currently the biggest threat to old growth and mature forests. The largest trees store the most carbon. When a tree is logged, the majority of the carbon that tree was storing is released into the atmosphere, either immediately or in the short term as these products end up in landfills; only a fraction of the carbon that a living tree stored ends up in any long-term storage in the form of lumber. For these reasons, logging emits more carbon than wildfire, up to three times more carbon can enter the atmosphere than the wildfire that logging will purport to reduce. Wildfire is a natural disturbance for old growth; logging is not.

In sum, please define old growth at a landscape level and with an ecosystem time scale. Impose a moratorium on logging old growth. Keep mature and old growth forests standing for the climate, for the wildlife, and for ourselves.




You may also use any of the comments that FOC provided to the USDA and DOI. See the comments that FOC submitted below:

FOC_AWR on Mature-OG Inventory RFI.