Action Alert! Help protect National Forests across the US

Public comments are needed on federal rulemaking for National Forests across the US.

Please speak up for biodiversity and forest and stream ecosystems! Comments are due by July 20th, 2023. 

The Forest Service is calling for public comments on how it should “adapt current policies to protect, conserve, and manage the national forests and grasslands for climate resilience.” This comes after an Executive Order from President Biden on Earth Day last year, which specifically addressed the importance of mature and old-growth forests.

In order to address the climate and biodiversity crises, the Forest Service needs a true paradigm shift that focuses on protecting biodiversity, ecological integrity, and carbon storage. BMBP is calling on the Forest Service to prioritize protections for wildlife and core habitats, connectivity corridors, streams, cold clean water, imperiled fish, and healthy soils. The agency’s outdated model of logging, livestock grazing, and other extraction-based management on National Forests is ecologically destructive, exacerbates the climate crisis, and does not keep homes or communities safe.

Rhetoric vs. reality: logging is not restoration. Amid the push from the timber industry and the Forest Service to increase logging, particularly logging of large trees and in mature and old forests, it is important to recognize the discrepancy between what the Forest Service is calling restoration and what is actually happening on the ground. Repeatedly, BMBP and others have found very concerning and heavy logging in sales that were presented to the public as necessary for restoration and safety.

You can see more examples of heavy logging, including clearcuts and logging of large and old trees here. 

The Forest Service is using fear of fire to justify widespread, intensive, and large-scale commercial logging. This narrative has been used to increase logging in remote back-country forests, far from communities. It’s been used to push for massive timber sales and decreased environmental review, and has led to fewer opportunities for public involvement with more agency discretion and flexibility—especially when it comes to logging of large trees and mature and old forests. 

Work around homes and communities to keep people safe, not logging and fire suppression in the backcountry! Focusing efforts on home hardening in and around communities is a more effective way to keep people safe. It also protects our firefighters from unnecessary risk in areas where wildfires could be allowed to burn and, in the process, create new and important habitats. For more on how to protect communities from wildfires, see this short report by Jack Cohen.

Tell the Forest Service to leave large trees and mature and old forests standing. We need your help to preserve large trees and mature and old-growth trees on federal lands. At a minimum, the Forest Service should put an end to logging of large trees and mature and old forests across the nation, with no exceptions. Mature and old growth trees store carbon, have been shown to be more resilient to fire, provide critical habitat to numerous sensitive and endangered species, provide stream-side shading and hiding cover for aquatic species in riparian areas, and are essential to nutrient cycling and soil stabilization. For more on this, see Dominick A. DellaSala and William L. Baker’s paper on large trees.

Tell the Forest Service to reinstate strong protections for large trees in eastern Oregon and southeastern Washington. As part of the increasing push for logging, the agency rolled back meaningful protections for large trees (those greater than 20” in diameter at breast height) across ~9 million acres on six National Forests in eastern Oregon and southeastern Washington. 

Previously, as part of rules known as the “Eastside Screens,” logging trees over 20” diameter was prohibited in most situations. These rules were put in place in the mid-90s in order to protect remaining habitat for old-growth-dependent wildlife. This was in response to over a century of overlogging and mismanagement that created an extreme deficit of large trees. 

Unfortunately, during the last days of the Trump administration, these protections for large trees were severely weakened, resulting in meaningful and enforceable standards in the region being virtually eliminated. There remains a well-documented deficit of large trees in the region. Large trees comprise just 3% of the trees in forests east of the Cascade crest in Eastern Oregon and Southeastern Washington (Mildrexler et al. 2020). We are asking for the Eastside Screens prohibition on logging large trees over 20” dbh be reinstated. 

Submit a comment to the Forest Service at link by July 20th, emphasizing the importance of ending logging of mature and old-growth trees. 

You may send comments electronically:
https://www.regulations.gov/document/FS-2023-0006-29271

You can also send comments by mail to:
Director, Policy Office, 201 14th Street SW, Mailstop 1108, Washington, DC 20250–1124.

You can customize the sample comment below or write your own. If you would like, include your connection to our national forests, the climate crisis, wildfires, or other logging-related issues here, and why this issue is important to you.

Dear Secretary Vilsack and Forest Service Chief Moore,

I am writing in response to the Forest Service’s public comment period on how to develop climate resilience on federal lands. One of the best ways to accomplish this goal is for the Forest Service and Bureau of Land Management to immediately end logging of large trees and mature and old growth forests on federal public lands across the US. This includes logging under the guise of thinning, selective logging, biomass utilization, post-disturbance logging and tree planting, and “restoration logging” for “resilience” and/or “climate smart forestry” purposes.

Please reinstate strong protections for large trees in eastern Oregon and southeastern Washington. Protections for large trees in this region were eliminated in the final days of the Trump administration in a rushed, politically motivated, and illegal process. There is still a deficit of large trees in the region, and we cannot afford to lose any more large trees. Mildrexler et al. 2021 found that large trees comprise just 3% of the trees on National Forests east of the Cascade Crest in eastern Oregon and southeastern Washington. Despite comprising only a very small percent of the trees in these forests, large trees store approximately 42% of the carbon. Large trees– regardless of species or age– also provide crucial habitat for birds and wildlife, and are essential components of healthy stream habitats. We need strong and enforceable standards to protect large trees– not ambiguous guidelines with numerous exemptions. The prohibition on logging large trees under the Eastside Screens provided crucial protections for wildlife habitat and streams for over two decades. Please reverse the ill-advised and illegal Trump-era rollback of the Eastside Screens. 

Logging large trees removes the most fire-resistant trees, and makes forests more flammable. Protected forests do not burn at more intense severities compared to unprotected forests (Bradley et al. 2016). Additionally, forests in the west evolved with and are adapted to wildfire, including mixed and high-severity fire regimes in many areas. Snag forests (i.e., burned forests) provide crucial habitat for species, some of which are specifically dependent on burned forests. The creation of snags (standing dead trees) and logs that are often abundant after fires provide critically important habitat for many sensitive species and jump start forest succession (DellaSala 2019).

Instead of outdated and ineffective management based on logging, it is imperative that we prioritize strong protections for wildlife and core habitats, unroaded areas, connectivity corridors, streams, cold clean water, imperiled fish, healthy soils, and carbon storage on public lands. Unlogged, intact, and less-managed forest ecosystems store more carbon and provide needed habitat for species. In order to allow species the best chance at surviving and adapting to climate change, we need to preserve wildlife corridors and large, un-fragmented, high-quality wildlife habitats (for more information, see this paper by Law et al. 2021).  Preserving large trees and mature and old forests are essential to such a strategy.

In addition to protecting large trees and mature and old forests, it is important to remember that other forest types, conditions, and processes are also essential components of forest ecosystems– and they deserve and need protections. Snag forests, young forests that are important for wildlife cover or connectivity, areas with abundant snags and downed wood, and stream habitats are all examples of habitats that are essential in forest ecosystems, and do not currently have enough protections from logging, livestock grazing and other destructive federal extraction activities. 

To restore forest ecosystems, the bloated and out-of-control road networks on National Forests must be addressed. Many National Forests currently have road densities at levels that exceed Forest Plan standards and are recognized as primary threats to water quality, fish, and watershed health. Road crossings across streams often create barriers to fish passage and block many miles of fish habitat for salmon and other imperiled fish. A key part of protecting streams in National Forests is reducing road densities, decommissioning roads, and removing artificial fish passage barriers primarily caused by roads (i.e., culvert removal and/or repair). Protecting riparian forests and stream habitats is key to protecting clean cold water, imperiled fish and aquatic species, and human drinking water.

 Logging continues to be a primary and widespread threat to mature and old forests in eastern Oregon and southeastern Washington, as well as across the nation. The Forest Service is entrusted with protecting public forests and ensuring that wildlife, clean water, and recreational opportunities are preserved for future generations. Logging does not mimic natural processes, and comes with a well-documented list of serious negative effects on wildlife, water, fish, soils, climate change, and more. Logging is also the leading source of carbon emissions in Oregon. We need to do better to protect biodiversity and our climate. 

The Forest Service must make crucial shifts away from failed logging practices and towards stronger protections for forests. An important first step is an end to logging of large trees and mature and old forests on public federal lands.

Sincerely,
Your Name

Citations:

Bradley, C. M., C. T. Hanson, and D. A. DellaSala. 2016. Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere 7(10):e01492. 10.1002/ecs2.1492 

Dominick A. DellaSala and William L. Baker 2020. Large trees: Oregon’s bio-cultural legacy essential to wildlife, clean water, and carbon storage. Available online at: https://wild-heritage.org/wp-content/uploads/2020/12/Large-Trees-Report-12.2020.pdf

Jack Cohen A More Effective Approach for Preventing Wildland-Urban Fire Disasters Jack Cohen, PhD; Research Physical Scientist; US Forest Service, retired. Available online at: https://static1.squarespace.com/static/61ef51b68cfef85e3fed8d43/t/6340520e899c747a294725bf/1665159696338/Dr.+Jack+Cohen+Wildland+Urban+Fire+Primer+for+Elemental+Viewers.pdf

Law, B.E., Berner, L.T., Buotte, P.C. et al. 2021. Strategic Forest Reserves can protect biodiversity in the western United States and mitigate climate change. Commun Earth Environ 2, 254 (2021). https://doi.org/10.1038/s43247-021-00326-0
https://www.nature.com/articles/s43247-021-00326-0

Mildrexler, David J., Logan T. Berner, Beverly E. Law, Richard Birdsey and William R. Moomaw 2020. Large Trees Dominate Carbon Storage in Forests East of the Cascade Crest in the United States Pacific Northwest. Frontiers in Forests and Global Change (2020). https://www.frontiersin.org/articles/10.3389/ffgc.2020.594274/full