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ACTION ALERT:

Comments Needed to Define and Protect Mature and Old-Growth Forests

On Earth Day, President Biden signed an Executive Order to protect mature and old-growth trees. This direction by the President begs the question: What is an old-growth tree or forest? To define what needs protection, the Department of Agriculture, which oversees the Forest Service, and the Department of the Interior, which oversees the Bureau of Land Management (BLM), have put out a request for information on how to define mature and old-growth trees (collectively called “MOG”).

EPIC, of course, has been fighting for the protection of old-growth since our inception in 1977. How would we define the term? We believe that 80 years is a good starting point to use. Why 80? That’s, generally, when we see mature characteristics begin to develop, like thick fire-resistant bark, and would protect the trees that have the most stored carbon. This standard is already used by the Northwest Forest Plan, which sets an important precedent in the Pacific Northwest.

Finding these trees should be easy to do! Qualified scientists have already quantified older forests for every single national forest and BLM area. Federal lands, primarily national forests contain most of the older forests and have the greatest concentrations of imperiled species and ecosystems, carbon stocks and drinking water. Further, the Forest Inventory and Analysis Program of the Forest Service, for example, already collects data on tree age, size, and other characteristics of older forests. By tiering the definition to already-collected information, the process of mapping —and protecting—MOG should go much more smoothly.

The federal MOG inventory needs to fully recognize historical and contemporary widespread logging of old-growth forests as the main driver of the current national deficit, which the government and its agencies still fail to recognize. The loss of forests is contributing to the global and biodiversity crises. Logging was and still is the top main stressor of MOG. The assessment needs to have a more direct purpose and need statement regarding the importance of the older forests as the most effective natural climate solution.

The inventory needs also to recognize the importance of mature and old-growth forests that have succumb to natural disturbances that restart their successional clock. Post-disturbance logging must be identified as a principal threat to the entire seral development of MOG. When trees die, they become the building blocks – biological legacies – for forests to replenish and soils to further develop. The entire successional pathway influencing MOG is important to protect as logging at any stage can disrupt this natural process at the detriment of carbon stores, biodiversity, and other ecosystem services. It is vital that these critical biological legacies are protected from logging to allow forest succession to proceed through the cyclical process of young to MOG and back again.

The inventory, like with biodiversity, should be scale dependent and must be viewed within the context of the surroundings, which can be described from large to fine scale. It should start with the concentration of threatened and endangered species and bioregions, which are commonly used to place forests broadly into boreal, temperate, and tropical biomes. While all regions with MOG are critical to effective climate-forest policy, some regions stand out as globally significant, for instance, the Klamath-Siskiyou (northwest California, southern Oregon) is considered one of the world’s most biodiverse temperate conifer forest ecoregions with exceptional species richness. The Klamath Siskiyou bioregion has an intense amount of endemic species. It is a safe haven providing climate refuge for multiple rare, threatened and endangered plants and animals. However their irreplaceable habitat is consistently threatened by logging on public lands.

What comes next is what it means to “protect” MOG. The recently passed Inflation Reduction Act specifically contains $50 million “for the protection of old-growth forests on National Forest System land…”. While the purpose of this inventory and the recent Executive Order is to recognize and define mature and old-growth forests to aid in the climate and biodiversity emergency, the Forest Service and the BLM must recognize the one threat that is within its control— logging. Our forests are worth more standing! Currently, the Forest Service continues to move forward on the Bear Country project on the Klamath National Forest, targeting the mature and old-growth forests along the Salmon River. EPIC will continue to monitor our National Forests and ensure that the Federal Government follows through on its promise to protect our forests.

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Environmental Protection Information Center (EPIC) is a tax-exempt non-profit organization, under the section 501(c)(3) of the Internal Revenue Code, and therefore all charitable donations are deductible to the full extent allowed by law.

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US Forest Service, Roy Barbour

Subject: Define and Protect Mature and Old-Growth Forests

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I support the efforts to define mature and old-growth trees and forests (MOG) and to map their locations. This action is necessary to implement President Biden’s Executive Order to protect our life-giving forests, which serve as the most effective natural climate solution. We urge you to work with scientists who have already developed nation-wide inventories so that the timing and costs saved can go towards safeguarding rather than removing forests on public lands. For the definition of mature, I suggest using trees 80 years old as a starting reference. This is when old-growth characteristics begin to develop, like thick fire-resistant bark. Because logging has and still is creating a devastating deficiency of older forests, younger forests must be allowed to grow to attain more carbon storage and sequestration. The inventory should recognize logging as a primary threat to our older forests. Importantly, the inventory should recognize the role of mature and old-growth trees that have succumbed to ecological disturbances, such as fire, insects or disease. Post-disturbance logging is a principal threat to the entire seral development of MOG. When trees die, they become the building blocks – biological legacies – for forests to replenish and soils to further develop. Our forests are worth more standing. The Temperate Rainforests of the Pacific Northwest, primarily consisting of national forests, are our nation's heritage. While all regions with MOG are critical to effective climate-forest policy, some regions stand out as globally significant, like the Klamath-Siskiyou. Despite the recent Executive Order, the Forest Service and BLM continue to target older forests for removal, including the Bear Country and River Complex timber sales on the Klamath National Forest. Protecting mature and old-growth trees, live and dead, is the most effective natural climate solution we have. Please err on the side of caution in the definition of older forests and recognize logging as a main threat. To survive the climate and biodiversity emergency we must act quickly. Thank you for your consideration.

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Environmental Information Protection Center (EPIC) is a tax-exempt non-profit organization, under the section 501(c)(3) of the Internal Revenue Code, and therefore all charitable donations are deductible to the full extent allowed by law.

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ACTION ALERT:

Comments Needed to Define and Protect Mature and Old-Growth Forests

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