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Deadline to submit public comments: September 20, 2024!
The National Old Growth Amendment

Everything you need to know

Background Information: 

On Earth Day 2022, President Biden released an Executive Order (EO 14072) committing the US to identify, inventory, and protect mature and old-growth forests on federal lands. The federal land management agencies (US Forest Service and the Bureau of Land Management) are responsible for developing a meaningful and durable protection policy, and implementing those protections in the field. 

Since the executive order, there have been more than half a million public comments calling for a formal rule to protect mature and old-growth trees and forests, in addition to dozens of letters to the US Forest Service from stakeholders—including Tribes, elected officials, and scientists—supporting the same. 

On Dec 19, 2023 the US Forest Service proposed a nationwide amendment to all 128 forest plans to restrict logging of old-growth forests, and begin guiding stewardship of future old-growth forests. The Draft Environmental Impact Statement (DEIS) for this proposal was released on June 21, 2024 and launched a public comment opportunity that will run through September 20, 2024. Given the outstanding role mature and old-growth trees and forests in national forests play in ameliorating the climate and biodiversity crises, it is vital that Federal agencies establish meaningful safeguards for their conservation. 

The agency’s proposed action fails to achieve these critical safeguards. 

The Chattooga Conservancy, in partnership with Climate Forests, will use this open public comment opportunity to urge the strengthening of the final policy and ensure that old-growth trees stay in the forest and are not sent to the mill.

The deadline to submit public comments is September 20, 2024! 

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Loopholes and Ambiguities: 
  1. None of the alternatives include language to prohibit logging of old growth, only a vague statement of desired condition. The final plan should end the cutting and selling of old-growth trees on public lands. These forests can be effectively managed without selling or commercially exchanging those trees. End of story. 
  2.  Mature forests and trees need explicit protection. The country has lost most of its old growth to over a century of logging. Mature forests provide the bulk of the climate benefits on federal forests and are the nation’s future old-growth. 
  3. We need solutions that match the magnitude of the threats we face. Conserving mature and old-growth forests on federal lands is a critical natural climate solution that will have a meaningful impact on the climate crisis and biodiversity crisis. We have a moral imperative to act boldly for future generations.  
  4. There are logging projects in the pipeline, including The Southside Timber Sale, that threaten mature and old-growth trees. The Forest Service included an elevated review process for proposed projects that contain old-growth in their announcement, but there is still a pressing need for the agency to follow through and ensure current projects are re-evaluated to reverse the loss of old-growth.

 

Asks:

The final record of decision should adopt a modified Alternative 3: 

  • 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. 
  • End any commercial exchange of old-growth trees. Even in the rare circumstances where an old-growth tree is cut (e.g. public safety), that tree should not be sent to the mill. (Alternative 3 includes a “no commercial exchange” provision.)
  • Remove the exception that allows for “de minimis” logging of old-growth trees.
  • Eliminate the agency discretion to manage old growth out of existence in pursuit of “proactive stewardship” goals.

 

Submitting a Public Comment: 

The Chattooga Conservancy is working in partnership with Climate Forests to raise public awareness and source public comments.  

We’ve created the Climate Forests comment submission page to allow us to track the comments that we have sourced and avoid relying on the Forest Services data. All comments submitted through the Climate Forrest comment submission page, linked below, will go directly to the U.S. Forest Service.

In the comment box, you’ll find a pre-written template that you are free to submit, edit, or re-write. Click below to comment!