-
by Matt Peters
July 8, 2024[Note: if you or your group would like to cosign the Heartwood Comments re. Project #65356: National Old-Growth Amendment Draft Environmental Impact Statement, please follow this link.]
The public has a second chance at a once-in-a-lifetime opportunity to protect our last remaining old-growth forests. On June 21, 2024, the US Forest Service published a Draft Environmental Impact Statement (DEIS), a study of five alternatives for implementing Executive Order 14072, issued by President Biden on Earth Day 2022, which directs the USFS and the Bureau of Land Management (BLM) to protect old-growth forests. The publication of this DEIS begins a 90-day public comment period, with comments accepted until September 20, according to their online announcement. This is a historic opportunity to provide meaningful protections to the last of our old-growth forests. More than half a million Americans participated in the first round of public comments to produce this DEIS. In this second opportunity we hope to see half a million new voices calling for genuine protections.
The DEIS presents several alternatives, various ways the agency might implement the Executive Order to provide protections for old-growth forests (including a “no action” alternative, as required by NEPA). Their preferred choice, Alternative 2, dares to claim that commercial logging is an ecological management tool in these fragile forests!
This outrageous claim is based on the faulty logic found in the first 40 pages of the Threat Analysis, a report published by the USFS a week before the DEIS. Predictably, this report finds that their own logging program is comparatively less of a threat than climate change or wildfires, and fails to acknowledge that it is their own logging in the name of “fuels reduction” that often makes these fires worse. The report spends page after page explaining how what constitutes a “threat” is relative, describing how logging interests may threaten conservation interests, and vice versa – thereby not only diluting the impact of their own logging and other management activity, but also presenting the worn-out “jobs vs the environment” trope as a basis for government policy.
The report ends with the frank acknowledgement that Eastern forests were largely not considered at all, which speaks to the need for further study at the very least. Yet the Forest Service is actively and aggressively pursuing not millions but billions of dollars in funds from Congress for massive wildfire management programs, and spending the bulk of that money in Eastern hardwood forests, where we see massive, landscape-scale ten-year projects like the Buffalo Springs proposal in the Hoosier, or the Jellico proposal in Kentucky’s Daniel Boone National Forest. Region 8, which includes the Boone along with the southeastern US down to Puerto Rico, receives the most funding by far, with region 9 the next largest recipient of these taxpayer dollars. This is more about logging the backcountry for timber than it is about genuine wildfire protection for homes, where that funding would be far more effectively spent.
Alternative 3 in the DEIS is the alternative that would restrict the use of commercial logging as a management tool. This alternative would still allow logging, burning, and herbicides in these delicate and fragile ecosystems, if it can be shown that it is being done for “ecological health” – but here again we see that this excuse has been abused by the agency as a way to meet timber quotas. Alternative 3 also states that restricting commercial logging on the last scraps of old-growth forest could mean an increase in logging elsewhere, a threat that ignores the implications of Executive Order 14008, known as “America The Beautiful” which aims to protect 30 percent of the land and waters of the US by 2030. Ohio and Indiana are typical of many states in regions 8 and 9, where national forests in their entirety comprise as little as 4% of the area, far short of these goals and standards.
Ending commercial logging on public lands is the founding principle of Heartwood.
By refusing to recognize the damage their own management has wrought on our national forests, the Forest Service has once again demonstrated that they cannot be trusted to manage our public forests for anything other than timber production. It is time for a change in administration of these lands to another agency more suited to forest protection than forest exploitation, such as the US Park Service in the Department of the Interior. This may be dismissed as “beyond the scope” of the question here at hand, but in the long run this may be the best way to provide our public forests with the protections they need.
Public participation is essential to ensuring our forests are genuinely protected.
The National Environmental Policy Act (NEPA) requires that the agency include the most current science in their decision-making process, and consider a “reasonable range” of alternatives. The law also provides opportunities for the public to participate in the management decisions that affect our public forests and require our taxpayer dollars to administer. Your letters and comments are an important element in a functioning democracy!Heartwood is working with our member groups to develop templates for detailed comments, as we dig into these highly technical documents and deepen our own understanding of the implications behind the jargon and rhetoric. We have until September 20th to send in our official comment letters, but we can begin in our own communities now with letters to our local newspapers, elected officials, and other public messaging on the need to protect forests and the seriousness of climate change.
Three major themes have emerged so far:
- The FS excludes forests in the entire eastern half of the United States from protection. Eastern deciduous forests from the Appalachians to the Ozarks play a crucial role in absorbing carbon from the atmosphere and storing it in the soil, and mature forests (which typically means “ready for harvest” to the agency) as well as old-growth must be protected under this important plan amendment. Instead, the FS proposes to continue their plans for logging and burning these forests, motivated by the money Congress gives them and conflating ecological health with the economic productivity of timber.
- The FS fails to recognize that their own management is the root of the problem. Many of the national forests in the Eastern US were established in the early 1900s, and a major factor in establishing these forests was because timber and railroad companies had almost entirely clearcut the entire eastern half of the continent. A century of continued logging under the management of the US Forest Service has kept these forests in a degraded early-successional state due to repeated disturbances. Yet the FS insists that commercial logging is an ecological management tool, in an effort to justify continuing their mismanagement of our public forests. Mature forests must be allowed to grow to old growth status to meet the goals of Executive Order 14072.
- The FS seeks to impose the same fire management techniques on eastern deciduous broadleaf forest ecosystems as those used in Western conifer forests, where fire plays a very different role. Our eastern forests are better suited for holding water and cooling the planet, and need to be allowed to do so.
This is only a preliminary critique of their proposals. Heartwood and many of our member groups will be hosting online seminars and study groups in the coming weeks to help coordinate the grassroots community behind a clear message: protect our old-growth forests from the ones who have mismanaged our forests and squandered our old-growth heritage in the first place. Look for announcements on our website as well as our facebook group and page.
This 90-day comment period is our best chance to protect America’s last remaining old-growth forests, and begin restoring our forests for our nation’s future.
Letters and comments for the public record can be sent to:
Land Management Plan Direction for Old-Growth Forest Conditions
Across the National Forest System, #65356.
Director, Ecosystem Management Coordination
201 14th Street SW, Mailstop 1108
Washington, DC 20250 - 1124or you can use their online comment form. Original comments are best, this is too big an opportunity to merely sign a petition or send a form letter.
More than half a million Americans spoke up for forest protection in the first round of comments. Don’t miss this second chance at genuine protections for our last remaining old-growth and mature forests!
Donate to Heartwood today!
photos by Steve Krichbaum