NOGA COMMENT By John Muir project,
To USFS, and all Reps:

We are in the midst of two interrelated crises: a rapidly changing climate and the escalating loss of biodiversity throughout this continent. Bold action is needed to address these twin crises,  action that you could take right now with an Executive Order directing an immediate halt to commercial logging in mature and old forests on land managed by the Forest Service and Bureau of Land Management.

Conserving forests is one of the most effective and lowest-cost options for managing atmospheric carbon dioxide, and mature and old-growth forests do this job best. Protecting and expanding these forests does not require expensive or complex energy-consuming technologies and supports the multiple uses mandated on federally managed lands.

Allowing mature and old-growth forests to continue growing will remove large amounts of atmospheric carbon from the air and store it in the critical decades ahead. Furthermore, mature and old-growth forests help moderate our planet's climate by providing cooler, wetter weather, thus contributing to the mitigation of global warming effects. The sooner the federal government stops logging these forests, the more climate benefit they can provide. 

Now is the time to issue a moratorium on logging mature and old-growth forests. We appreciate that the old growth management rulemaking is underway, but the US Forest Service and Bureau of Land Management are still planning and implementing commercial logging projects in these important forests even as the rulemaking process moves forward, undermining the intent of your Executive Order 14072 and the ecological integrity of these special places.  A new Executive Order, establishing an immediate moratorium on logging old growth forests, would ensure that these critical forests are still standing by the time the rulemaking is complete. 

Prioritizing carbon storage in mature and old-growth forests has the co-benefits of providing high-quality habitat to imperiled species, making forests more resilient to disturbances like wildfire, and providing cold clean water for drinking and for terrestrial, avian, and aquatic species. 

We ask that the Biden Administration: 
- Establish a moratorium on logging all mature and old-growth forests on federally managed land until such a time as permanent and legally binding protections for these forests are in place.
- Ensure that agencies identify logging, including post-disturbance logging, as a primary threat to these forests in the Environmental Impact Statement for the National Old Growth rule and related rulemaking for Bureau of Land Management (BLM) lands.
- Establish requirements for agencies to include mature forests in developing policies to protect older forests on federal public lands, as per E.O. 14072. Given that only a small percentage of old growth forests remain, it is imperative to provide strong and durable protections for mature forests, in addition to old forests, to ensure a supply of future old growth. Thus far, agencies have excluded mature forests in their initial analyses. 
- Require the FS and BLM to comply with the direction and intent of Biden's Executive orders as part of current and future Forest Plan revisions and amendments to ensure that protections for mature and old forest are strengthened--not undermined or weakened--in future Forest Plans. 
- Reduce or eliminate the annual timber targets set by the Forest Service and BLM. This will reduce pressure on forest managers to meet specific harvest quotas, for which they rely on logging large trees and intensive logging practices. . 

Contrary to prevailing forest fire management perspectives, intensively managed and logged forests burn more severely than protected forests. Protected forests are less likely to burn at high severity than managed forests, with increasingly higher levels of protections for forests corresponding to increasingly lower severity wildfires.

Brave leadership is needed to enact a paradigm shift for federal forest management that prioritizes biodiversity, clean cold water, carbon storage, connectivity and core habitats for wildlife, and unfragmented forests. It is long past time to move away from outdated strategies of large scale resource extraction on federal public lands. Such changes are needed to avert the worst of the climate crisis, as well as for ensuring clean drinking water and livable communities.

We appreciate the action that this administration has already taken on behalf of biodiversity and the climate, and implore you to take this next important step to keep mature and old-growth forests standing. Thank you and we look forward to hearing from you soon.