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Deadline to Comment on Forest Service’s DEIS on Old Growth – Amendments to Forest Plans

September 20 @ 9:50 pm - 9:59 pm

The United States Department of Agriculture has prepared a draft environmental impact statement (DEIS) for Amendments to Land Management Plans to Address Old-growth Forests Across the National Forest System. The Forest Service’s proposed old-growth amendment amends over 120 land management plans through one analysis and decision. The proposed amendment is intended to provide a consistent management framework to conserve and steward old-growth forests in response to rapidly changing climate conditions and other threats (e.g. wildfire, insect and disease).  

The draft environmental impact statement and supporting documentation is available online at https://www.fs.usda.gov/project/?project=65356 

HOW TO COMMENT:

Comments on the DEIS will be accepted for 90-days, starting the day after the publication of the Notice of Availability (NOA) for the DEIS in the Federal Register.

Comments may be submitted online through the Comment Analysis and Response Application (CARA) (preferred) or hardcopy.  

As the CARA webform and hardcopy are the two platforms for accepting comments, comments submitted outside these methods will not be prioritized for consideration and response; however, they will be included in the project record.

We assume the time-of-day deadline is comments submitted on-line by 9:59 MT, or 11:59 EST, as the deadline is usually the time zone of address, which is in DC, but this needs to be verified.

ALTERNATIVELY USE A PRE-FAB FORM LETTER
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FORM LETTER # 1

CBD form letter (pre-fab sign on letter)

https://act.biologicaldiversity.org/gQivV6PZXk6NehW3THNZLw2?sourceid=1009609&utm_source=action&utm_medium=email&contactdata=pUxC9h2WSLpilHuDWye8ZVzK+nhcWDH5HaDJBWNxfAe3lKq6UmlR0nUmEDP%2fc29xoXh0IvwkZ47Sjd%2fWhBGD5L1VEtxvxFisHqphY8X0ACwnwM7MtK7ij6etQqXjmEhTurqBRwdryKv01Wxgv0LIMPkTURMtc5TmZbzJ0y1mn8vQgvsB4YUCgQWN+GmQjp7jhCQ89fvNDSzbhK7DXLjWz6xZuEOQrMNmhVpLuV1cAnk%3d&emci=ffa97720-7865-ef11-991a-6045bdd9e096&emdi=8b687a8c-f466-ef11-991a-6045bdd9e096&ceid=586032

FORM LETTER # 2
Note there is an environmentalist portal created by Climate Forest coalition  for submitting comments – it has pre-fab comments.
LETTER TEMPLATE
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RESOURCES
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You can go to the Reading Room of the Forest Service and read letters that have been submitted. You type in the name of the organization or individual that submitted them.
Here are the 2 letters created by the John Muir Project on the DEIS that Prairie Hills Audubon Society signed on to:
You can go to the Forest Service reading room and see letters submitted by other environmental organizations.

 ARTICLES  or statements on Old Growth Forest amendments DEIS, Comments due Sept 19th

Center for Biololgical Diversity’s Press Release:

Forest Service Urged to Strengthen Protections for Mature, Old-Growth Forests in Draft Plan

https://biologicaldiversity.org/w/news/press-releases/forest-service-urged-to-strengthen-protections-for-mature-old-growth-forests-in-draft-plan-2024-06-21/

Earth Justice’s Press Release:

Forest Service takes key step toward first national rule to protect mature, old-growth trees, forests.      

https://earthjustice.org/press/2023/forest-service-takes-key-step-toward-first-national-rule-to-protect-mature-old-growth-trees-forests

Climate Forests Discussion of DEIS effort:

https://www.climate-forests.org/post/biden-administration-moves-to-protect-old-growth-forests

Climate Forests provides educational material on benefits of old growth forest:

https://www.climate-forests.org/copy-of-news-1

National Audubon Society’s article

https://ak.audubon.org/news/tongass-national-forest-and-new-old-growth-protections

Links to useful articles by Climate Forest relative to old growth

TEXT OF THE TWO ON-LINE COMMENT LETTERS

CENTER FOR BIOLOGICAL DIVERSITY FORM LETTER’s TEXT
 
I urge the U.S. Forest Service to significantly strengthen its final record of decision on the national old-growth amendment to (1) ensure meaningful protections for the United States’ remaining old-growth forests and (2) lay a foundation that will increase the abundance and distribution of old-growth trees for future generations. 
 
The agency’s proposed policy includes numerous loopholes that allow for continued — or even increased — logging of old-growth trees. Logging old-growth trees to save them from potential threats is a false solution. These climate champions are worth more standing.  
 
To successfully protect old-growth forests and trees, the final national old-growth amendment must support a modified alternative 3 that does the following: 
 
– Eliminate exceptions and end *all* logging of old-growth trees in national forests. 
 
– Remove the economic incentive for logging old growth by prohibiting the sale, exchange, and milling of old-growth trees. This should prevent all but truly rare removals of such trees. 
 
– Set the stage for durable protections for mature trees and stands, which is paramount to expanding the abundance of future old growth. To recover old growth that was lost to past mismanagement, mature forests and trees must be protected from commercial logging. 
 
Given the outstanding role mature and old-growth trees and forests play in curbing the climate and extinction crises, the Forest Service must establish *meaningful* safeguards for their conservation. Failure to do so undermines the objectives of this amendment, contravenes the direction of President Biden’s Executive Order 14072, and ignores more than half a million public comments the U.S. Forest Service received following the advance notice of proposed rulemaking it published in April 2023. 
 
Chief Moore, I’m counting on you to listen to the public and end the commercial exploitation of the country’s oldest forests and trees. They should be left standing to store climate-heating carbon, improve watershed health, provide crucial wildlife habitat, increase forest resilience to wildfires, and act as a bulwark against climate-change impacts like flooding and drought.
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CLIMATE FORESTS FORM LETTER’s TEXT:
 
Mature and old-growth trees and forests protect our climate by absorbing and storing carbon, boost resilience to fire, help regulate temperatures, filter drinking water and shelter wildlife. Logging them deprives us of the benefits and beauty of our largest, oldest trees.
 
The Draft Environmental Impact Statement fails to protect old-growth trees and forests. The proposal allows old-growth trees to be sent to the mill and allows agency staff to manage old-growth out of existence in pursuit of “proactive stewardship” goals. The draft also contains ambiguous language that could be used to justify continued commercial logging of old growth in the Tongass.
 
The final record of decision should:
1.End the cutting of old-growth trees in all national forests and forest types and end the cutting of any trees in old-growth stands in moist forest types.
2.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.
 
Cutting down old-growth trees to save them from potential threats is a false solution. They are worth more standing.
 
The DEIS fails to protect mature trees and forests. Mature forests and trees – future old growth – must be protected from the threat of commercial logging in order to recover old growth that has been lost to past mismanagement. Protection of mature forests can be accomplished in a manner that is consistent with addressing the threat of fire. They must be protected to aid in the fight against worsening climate change and biodiversity loss. And they must be protected to ensure that our children are able to experience and enjoy old growth.
 
We urge you to take this opportunity to protect our oldest trees and forests. Failure to do so undermines the objectives of this amendment, contravenes the direction of EO 14072, and ignores 500,000+ public comments the agency received on last summer’s advance notice of proposed rulemaking.

Details

Date:
September 20
Time:
9:50 pm - 9:59 pm
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