Climate Change Policy and Initiatives

Respondents expressed appreciation for the opportunity to comment, interest in ongoing inclusion of public in the rulemaking process and noted that all options should be considered during the rulemaking process. Some commenters asked specifically for the Forest Service to work with Tribes.

Respondents were concerned about compliance with the Administrative Procedures Act and National Environmental Policy Act processes, including the preparation of an environmental impact statement. Concern was also expressed about consistency with the Multiple-Use Sustained-Yield Act. Some commenters suggested that the Forest Service should expand the definition of multiple uses to include archeological uses, air and atmospheric uses, ecological uses, ecosystem carbon storage, quiet, and darkness. Others commented that the Forest Service may not adopt a more protection-oriented management regime.

A majority of the respondents expressed support in varying ways for the rulemaking and appreciated that the Forest Service is looking for ways to address climate change, noting that the effort is consistent with Executive Order 14072 and the America the Beautiful 30 by 30 initiative. Those who oppose the rulemaking do so because of skepticism about climate change claims and because they do not believe that the Forest Service has the authority to make the proposed changes.

Suggestions from respondents as to what the rule should accomplish included protections for mature and old-growth forests, prohibitions on logging, management for resistance to wildfire, restoration of forest lands, and forest management for carbon uptake and storage. Respondents provided examples that the Forest Service could consider while crafting the rule, including the Southeast Alaska Sustainability Strategy, and the Bureau of Land Management’s experience during their rulemaking exercise. Respondents also suggested many references for the Forest Service to consider in development of the proposed rule.

Several respondents made suggestions for layers to be added to the Climate Risk Viewer. Suggestions included layers for seed zones and seed inventories, layers tracking land management treatments, information about which layers have been ground-truthed, and requests that layers be included that focus on historic properties and their vulnerability to environmental stressors.

The use of Indigenous Knowledge is a concern for many respondents. Many supported the use of Indigenous Knowledge and had a number of suggestions as to how best to collaborate with Tribal Nations and Indigenous peoples and what areas of knowledge should be the focus. Conversely, some respondents asked that the use of Indigenous Knowledge be limited so that it is not elevated over other sources of reliable information. Respondents supporting the use of Indigenous Knowledge suggested that the Forest Service should adopt place-based stewardship strategies, as exemplified by Indigenous peoples and their traditional practices. Some respondents also made suggestions related to cultural burning and its relationship to prescribed fire.

Many respondents encouraged the Forest Service to make use of the best available science in decision making and provided suggestions, including using climate vulnerability assessments prepared by the National Park Service, using the USDA Climate Hubs and other research units, using local-scale ground-based data and Traditional Ecological Knowledge, and using sources from academia, state-level projects, and industry research. There were suggestions that best available science does not support the assertion that human-caused climate change is occurring. Respondents also suggested that the Forest Service seek out and make use of existing data sets and offered specific suggestions as to which data sets might be useful.

There were suggestions for initiatives with which the proposed rule should comply, including Executive Order 14072, the Wildfire Crisis Strategy, the Climate Adaptation Policy, the America the Beautiful 30 by 30 initiative, and Secretary Vilsack’s Memorandum 1077–044. Respondents asked that the Forest Service implement the Wildfire Crisis Strategy to reduce wildfire impacts and address the expansion of the wildland urban interface. Some suggested that the Forest Service use funding provided through the Infrastructure Investment and Jobs Act and the Inflation Reduction Act to fund construction needed for commercial timber harvesting and related restoration activities. Additionally, some respondents suggested that the Forest Service should partner with environmental justice communities to ensure that wildfire mitigation strategies align with climate and environmental justice goals.

Respondents suggested that the Forest Service mission and motto be revised to better reflect the need to consider climate resilience. Some also suggested that Forest Service directives be revised to reflect the proposed new policy direction. Some respondents were concerned that the proposed rule does not adequately acknowledge current protections in existing law for minerals mining. Others suggested that lands established for conservation be withdrawn under the Federal Land Policy and Management Act.

A number of respondents urged the Forest Service to more fully implement the 2012 Planning Rule because the rule includes policies that specifically address climate change. Commenters also asked for improvements in implementation of the 2012 Planning Rule, including placing greater emphasis on integrated resource planning, emphasizing renewable energy opportunities, and evaluating the current state of assessments and plan components to ensure they reflect best practices. Those that requested changes to the 2012 Planning Rule suggested that the rule should be revised more frequently.

Others suggested that the Forest Service reconsider its use of categorical exclusions because they are prone to abuse and do not allow for sufficient public review or consideration of the larger cumulative effects. However, some suggested that categorical exclusions should be applicable to cultural burning. Some respondents also asked for the Forest Service to streamline National Environmental Policy Act compliance as it relates to grazing.

Respondents suggested updates to the Forest Service Handbook, including simplification of definitions for certain terms, revisions to the definitions of Native Knowledge and Best Available Science, revisions to be consistent with policy options adopted in response to this ANPR, and revisions to policies related to silviculture.

New policies or statutes suggested by respondents included policies or rules that would require extinguishment of all wildfires during wildfire season, increase availability of domestic wood products from National Forest System lands, include new key performance indicators, require provision of forest carbon leakage data in forest planning documents, require communicating climate and carbon tradeoffs from deferring timber harvests, and require collaborating with the Department of Education to establish Conservation Education as a requirement at all accredited educational institutions.

Respondents supported the Forest Service developing outcome-based measures and indicators to address wildfire resilience and other threats. As to what those measures and indicators should be, suggestions included comparing wildlife populations in logged areas versus mature and old-growth forests; improving recreation use tracking; implementing measures of in-situ forest carbon storage; quantifying the sustained yield of all multiple uses; tracking numbers of acres burned in high-severity fires and whether the burned acres are in restricted areas, such as wilderness; and improving monitoring and tracking of vegetation management activities.

Respondents expressed general concerns about the effects of climate change and noted that there are many reasons why it needs to be addressed, including concerns about global temperature rise, wildfires, droughts, extreme weather events, and increasing ocean temperatures. Some also noted that climate change has exacerbated ecosystem threats such as wildfires, insects and disease, and extreme weather, all of which amplify already poor forest health. Respondents suggested that the Forest Service should revalue the ecological assets of national forests to reflect their irreparable nature.

Respondents urged the Forest Service to increase transparency, increase public input, reduce bureaucracy, and prioritize climate resilience at all organizational levels. Some asked that any new polices not impede access to mineral and energy resources. Others asked that the Forest Service use ecological integrity as an organizing principle. Some suggested that the agency focus on conservation and climate-smart forestry in adaptation planning. Others asked that the Forest Service consider fire risk and forest health in adaptation planning. Some asked for attention to be paid to the roles of field managers and other local resource professionals, and some asked for more funding, time, and training for forestry professionals. Respondents noted that there is a need to streamline the planning processes. A holistic management approach is advocated by some. Others suggested the Forest Service rely on science-based frameworks.

A number of suggestions were made regarding land management plans (forest plans) including more frequent revisions, improved monitoring, requiring that forest planning address climate change, allowing for more frequent amendments to forest plans to help keep them up to date, and developing a nationwide forest plan amendment requiring conservation of mature and old-growth forests. Respondents suggested that the Forest Service should fund and conduct research that could help with forest planning, including research to improve our understanding of how forest management can enhance water and climate security and resilience, and research on wildland fires. Some respondents asked for timber management prescriptions to be included in forest planning, including provisions allowing for timber harvest.

Respondents also suggested that the Forest Service develop a landscape-scale restoration program. Others suggested incorporating the Watershed Condition Framework and the Water Source Protection Program into the rule. Some suggested looking to watershed restoration action plans for examples of restoration activities. Others advocated for policies that support fire-resilient landscapes and communities and guidelines for large-scale landscape treatments. Respondents made suggestions as to which types of projects should be funded, including projects that reduce the risk of wildfire, projects that maximize the retention of large trees, projects that do not establish permanent roads, and projects that would include decommissioning of temporary roads.

Respondents urged the Forest Service to conserve landscapes with high biodiversity, social, and recreational values. Some asked for the designation of additional special management areas, such as wilderness and inventoried roadless areas, and others asked that conservation lands be withdrawn from mining and development.

Respondents asked that the rule protect water resources by addressing the effects of landfills, protecting water retention in aquifers, reducing the disturbance or fragmentation of forests, and combining actions to restore forest health with those to improve aquatic habitat resilience.

Respondents urged the Forest Service to adaptively manage wildlife habitat for a variety of reasons, including because climate change can have both positive and negative effects on species, because the balancing of multiple objectives can require tradeoffs, and because it allows for better protection of species of concern. Respondents also advocated for the maintenance of wildlife habitat connectivity; suggesting that the proposed rule should require identification of climate-sensitive, connectivity-dependent species; assess habitat connectivity; and identify areas needed to sustain wildlife. Others asked that the rule include identifying priority species and provide for habitat connectivity areas that would support those species. In a similar vein, respondents requested that the Forest Service work to reduce the effects of roads on terrestrial and aquatic species, including decommissioning and upgrading roads and removing barriers such as culverts.

Respondents supported the protection of forests and trees because they help curb global warming, are a renewable resource, support wildlife, and provide for mental and physical health benefits. Respondents commented on a variety of tactics that the Forest Service could engage in to ensure forests are managed for resilience in a changing climate, including prescribed burning, reforestation, and forest thinning.

Respondents commented on infrastructure and focused on the importance of roads and trails. Some commenters noted that road densities need to be addressed as part of climate resilience and that roads have negative effects on water quality, fish, and watershed health. Additionally, respondents commented on the relationship between Tribes and Forest Service roads and trails, noting that Forest Service roads are primary travel corridors for Tribal communities and that Tribes should be involved in the decision-making process around potential road closures. Similarly, it was noted that Forest Service trails provide Tribes with important access to hunting, fishing, gathering, and ceremonial locations.

Respondents suggested that recreational facilities should be designed and located to avoid environmental impacts. Respondents disagree as to whether recreation and spiritual values lead to economic development.

Many respondents asked for prohibitions on logging because forests store carbon, provide habitat, and support biodiversity. Commenters assert that the value of forests is greater than the monetary value of trees and harvesting is contributing to climate change. Conversely, some respondents advocated for timber harvesting to continue; noting that proper fuels management helps prevent high-severity wildfires and active forest management helps create more resilient forests. These respondents noted that timber harvesting is part of the Forest Service’s multiple-use mandate and contributes to the maintenance of healthier forests. Respondents asked for the Forest Service to support sustainable timber management practices to allow for timber harvesting while still maintaining ecosystem services that are sustainable over the long term.

Respondents asked for adaptation of policies related to rangeland management and grazing that include maintaining the culture of livestock grazing; requiring rotational, fenced grazing; streamlining grazing management policy across Forest Service and Bureau of Land Management lands; coordinating with permittees to allow minimal use on riparian pastures during the summer; giving Tribes equal, not preferential, treatment in providing input on land management; and using new technologies, such as virtual fencing, to address effects of fencing on wildlife.

On the issue of carbon uptake and storage, many advocated for national forests to be managed to increase carbon storage and as a hedge against climate change. Some argue that more carbon is lost through clearcuts and logging than through forest fires, while others assert that fires negate the benefits of maximizing forest carbon storage. Respondents’ expressed skepticism about the use of carbon credits, with some noting that current cap and trade programs have not been effective and that the goal should be to have net negative carbon emissions, which the use of carbon credits does not facilitate.

Respondents asked that the Forest Service work to mitigate risks to historic properties from climate change and work with Tribes and Indigenous peoples to that end. It was suggested that historic properties should be considered in every level of planning and that projects should be designed to improve the resiliency of historic properties.

When it comes to post-wildfire recovery and restoration, respondents had a number of suggestions, including allowing for passive restoration or passive rewilding, increasing the pace and scale of treatment implementation, planting trees, addressing road maintenance post fire, addressing propagation of invasive plant species post fire, and including watershed and aquatic restoration efforts.

A number of comments were made that relate to the management of eastern forests. These respondents noted that the threats to eastern forests differ from the threats to western forests, and that timber harvesting is a much greater threat than wildfire or insects. Respondents asked that the Forest Service change how policies are implemented to better reflect the needs of eastern forests. Respondents suggested that the Forest Service engage in more proactive planning and develop regional disaster response plans to address the needs of eastern forests. It was suggested that additional research is needed to better understand the nature and needs of eastern forests.

Commenters expressed support for cross-jurisdictional boundary efforts to address climate change. Specific suggestions included ensuring the rule supports Good Neighbor Authority Agreements; coordination with counties, businesses, interest groups, and other organizations; and working with communities to ensure the safety of those communities. Many were specifically supportive of better consultation and coordination with Tribes. Commenters noted improved coordination would allow for better integration of Indigenous Knowledge, would build trust, and would be consistent with Joint Secretarial Order 3403 on Fulfilling the Trust Responsibility to Indian Tribes in the Stewardship of Federal Lands and Waters. Respondents also urged the Forest Service to honor the commitments in the 2023 Action Plan on Strengthening Tribal Consultations and Nation-to-Nation Relationships. Several also asked for the Forest Service to respect reserved and retained treaty rights, Tribal sovereignty and autonomy, and federal Indian trust responsibilities to Tribal Nations. Respondents had a number of suggestions as to how the Forest Service might improve coordination with Tribes, including integrating Tribal management priorities into 5-year work plans, expanding the use of Integrated Resource Management Plans, employing Indigenous people, and funding programs to develop a Tribal forestry workforce.

Respondents value mature and old-growth forests and noted that they provide biodiversity, carbon uptake and storage, wildlife habitat, and recreational opportunities, among other things. Some respondents advocated for rules banning or limiting logging of mature and old-growth forests and asked for them to be protected generally from extractive uses. Some respondents stated that wildfire, drought, and pests act as additional threats.

Respondents asked for a number of revisions related to the mature and old-growth forests inventory, including adding place-based definitions, refining the structural definitions of mature and old-growth, and reviewing inventories that have been conducted by other entities.

Respondents provided many suggestions as to what policies the Forest Service should enact related to mature and old-growth forests. These included an old-growth logging moratorium, creation of a national land management consistency oversight and accountability program focused on maintaining the ecological integrity of mature and old-growth forests, and integration of Indigenous Knowledge and Western science into the management of mature and old-growth forests. Respondents also encouraged the Forest Service to collaborate with Tribal, public, and other government entities to develop forest conservation and restoration strategies for conserving and restoring mature and old-growth forests.

The ability of mature and old-growth forests to sequester carbon is valued highly by respondents and they connect this to climate resiliency. Respondents also value mature and old-growth forests for their importance to terrestrial and aquatic species because of the high-quality habitat mature and old-growth provides.

Respondents provided a number of suggestions as to how the Forest Service could better support diversified forest economies and help make forest-dependent communities more resilient to changing economic and ecological conditions. Suggestions included increasing recreation and tourism opportunities, promoting heritage tourism, investing in electric vehicle infrastructure in recreational facilities, supporting biomass pellet production, and prioritizing spending to reduce risks to communities. Respondents also suggested that developing policies to conserve and manage national forests and grasslands for climate resilience will also allow for social and economic sustainability. Respondents supported prioritizing nature’s health benefits over its economic value. Some respondents asked for the Forest Service to focus more on how the effects of climate change affect Tribes, communities, and rural economies. Suggestions from these respondents included tracking population trends, considering climate change during the forest plan assessment process, ensuring that fuel breaks are effective, and making use of social and economic models.

Respondents also asked that the Forest Service support adaptive capacity for underserved communities to help ensure equitable investments in climate resilience, noting that doing so is consistent with the Forest Service’s Climate Adaptation Plan, the Equity Action Plan, and the Tribal Action Plan. Commenters further noted that these efforts are important to help communities adjacent to national forests adjust to climate change and preserve historic properties. Some also focused on the inequities in the Forest Service’s systems and asked for improvements. Respondents asked for the Forest Service to work with underserved communities by partnering with local and Tribal governments and providing funding for liaison positions. Others asked for increased funding to support ecologically based forest management and training for individuals transitioning from forestry work.

On October 31, 2023, the Forest Service hosted a virtual public session to provide updates on our progress reviewing comments received. A recording of that session is available online.

The ANPR is consistent with and intended to support implementation of Secretary Vilsack’s Memo 1077-044, and the USDA Forest Service’s.

The public comments and recommendations received will continue to inform agency policy actions such as the proposed land management plan amendment and implementation of Secretary Vilsack’s Memo 1077-044, Climate Resilience and Carbon Stewardship of America’s National Forests and Grasslands.