Public Comments for:

​Proposed Rulemaking for mature and old-growth forests


Take action! Tell the Forest Service to stop clearcutting our climate!

Need to Know:

Our few remaining old-growth forests provide unmatched natural benefits and beauty, but the U.S. Forest Service continues to target them in timber sales. If our older, most resilient forests’ incredible biodiversity, water-purification power, and boundless opportunities for recreation are not enough to convince you they’re worth protecting, their potential to store and sequester mass amounts of climate-harming carbon should.

You can help by sending a comment to the Forest Service now. Tell the agency it must recognize logging as the primary threat to carbon storage in eastern national forests, and to use our mature and old-growth forests in the fight against climate change by protecting them.

Add your name to the growing list of over 43,000 individual comments to the Forest Service urging them to protect our mature and old-growth forests. This link will take you to a form-letter where you can sign on and submit a personal comment now through July 20th, 2023.

Take A Deep Dive:

The Forest Service has announced its Proposed Rulemaking for mature and old-growth forests. The public has through July 20 to comment.  This will help direct the overall management of the 188-million-acre National Forest system.  This analysis and request for comment covers broad-based questions that get at the heart of the overall direction of the agency.  Your voice is needed to help encourage the Forest Service to focus on a land ethic that promotes preservation of our public lands heritage.


The announcement (above and here) requests comments on a battery of questions, with some of the overarching questions including:

  • ​How should the Forest Service adapt current policies and develop new policies and actions to conserve and manage the national forests and grasslands for climate resilience, so that the Agency can provide for ecological integrity and support social and economic sustainability over time?
  • How should the Forest Service assess, plan for and prioritize conservation and climate resilience at different organizational levels of planning and management of the National Forest System (e.g., national strategic direction and planning; regional and unit planning, projects and activities)?
  •  What kinds of conservation, management or adaptation practices may be effective at fostering climate resilience on forests and grasslands at different geographic scales?


Some of the most important things the agency needs to hear include ending the logging of mature and old-growth in our national forests for not only the obvious watershed and wildlife protections, but for the vast importance they have on climate.  

Over seventeen billion metric tons of carbon is stored in federal forests. The larger and older the trees, the more carbon stored in them. We want you to protect these trees that remove carbon from our atmosphere every single day. Their carbon storage in roots, trunks and branches grows every year of their lifetimes at no cost to us nor to the USFS. Some trees live far beyond 400 years. There is no other natural or man-made technology that comes close to being as effective.

When trees are logged eighty percent of the carbon they’ve stored is released to the atmosphere.

In addition, the heavy equipment that is used to cut the forests, from feller bunchers to logging trucks, causes soil compaction, biodiversity loss, and releases even more greenhouse gasses. All further accelerate climate change.

Allowing forests to mature into old-growth is a sound investment in our future.  The idea of "resiliency" has been an ecological term that has been adopted by the Forest Service, but much debate remains on what that term means.

Below is a discussion of "resilience" to help clarify this. In short, allowing natural processes to be the main driver of forest structure and health allows forests to heal and develop in the ways they have evolved to do so for millennia.  Unfortunately, many forests are facing significant pressures through logging for "forest health, restoration, and resiliency" justifications. Here's a few local examples:

  • In the Redbird District of the Daniel Boone National Forest: 4,000 acres of logging in South Red Bird. The 32,275-acre South Red Bird Wildlife Enhancement Project, along with the smaller Spring Creek project, includes over 2,800 acres of clearcutting and the construction of nearly 100 miles of logging roads on extremely steep and landslide-prone mountainsides.
  • In the Stearns District of the Daniel Boone National Forest: 10,000 acres of forest including mature and old-growth, much of it on steep, erosion-prone slopes near the Jellico Mountains. 5,000 acres of clearcutting.
  • In Indiana: Hoosier National Forest plans threatens 9,000 acres of forest, prescribed burns on another 28,000 acres and building more than 27 miles of roads.
  • In West Virginia: Monongahela, 3500 acres of forest, mature and old-growth, steep slopes, erosion-prone.
  • In North Carolina: Nantahala-Pisgah National Forest plan puts over 12,000 acres of old-growth on the chopping block.

The role of providing the nation with timber for construction materials, furniture, and paper is amply filled by privately-owned forests that supply ninety-five percent of our national needs. Even the menacingly destructive, polluting wood pellet industry relies on private forests, primarily in the southeast, shipping the fuel product to European countries where shredded trees contribute even more carbon to the atmosphere than burning coal.

Our national forests are now far more valuable for their role in helping to stabilize climate, protecting wildlife habitat, ensuring clean water supplies, and offering respite and recreational opportunities for current and future generations. Humans and wildlife both need room to roam.

There are plenty of current and historic precedents for alternative ways to manage our national forests the USFS already employs. By establishing no-log special management areas, such as has been done in some places, our mature and old-growth forests could be protected.

As the USFS moves forward to establish a Rule to govern a new era in management of our National Forests, we ask citizens like you to call upon  the Forest Service to prioritize preserving mature and old-growth in our national forests, our public lands, for their value to the public, in climate change mitigation, clean air and water, wildlife habitat, biodiversity and recreation.

It is important that regional realities be addressed.  While the above recommendations apply to our forests nationwide, there are significant issues that are specific to Eastern landscapes that are overdue for the agency to address.  While the ideas and issues discussed above cover many of the core issues, below are some further topics if you wish to dig deeper and customize your comments further, with real-examples of from Eastern National Forests.  Check them out!

We encourage you to take a few moments and support our public lands by being a voice for forest protection and our National Forests role as our homelands of ecological sustainability. The Forest Service takes individualized comments more seriously, so make your thoughts your own.

Comment Ideas:

Eastern forest specific:

We are blessed with 188 million acres of National Forest land nationwide and all are worthy of our protection and attention.  However, with differing land use history, ecology, and land ownership patterns, Western and Eastern forests each have significant issues and challenges.

With its vast acreages of contiguous lands and large parcels that largely escaped development, it is hardly surprising that a great deal of the Forest Service's orientation is in the west, while Eastern forests are generally smaller, more fragmented, and largely recovering second- growth.

The agency needs to address these realities more:

General comment ideas:

Comment Resources: