On Earth Day President Biden issued an Executive order calling on the Forest Service and Bureau of Land Management to conserve mature and old-growth forests as a climate solution. This was a momentous step toward meaningful protections, but the Forest Service is trying to undermine the executive order by sidestepping its responsibility to put a moratorium on all logging of mature and old-growth forests. Now it’s up to us to ensure that this executive order turns into real and lasting changes in how federal agencies manage older forests. 

In response to the President’s Executive Order, the federal agencies have opened an official public comment period to solicit public feedback on how “to define, identify, and complete an inventory of old-growth and mature forests on Federal lands.” It is critical that we demonstrate widespread, overwhelming public support for permanent protections, and we want Kentucky's voice to be loud and strong! 

We are working with the Climate Forests Coalition toward the national goal of  100,000 comments submitted by the August 30 deadline. The most important goals of this campaign are to:

• Ensure that "mature" forests are defined in a manner that protects the majority of carbon, wildlife habitat, and watersheds on the landscape (we're using 80 years old as a benchmark for this). To us, the mature definition is more important than the definition for old growth. 
• Stress the need for a lasting rule prohibiting logging in mature and old-growth forests - it's not the focus of this federal register notice, but we're not sure how many public comment opportunities we'll get so we want to take advantage. 

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Please take action by submitting comments through the Forest Service’s portal.

Comments are more impactful when they are personalized! Please consider personalizing this letter to explain what mature and old-growth forests mean to you. 

Sample comments:
Thank you for taking the next steps to advance President Biden’s Executive Order on Strengthening the Nation's Forests, Communities, and Local Economies. As you know, protecting our remaining mature and old-growth forests and trees on federal lands represents one of the simplest and most cost-effective climate policies the U.S. can deploy at scale. But time is running short: the climate and biodiversity crises are growing exponentially worse and it is critical that you fulfill the President’s directive to provide lasting protections for these trees.

For the purpose of protecting these climate-critical trees and forests from logging, “mature” should be defined as 80 years and older. By setting logging limits using this definition, federal agencies will establish a safety net that assures minimum protection of the ecological and carbon benefits these older forest elements provide for future generations. These older forests and big trees collectively contain the bulk of the carbon already stored in federal forests and they continue to sequester carbon at high rates far into the future. They also provide, across forest types, vital habitat and biodiversity benefits, and important sources of drinking water for communities. Critically, protecting mature forests and trees today will provide the foundation to recover old-growth ecosystems which have largely been lost to logging across the landscape.

President Biden’s Earth Day Executive Order rightly recognized the critical role mature and old-growth forests play as a climate solution, and the urgent need to confront the threats forests face. If continued logging of these trees is allowed, the very values that let them play a vital role will be eliminated. Losing more of our mature & old-growth trees and forests to logging will only make the climate crisis worse:  Scientific research indicates that logging of federal forests is a major source of carbon dioxide emissions to the atmosphere that is at least comparable to, and probably greater than, levels associated with wildfires. 

In Kentucky’s Daniel Boone National Forest, there are an estimated 430,000 acres over 80 years old, comprising about 60% of the forest. About 100,000 acres of mature and old-growth forests have been cut since 1980; making up about 15% of the Daniel Boone National Forest. We must preserve what we have left! 

Protecting trees in the Daniel Boone National Forest over 80 years old will benefit the many species of conservation concern that depend on the mature and old-growth forests found here, such as:

• Threatened and endangered Indiana, northern long-eared, and gray bats
• Numerous species of birds that are suffering from habitat loss such as the Cerulean Warbler, Wood Thrush, and Red-headed woodpecker
• Medicinal and culturally significant plants like ginseng and goldenseal
• The endemic Pine Mountain tigersnail, which is mostly associated with old growth

In addition, the Daniel Boone National Forest is home to old-growth and culturally  significant trees, such as the largest known Red Hickory tree, located in an old-growth forest in an area of the Redbird district that is marked for cutting.

If the Biden administration is to do all it can — and must — to limit atmospheric carbon levels, and demonstrate international leadership, these protections must be made through binding regulations that will endure in future administrations, much as the Clinton-era Roadless Rule has done. To ensure a rule can be adopted on the necessary urgent time frame, with the opportunity for robust public engagement and environmental review, it is critical for federal agencies to initiate a rule-making process as soon as possible that would prohibit logging in mature and old-growth forests.
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In summary, I urge the US Department of Agriculture and US Department of Interior to work together to soon initiate a rulemaking based on a definition of mature forests and trees as 80 years and older, to permanently end the avoidable loss of their critically important carbon, water, and wildlife values to logging.

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​Kentucky Heartwood has uncovered that the U.S. Forest Service lied about the location and impacts of a 2016 wildfire to justify logging 170 acres of unaffected forest in Long Hollow, an area of the Daniel Boone National Forest in Leslie County. The logging in Long Hollow is part of the roughly 4,000 acres of logging approved in the Daniel Boone National Forest as part of the South Red Bird Wildlife Enhancement Project.

​In the Environmental Assessment for the project, the Forest Service states that “More than 600 acres of forest in the South Red Bird IRMA were badly damaged from wildfire in 2016 and need to be salvaged to prevent insect invasion and disease,” including Long Hollow. The agency added that “The proposed salvage treatment would remove these fire-damaged trees, which are merchantable for about 5 years after the fire, after which their value declines rapidly. A healthy unburned forest of fire-resilient species is needed to regenerate the damaged stand.”

​The Forest Service included pictures taken of burned forest adjacent to the Steeltrap surface mine to illustrate the damage. Under the plan approved by the Forest Service, most of the standing trees in the steep and landslide-prone forest will be cut.

​The problem is that Long Hollow didn’t burn. 

​We scouted the area in May, following review of a report from the Office of Kentucky Nature Preserves (OKNP) that described Long Hollow as a significant conservation site. Kentucky Heartwood acquired the report through a Freedom of Information Act (FOIA) request to the Forest Service. The findings of the OKNP report were never included in the Environmental Assessment or other public documents related to the project. 

​The OKNP report stated that:
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“The Steel Trap area (including upper Long Hollow and abutting Jesse Fork) is of significant conservation importance in the project area. The mesic forests within the upper reach of Long Hollow contained the highest density of rare and Conservation Species within the project area including occurrences of butternut, ginseng, American chestnut, Goldie's wood fern, goldenseal, and large-tooth aspen. Additionally, a new population of downy goldenrod was discovered along the disturbed ridgetop that separates Long Hollow from the Steel Trap mining site. According to the Kentucky Plant Atlas project and USDA Plants Database, it is the first time this species has been documented in Leslie County.”

​During our survey of Long Hollow we found no evidence recent fire damage. In fact, we found that this north-facing valley consists of predominantly fire-intolerant, mixed-mesophytic species. With the exception of the dry ridges, the forest includes very few oaks or other fire-adapted species. We observed a significant population of Synandra hispidula, also known as Guyandotte Beauty, which is known to be highly sensitive to fire, logging, and other disturbances. The ecological indicators of the site strongly suggest that fire has not been a major factor in shaping the forest community. 

​Further review of FOIA documents uncovered a Forest Service map showing how the Steeltrap fire didn’t burn Long Hollow. That map was among a variety of documents associated with a private 2019 planning meeting jointly organized by the Forest Service and Rocky Mountain Elk Foundation. That invitation-only meeting was held to explore ways that hunting groups can work together to increase timber harvest in the Daniel Boone National Forest. 

​While Long Hollow is a relatively small part of an otherwise massive and deeply problematic logging project, the fact that the Forest Service so blatantly lied to the public to justify even more logging in the Redbird District is absolutely shocking. Their actions are dishonest and illegal and provide yet another window into how the Forest Service is rapidly moving to turn the Daniel Boone National Forest over to the timber industry and hunting organizations. 

​Kentucky Heartwood is continuing our work to stop the South Red Bird project, preparing litigation to protect the endangered species and old-growth forests directly threatened the project. Please consider supporting our efforts to protect these special places and the species that depend on them. You can support our efforts and sign up for emails here.