To: The Honorable John Kerry, U.S. Special Presidential Envoy for Climate
Cc: The Honorable Tom Vilsack, United States Secretary of Agriculture
The Honorable Deb Haaland, United States Secretary of the Interior
The Honorable Brenda Mallory, Council on Environmental Quality
John Podesta, Senior Advisor to the President for Clean Energy Innovation and Implementation
Ali Zaidi, Assistant to the President & National Climate Advisor
Date: March 16, 2023
Re: Mature Forests and Trees Must Be Protected to Meet Key International Commitments
_______________________________________________________________________________________________
The Honorable John Kerry,
To credibly advance the Biden administration’s domestic and international climate commitments,
the U.S. Forest Service and Bureau of Land Management need to promptly initiate a rulemaking
conserving mature and old-growth forests and trees on federal lands from logging. Such a rule
would implement a core promise of President Biden’s Executive Order 14072. It would
demonstrate the government’s commitment to using every available tool to fight the climate crisis.
It would meaningfully contribute to the last 10-12 percent of President Biden’s target of reducing
net greenhouse gas emissions 50-52 percent by 2030. It would go hand-in-hand with the
administration’s other forest conservation efforts—such as the steps taken to protect the Tongass
National Forest—to concretely show U.S. international leadership on forest conservation, including
on issues of active negotiation such as 30×30. It can be done administratively this presidential term.
And, done right, it would be durable into future administrations.
As international climate organizations that represent over 19 countries and members, we urge you
to work with your colleagues across agencies and the White House to ensure that these domestic
actions take place. Initiating a rulemaking that presumptively conserves mature and old-growth
forests and trees on federal lands would strongly signal to other nations the U.S. commitment to
climate action. As the administration continues to address the threat posed by uncharacteristically
severe wildfire, it must take decisive action on protecting our climate-critical mature forests from
logging. And it could readily act as a domestic counterpart to specific international initiatives, such
as joint action with the Lula administration to protect the Amazon.
America’s mature and old-growth forests and trees play an irreplaceable role in the fight against
the climate crisis. No human-made technology can match such forests for their ability to remove
and store carbon pollution from the atmosphere at scale. They also buffer key ecosystems from
continued biodiversity loss, protect critical drinking watersheds for communities across the
country, and provide increasingly scarce high-quality outdoor recreation experiences. Mature and
old-growth forests in much of the United States have been eliminated, but federal lands still contain
important expanses. And those mature forest expanses account for most carbon storage on federal
lands.
These forests and trees can contribute maximally to U.S. climate goals only if they are protected
from logging. Logging releases stored carbon, eliminates the older trees’ ability to sequester
additional carbon, and damages the other ecosystem services and biodiversity values these forests
uniquely provide. Unfortunately, though older forests and trees are in public hands, they continue
to suffer ongoing degradation from logging, often at taxpayer expense.
And such action need not come at the expense of managing uncharacteristically severe wildfire. We
welcome the administration’s recent efforts to address wildfire, including the directive to protect
mature and old-growth forests in such management. Logging, however, remains the largest threat
that is wholly under agency control. And protections for these climate-critical forests and trees
from logging are a necessary complement to the administration’s wildfire efforts.
As other nations decide how thoroughly to join the existential climate fight, they will be watching
what happens to these remaining federal forests. Business-as-usual logging will thus not only
reduce U.S. climate gains, it will also undermine international credibility on both climate and forest
conservation. Conversely, effective regulatory protections from logging for federal mature and oldgrowth trees and forests would demonstrate leadership on forest conservation, strengthen U.S.
international climate negotiators’ positions, and significantly advance key international
commitments that the Biden administration has made (such as the Nation’s updated Nationally
Determined Contribution and the Roadmap for Nature-Based Solutions). The Glasgow Climate Pact
notes the importance of ensuring the integrity of forests and emphasizes “protecting, conserving
and restoring nature and ecosystems to achieve the Paris Agreement temperature goal, including
through forests . . . acting as sinks and reservoirs of greenhouse gases.” Furthermore, the U.S.
committed in the Glasgow Leaders’ Declaration on Forests and Land Use to “strengthen” its effort to
“[c]onserve forests and other terrestrial ecosystems and accelerate their restoration.” And the
Biden administration commended the outcome of COP15, which emphasized the importance of
intact ecosystems for their higher biodiversity and climate values.
Regulatory protections for mature and old-growth forests and trees would also help the U.S. meet
the commitments it has made internationally to advance the interests of Indigenous peoples. At
COP26, the U.S. committed to “renewed collective and individual efforts to further recognize and
advance the role of Indigenous Peoples and local communities as guardians of forests and nature.”
Both the Affiliated Tribes of Northwest Indians and the National Congress of American Indians have
adopted resolutions calling on the United States government to initiate a rulemaking to protect
mature and old-growth forests and trees on federal forestlands from logging. Pursuing these
protections in a way that helps honor key Tribal interests would concretely demonstrate the
renewed effort the government has pledged.
The recent COP27 Sharm El-Sheikh Implementation Plan re-affirmed parties’ commitment to
limiting warming to 1.5 degrees Celsius; this decade is our last chance to hold that line. But we can
no longer leave potential gains on the table. The Biden administration must promptly advance all
agency actions that will help the U.S. and world reach their goals expeditiously.
A durable regulation presumptively conserving mature and old growth trees and forests from
logging is one of the most cost-effective and immediate impact options the administration can take
to protect the U.S. and the world from climate impacts while also strengthening and advancing
international forest conservation commitments. Our organizations ask that you work with your
agency and White House colleagues to start a rulemaking as soon as possible.
Thank you very much for considering our request on this extremely pressing question.
Sincerely,
Agent Green
Abibinsroma Foundation
AJESH
Australian Forests and Climate Alliance (AFCA)
Centre for Econics and Ecosystem Management, Eberswalde University for Sustainable
Development
Coastal Plain Conservation Group
Comité Schone Lucht
Congo Basin Conservation Society CBCS
Conservation North
Earth Ethics, Inc.
Earth InSight
Earthjustice
Environment America
Environmental Investigation Agency
Environmental Protection Information Center
Foreign Policy for America
Foundation Conservation Carpathia
Foundation Earth
Friends of ZOKA
Fundación Gaia Amazonas
Hip Hop Caucus
International Conservation Fund of Canada
Leefmilieu
Natural Resources Defense Council
Nature Nova Scotia
Old-Growth Forest Network
Oxfam America
Re:wild
Save Estonia’s Forests (Päästame Eesti Metsad)
Sierra Club BC
Stand.earth
Strong Roots Congo
The Australian Rainforest Conservation Society
The Lifescape Project
The Samdhana Institute
The Woodland League
Wild Europe Foundation
Wild Heritage
Wildland Research Institute
Wildlife Conservation Society
Women’s Earth and Climate Action Network (WECAN)