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Tuesday, 11 May 2021
USDA “Climate-Smart Forestry”


Recently, the US Department of Agriculture issued a call for public input on “climate-smart forestry,” including ways the agency can “utilize programs, funding and financing capacities, and other authorities, to encourage the voluntary adoption of climate-smart forestry practices.”

This clearly represents an exciting new opportunity for FSC to become an important component of US government policy on forestry. In response to this call, FSC US submitted the letter below. As climate-smart forestry is a rapidly evolving area of focus, we would welcome input on the letter from interested stakeholders. Please send any comments or questions to Brad Kahn (b.kahn@us.fsc.org).

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Seth Meyer
Chief Economist
Office of the Chief Economist
U.S. Department of Agriculture
Docket Number: USDA-2021-003
Submitted via Regulations.gov

April 29, 2021

Dear Mr. Meyer:

I write today on behalf of the US-based members and certified companies of the Forest Stewardship Council (FSC) to submit our comments on Climate-Smart Forestry. Specifically, we are offering high-level framing recommendations related to question 1A, how should USDA “encourage the voluntary adoption of climate-smart forestry practices?”

The Forest Stewardship Council is the world’s most trusted forest certification system, representing consensus between economic, environmental, and social interests on responsible forest management for more than 25 years (see US member list on the last page). This experience is directly relevant to USDA’s efforts related to climate-smart management of working forests across the United States.

While it is well established that forests and forestry management policies can have a significant impact on climate, the underlying science and knowledge base is still nascent and continues to evolve. Given this dynamic, it is critical to have vehicles by which consensus can be achieved between diverse interests to continually fine-tune efforts as new scientific understanding comes into view. FSC is a leading means by which to accomplish this.

In addition, peer-reviewed research (source: https://www.mdpi.com/1999-4907/9/8/447/htm) finds that FSC-certified forests in Oregon and Washington stored an average of 29 percent more carbon than those managed to regulatory requirements alone. FSC requires larger buffers along waterways, more tree retention within openings, and more habitat protections and age-class diversity, among many other requirements, which research shows correlates with both increased resilience (adaptation) and carbon storage (mitigation). In short, FSC is a good proxy for “climate-smart forestry” in the U.S.

As the federal government looks to implement “effective climate-smart solutions in forests,” it is important to keep the following high-level points in mind:

  • Climate-smart forestry protects all forest values, as forests are much more than stores of carbon alone. This includes water, biodiversity, social and cultural values, and much more. As climate change accelerates and its impacts on forests increase, it is important to apply the precautionary principle. Specifically, where the science is not yet settled on the best course of action, we should pursue a path that is most protective of forest values. This also includes using USDA policies and incentives to discourage forest conversion, whether from a natural forest to a plantation or to a non-forest use.
  • Climate-smart forestry considers both mitigation and adaptation across all forests in the United States. We need forest management that helps reduce the risks associated with climate change by sequestering more carbon, while also making forests more resilient to the changes already present and anticipated in the future. Across all forested regions of the U.S., there are opportunities to store additional carbon, reduce forest-sector emissions, and at the same time improve the resiliency of forests and protections for the breadth of values addressed above. For example, a large and growing body of scientific research demonstrates that older trees and forests store more carbon and are more resilient to disturbances (e.g., wildfire) while maintaining the flow of wood and fiber into the marketplace.
  • Climate-smart forestry must foster and reward practices that go well beyond conventional forestry, generally defined by regulatory requirements. The status quo is what gave us the climate crisis, so we need performance that is well above conventional to tackle the challenges ahead. To the extent that the USDA and other agencies are incentivizing climate-smart practices through grants programs or other incentives, the agency should recognize forest managers who are already doing truly exemplary work, differentiating incentives for those managers whose current practices merely meet regulatory requirements. This should include unique incentives for forest managers who are already implementing exemplary and beneficial management practices, rather than equating them with those who may wish to initiate such practices anew.
  • Climate-smart forestry respects the rights of Indigenous Peoples by requiring Free, Prior and Informed Consent before management activities take place on lands where they have formal or customary rights. In many cases, Indigenous Peoples have been managing their forests for thousands of years, offering many valuable lessons that could be applied more broadly. In addition, Indigenous Peoples have used lands outside their legal tenures for thousands of years. Many of these lands include sacred sites, cultural uses and other important traditional values which should be recognized and respected where federal funds are used to advance climate-smart forestry.
  • Climate-smart forestry creates meaningful ways for frontline communities and other stakeholders to impact decisions about forest management that affects their quality of life, including cultural, recreational, and other traditional uses of forests. This means thinking at a landscape scale and creating opportunities for engagement with impacted stakeholders. Currently, engagement with affected stakeholders is required on public, but not on private, lands. Where USDA is incentivizing climate-smart forestry, public engagement should be required whether the lands in question are public or private.

We believe the principles above should apply on federal lands, and on private lands where federal funds are used to promote climate smart forestry. Adherence with these principles may be effectively demonstrated through FSC-certification, including on National Forests. To that end, the Forest Stewardship Council is excited to engage with the US Department of Agriculture to explore the prospects for FSC certification of National Forests, both to advance Climate-Smart Forestry and to support market recognition for exemplary management by the U.S. Forest Service.

We sincerely appreciate the opportunity to submit these comments to the U.S. Department of Agriculture. Climate change is an urgent existential concern for forests across the U.S., and for the people and wildlife that depend upon them. While the private marketplace continues to help address forest management challenges, given the profundity of the climate challenge we face, the federal government has an indispensable role to play in identifying and incentivizing Climate-Smart Forestry.

On behalf of the Forest Stewardship Council, we stand ready to help support your efforts. Please don’t hesitate to call upon me if we can be of any assistance.

Sincerely,
Corey Brinkema
President