American Forests Issues Public Comment on USDA Notice

WASHINGTON, May 27 -- Jad Daley, president and CEO, and Leslie Jones, senior vice president for policy, at American Forests, Chicago, Illinois, have issued a public comment on the U.S. Department of Agriculture notice entitled "Request for Comments: Executive Order on Tackling the Climate Crisis at Home and Abroad". The comment was written on April 29, 2021, and posted on May 25, 2021:

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American Forests is pleased to submit our response to the request for input regarding the development of climate-smart agriculture and forestry strategy in response to President Biden's Executive Order on Tackling the Climate Crisis at Home and Abroad. We are grateful for the administration's immediate leadership on these issues in bold and innovative ways.

We want to underscore that all natural climate solutions are important, but forests and forest products are uniquely so. To wit, the current U.S. EPA Greenhouse Gas Inventory of the United States, prepared with data from the U.S. Forest Service Forest Inventory and Analysis Program, shows that more than 95 percent of carbon sequestration is occurring in the forest sector, sequestering the equivalent of 11 percent of U.S. greenhouse gas emissions. Research led by a team at The Nature Conservancy projects potential to nearly double the contribution of the forest sector, especially through actions such as reforestation that have strong carbon additionality.

It is vital that our investment in natural climate solutions, and even our narrative about them, reflects this unique importance. We are working hard to carry this message through our organization, and to organize forest stakeholders to collaborate with the federal government through coalitions such as the Forest-Climate Working Group (forestclimateworkinggroup.org) and U.S. Chapter of 1t.org (us.1t.org). As an example of the readiness in the U.S. forest community, the more than 50 partners in the U.S. Chapter of 1t.org have already pledged nearly 50 billion trees to be conserved, restored and grown by 2030, and billions of dollars in additional supporting actions such as nursery establishment, technology, climate finance, and workforce development.

With these comments, we highlight a set of opportunities for federal partnership, technical assistance, and investment impacting all lands. We also have specific suggestions for how to realign policy to maximize the contributions of the U.S. National Forest System to climate action, and to assure the long-term health and resilience of these precious public lands in the face of mounting stressors such as wildfire that are exacerbated by climate change.

Climate-Smart Agriculture and Forestry

Our lead principle for climate-smart agriculture and forestry (CSAF) is to be holistic. First, this requires adoption of a "carbon offense + defense" mindset. Forests provide the best carbon sequestration results when they are healthy and resilient. Therefore, we must integrate actions that are designed to increase the rate and amount of carbon sequestration, strategies traditionally known as "climate mitigation", with actions that will maintain a healthy and resilient forest, actions traditionally known as "climate adaptation." Because these adaptation actions will help protect carbon stores from being lost to mortality and wildfire, they are in effect "carbon defense". The end goal of climate-smart forestry should be resilient carbon sequestration, a strategy that will have the additional effect of maintaining the many other benefits such as wildlife habitat and water supplies that healthy and resilient forests can provide.

American Forests is proud to have co-authored an integrated menu of climate mitigation and adaptation practices in partnership with the U.S. Forest Service Northern Institute of Applied Climate Science (NIACS). This menu, entitled, "Practitioner's Menu of Adaptation Strategies and Approaches for Forest Carbon Management" was published in the Journal of Forestry in late 2019. (Link to this document can be found here: https://academic.oup.com/jof/article/118/1/86/5648951.) This encapsulates the approach that we believe USDA should prioritize going forward, with three additional recommendations.

First, we encourage USDA to continue refining and adapting this menu for the specifics of different geographies and forest landscapes. There is broad agreement within the forest community that "one size fits all" doesn't fit when it comes to climate-smart forestry. While this menu is set up to be adapted for any forest type or setting, there is still more that USDA can do to proactively lead this customization and downscaling. In fact, our partners at NIACS and the USDA Climate Hub in California have provided one strong example of this with a new California version of this menu. This should be replicated in other priority geographies with leadership from the USDA Climate Hubs.

Second, USDA should invest in research to quantify the expected carbon response from applying this menu, calibrating for these different practices on a per acre basis, and by other metrics where more appropriate. This could also be done a national level, using broad averaging, and then downscaled to specific forest types and geographies.

This would have important effects. It would help USDA to consider how to align its cost-share and incentive programs to support activities that have carbon benefits, and to calibrate payments to align with expected carbon benefits. This information would also help to influence other actions, from influencing decisions by public land managers and private landowners, and by influencing the investment of funds in these practices from other levels of government and from the private sector.

Lastly, the application of these practices should be institutionalized and scaled with collaborative structures. We believe that USDA has developed many of the best-in-class approaches to do this. The USFS Climate Change Response Frameworks are one such example. These landscape-scale collaborations have enabled very diverse public and private actors to come together, inform and refine science-based tools, and then apply this approach in a coordinated manner that promotes learning. Approaches such as the Climate Change Response Frameworks likley have application across the whole of government, including, for example, DOD and the Readiness and Environmental Protection Integration (REPI) program. Ultimately a model like this could drive policy and investment even more broadly than it already has. Other successful examples include the Pacific Northwest Climate Hub working with western public land managers to realign management for climate considerations, and the Adaptive Silviculture for Climate Change model led by various USFS collaborators. We would love to see these kinds of models applied comprehensively, with coordination to assure the right alignment and complementarity, and with the full level of investment needed to unlock their potential.

In partnership with The National Wildlife Federation and The Nature Conservancy, American Forests has developed recommendations for Revitalizing America's National Forests: Policy Recommendations for Restoring Forests to Deliver Natural Climate Solutions and Ecological Benefits (available at https://forestclimateworkinggroup.org/uncategorized/revitalizing-americas-forests/). We provide comments based on these recommendations under separate cover.

Similarly, as leaders and members of the Forest Climate Working Group (FCWG), American Forests joins other FCWG members in providing comment under separate cover. The FCWG has developed a policy platform, released in November 2020, which identifies four key interdependent strategies for realizing the potential of forests and forest products as climate solutions, strategies that should be embraced as USDA seeks to promote climate smart forestry that helps the U.S. achieve our ambitious climate goals. This platform can be found at https://forestclimateworkinggroup.org/resource/forest-climate-working-group-policy-platform-for-117th-congress/ Biofuels, Wood and other Bioproducts

American Forests believes strongly that diverse wood products can be part of natural climate solutions. This includes durable wood products, such as mass timber, more active use of forest products for packaging and other applications where they displace fossil fuel-based materials, and appropriate use of forest-based bioenergy.

For our organization, the keys to unlock this potential are quantification and innovation. Quantification is important to understand the carbon dynamics of different wood products scenario. An example is to understand the carbon profile of a product such as mass timber in a "forest to frame" modeling scenario that helps examine all of the variables in the forest and along the supply chain that together enable us to truly understand the carbon mitigation potential of any particular product in the context of the forest where the material will be drawn.

As an example of success, our organization has been working with the Canadian Carbon Budget Model (CCBM) to run scenario analysis for states in the U.S. Climate Alliance. This particular model is uniquely effective at integration of forest products into carbon scenario analysis, and our partners seem to be drawing important information from this analysis to help them assess active management and forest product utilization strategies in a carbon context. We would recommend a push through the USDA Climate Hubs and other relevant structures to help support more of this kind of modeling, using the CCBM and/or other models, across US forest landscapes.

We also see a vital role for innovation. There are many forest landscapes, particularly in the western states, where it does not feel as though we yet have the mix of wood utilization options, in the form of potential end uses, to match the forest material that will be generated by the management that is needed for goals such as wildfire risk reduction. An example of success is recent innovation to use wood nanoparticles as a way to displace other materials in the making of concrete. Continued research and innovation like this will be essential, and should ideally be tailored to the wood utilization needs of specific landscapes and settings.

Finally, on the subject of wood bioenergy, we think it is vital to create the correct decision frameworks to identify where this utilization scenario will lead to positive climate outcomes, and where it will not. As with the other items above, this includes the context of the forest where the material is drawn, or in some cases, the manufacturing processes from which the material is drawn as a byproduct. Each of these has scenarios has unique carbon efficiencies driven by the trajectory of the source forest and the different Green House Gas (GHG) mitigation profiles of different end uses--for example, the very different GHG profile of using woody material in large scale power stations versus community-scale combined heat and power.

Where we can identify clear climate mitigation pathways with bioenergy, such as community-scale heating as well as combined heat and power projects that tie to naturally productive forest types, USDA should continue to increase grant and cost-share opportunities that help get these pathways to scale. The USFS Community Wood Energy and Wood Innovation Program is one example of success.

Wildfire

Much has been written about the increasing risk and severity of wildfire. While largely focused on the west where the challenges are most acute, the risk of catastrophic wildfire is rising nationwide, including in the southeast and in diverse eastern landscapes such as New Jersey's Pine Barrens.

American Forests' organizational strategy to advance wildfire resilience across our nation's forests through climate-informed forestry, found here, is a comprehensive response to how USDA can use programs, partners, science and funding to address wildfire.

American Forests is calling for a forest wildfire policy framework that:

* Addresses, over the next 5 to 10 years, wildfire threats to communities and high-value infrastructure such as drinking water source areas,

* Focuses long-range landscape-scale prioritization, work planning and resource allocation over the next 10 to 20 years,

* Expands funding and capacity for cross-boundary public-private partnerships for large "all lands" projects,

* Ramps up development of science-management partnerships to advance climate-informed forestry, including the deployment of prescribed fire and managed wildfire at scale,

* Advances science-based climate-informed forest regeneration in fire scars,

* Creates a 21st-century forestry workforce to help our forests and communities adapt to climate change and find their capacity for resilience

At its heart, a national policy should direct coordination across all land ownerships and jurisdictions. To do so successfully USDA must work across agencies within USDA, including NRCS, Rural Development and Research, as well as through existing inter-agency initiatives such as the CFLRP and the Joint Chiefs Restoration Partnership.

The role of partners and stakeholders is vital. Here too, the groundwork is laid through mechanisms such as shared Stewardship agreements, CFLRP as well as diverse coalitions such as the Forest Climate Working Group. Please see Section 2 -Public Private Partnerships, for detailed recommendations, including:

* Codifying the USDA Joint Chiefs' Landscape Restoration Partnership (Joint Chiefs') in federal legislation

* Leveraging the Wood Innovations Grant Program of the Forest Service to support wood biomass market development in places capable of supporting projects within identified priority areas. Support State Wood Energy & Utilization Teams and parallel initiatives (e.g., Washington's Carbon Leadership Forum) to develop market development plans for identified priority areas.

* Advancing financing tools and contracting that de-risk investments in appropriately scaled and strategically located wood utilization facilities.

To increase the pace and scale of climate-informed forestry we will need continued development of science-management partnerships to advance climate-informed forestry principles, including to reduce threats of tree mortality, uncharacteristic wildfire, continued wildfire exclusion and vegetation type conversion post-fire. Section 3 of the Strategy and Policy Agenda lays out specifics including:

* Seeking opportunities to better integrate the work of existing climate-science institutions (e.g., USDA Climate Hubs and Department of the Interior Climate Adaptation Science Centers) directly to managers' decision-making, forest and land management planning and landscape-scale environmental analyses

* Creating a new federal matching grants program to support fire-focused forestry extension programs within western states modelled off Oregon's program; and encouraging targeting this additional capacity to private landowner engagement in identified priority areas.

Environmental Justice and Disadvantaged Communities

Our comments in this section focus on the opportunity for USDA to help overcome one hard reality: the fact that a map of tree cover in America's cities is most often also a map of income, and of race in ways that transcend income thanks so the effect of systemic racism such as redlining. We recommend that USDA align its programs to help achieve Tree Equity in America's cities.

It is hard to overstate the role of Tree Equity in environmental justice, climate justice, and health equity. Put simply, trees reduce localized air pollution and provide extremely effective reduction of urban heat islands. Neighborhoods without this natural asset face far greater health risks, including chronic illness and higher death rates, spending more on energy bills, lower property values, and many other inequities--all the result of not having equitable tree cover with other neighborhoods. American Forests has made this case concisely with Let's Commit to Tree Equity in American Cities & Let's Throw Cities Some Shade. Both pieces feature links to relevant science.

Urban forests not only save lives, but also can help save the climate. Urban forests account for more than 15 percent of sequestration via growth in U.S. forests (129 MMT CO2e per the 2020 EPA GHG Inventory). They also significantly lower carbon emissions by reducing energy use for cooling and heating by 7.2 percent nationally, saving consumers more than $7 billion and delivering significant avoided emissions benefits (Nowak et al. 2017).

Over the last 12 months, awareness and support has surged with unprecedented media coverage, in some cases generated by American Forests, touching major outlets including NPR, Washington Post, New York Times, Chicago Tribune, Bloomberg CityLab, and other outlets. The environmental justice and climate justice community, including frontline organizations, has embraced this intersection of interests with other conservation organizations, coming together to make Tree Equity part of the movement.

On November 17, American Forests established a new a data-driven standard to inform this work nationwide with the launch of Tree Equity Score. This national analysis integrates seven different types of data: tree canopy, population density, income, employment, race, age, and urban heat island. We model these data together to show where cities have the greatest urgency to invest in Tree Equity, based on the combination of low tree cover and heightened vulnerability factors. The Tree Equity Scores are at the city scale and also the neighborhood level, the latter of which we consider most essential for prioritizing investment.

We also have the ability to develop the Tree Equity Score Analyzer for interested jurisdictions, which enables all users to access a free online tool that allows them to explore Tree Equity Scores within each neighborhood, and to run scenarios that show how tree planting can be used to improve the Score for that neighborhood, and details on different outcomes for environmental justice, climate justice and public health.

Tree Equity Score will be complete for all urban areas across the U.S. by early June. We are sharing information about this tool, because we hope that it could be used by USDA and its partners to help understand the need for Tree Equity, and to help focus partnership, technical assistance, and federal investment to achieve this goal, consistent with the goals of the Justice40 initiative.

Urban forestry also presents unique career pathways for socially disadvantaged populations. Already public and private urban forestry employers, from city public works to tree care companies such as Davey, face thousands of vacant positions nationally. This will rise rapidly if urban tree planting and care is catalyzed with new public funding--each million dollars invested can support 25.7 direct, indirect, and induced jobs. We encourage USDA to lean into this opportunity with its different programs and capacities, as described in more detail below.

Key Recommendations for Tree Equity:

Expand USFS Urban & Community Forestry Program to fund Tree Equity implementation at scale, including funding for frontline organizations. The only dedicated urban forest program in the federal government, the Urban and Community Forestry Program is a technical assistance program with little grant making capacity for actual on-the-ground implementation relative to need for cities and their partners. We believe that USDA could help scale this program to address these needs with aggressive proposals in the President's Budget, with a portion of this enhanced funding clearly set aside to support tree planting grants aligned with Tree Equity as demonstration for more focused funding in the future.

Ideally, this scaling up should also be used to build capacity in community-based, frontline organizations that are leading tree planting, care, and protection in the highest need neighborhoods. While some NGOs, including American Forests, help to fund such organizations with grants, federal funding could be awarded directly to these important entities through the USFS Urban & Community Forestry Program under its existing purposes and authorities.

Engage other departments and agencies to enhance Tree Equity funding through their existing authorities. Many other parts of the federal government should be able to identify opportunities to increase their contributions toward urban tree planting and care within existing programs and dollars, using program criteria and other means to enhance the impact of existing programs on Tree Equity. This includes programs such as DOI Outdoor Recreation Legacy Program, DOT Transportation Enhancements and HUD Community Development Block Grants. One structure for doing this is the Interagency Trillion Trees Council established under Executive Order. This kind of leveraged funding and expertise across departments is right in alignment with the purpose behind this Interagency Council.

We see an opportunity to go even farther by having USDA work with the White House to catalyze an Interagency MOU to advance Tree Equity through federal programs. An Interagency MOU directing engagement from the most potentially relevant agencies--at minimum USDA, DOI, EPA, HUD, DOE, Transportation, HHS, and Labor--would catalyze identification and implementation of strategies to advance Tree Equity through existing programs and authorities. Such an MOU should prioritize environmental and climate justice considerations including air quality, heat island mitigation, reducing energy burden, and enhanced shading for heat-resilient housing and active transit (e.g., shading trails and bus stops), as well as the climate action potential in urban forests through carbon sequestration and energy savings.

Use USDA Job Corps Civilian Conservation Centers and the new Civilian Climate Corps and to enhance Tree Equity career pathways and access to them. The 24 USDA Job Corps CCCs are well positioned to dramatically ramp up training of youth in at-need populations nationwide, and could do even more to train the workforce of the future for Tree Equity. Today, just 4 of 24 USDA Job Corps CCCs provide urban forestry training opportunities. We expect much greater demand, especially if federal investment in on-the-ground implementation scales up in the ways we have recommended. We recommend that USDA dramatically broaden opportunities within these Centers.

The new Civilian Climate Corps can also help. American Forests is currently standing up new Tree Corps in cities, working with partners such as TAZO and Davey Tree Expert Company, and have seen the ready workforce waiting for these opportunities. We encourage USDA to build urban-focused opportunities like this into the development of the new Civilian Climate Corps. We stand ready to help USDA identify the needs that these Corps can meet in urban forestry, and potentially even align our programs to serve as matching private dollars and capacity.

Thank you for your consideration of our perspectives. We stand ready to support you in this important work.

Jad Daley, CEO & President, [email protected]

Leslie Jones, SVP for Policy, [email protected]

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The notice can be viewed at: https://www.regulations.gov/document/USDA-2021-0003-0001

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