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We want to underscore that all natural climate solutions are important, but forests and forest products are uniquely so. To wit, the current
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
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
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.
First, we encourage
This would have important effects. It would help
Lastly, the application of these practices should be institutionalized and scaled with collaborative structures. We believe that
In partnership with The
Similarly, as leaders and members of the
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
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
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,
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
* 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
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
* Codifying the
* Leveraging the Wood Innovations Grant Program of the
* 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.,
* Creating a new federal matching grants program to support fire-focused forestry extension programs within western states modelled off
Environmental Justice and Disadvantaged Communities
Our comments in this section focus on the opportunity for
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.
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
Over the last 12 months, awareness and support has surged with unprecedented media coverage, in some cases generated by
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
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
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
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
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
We see an opportunity to go even farther by having
Use USDA Job Corps Civilian Conservation Centers and the new
Thank you for your consideration of our perspectives. We stand ready to support you in this important work.
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The notice can be viewed at: https://www.regulations.gov/document/USDA-2021-0003-0001
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