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32 FFCC Members Call on Obama Administration to Recognize Importance of Tongass NF


Thirty-two Federal Forest Carbon Coalition (FFCC) Members signed the following letter on recognizing, conserving, and increasing carbon stores on Tongass National Forest in Alaska. The FFCC has a national focus and normally does not comment on forest specific issues. However, we believe it is appropriate for the FFCC to weigh in this issue because the Tongass holds by far the most carbon of any national forest in the U.S. and because the right decisions and actions there can provide a model for forest carbon management on other forests nationwide. 

The letter was sent to the listed officials on Tuesday January 20.

Read the Letter (below)   |   See the list of Signatories  

Read the Federal Forest Carbon Coalition (FFCC) Tongass Sign-On Letter below or access a PDF of the letter here.

January 20, 2015

Secretary Tom Vilsack 

U.S. Department of Agriculture

1400 Independence Avenue SW Washington, DC 20250

cc: President Barack Obama, Robert Bonnie (USDA Undersecretary), Beth Pendleton (Tongass National Forest), Forrest Cole (Tongass National Forest), Mike Boots (CEQ), Jason Anderson and Lynn Jungwirth (Tongass Advisory Committee)

Re: Importance of the Tongass National Forest in Climate Change Remediation

Dear Secretary Vilsack:

The Federal Forest Carbon Coalition (FFCC) is a broad-based national coalition that is encouraging federal forest management agencies to manage forests in ways that protect the Earth’s climate. We focus on minimizing the release of greenhouse gas emissions, optimizing carbon sequestration, and generating co-benefits from forests in just and equitable ways. FFCC is especially interested in linking the Obama Administration’s climate change policies to protection of forest carbon stores and climate resilience on the national forests especially as it pertains to the Tongass Land Management Plan (TLMP) amendment.

The Tongass National Forest is by far the nation’s champion in storing carbon long-term as its “high-biomass [older] forests” contain over ten times the carbon stores as the next highest national forest, the Willamette in Oregon[1]. Despite these high carbon values, Tongass climate change planning lags behind that of other national forests. Continued logging of the carbon dense old-growth rainforests on the Tongass is not only inconsistent with modern management of other national forests, but runs directly counter to the Obama Administration’s climate change goals.

We provide several science-based considerations and recommendations on climate change planning to bring the TLMP amendment process in line with the administration’s climate change policies.

Align the Tongass Land Management Plan Amendment process with existing climate directives and documents:

  • Instruct the Forest Service to link the protection of nationally significant forest carbon stores on the Tongass to President Obama’s November 1, 2013 Executive Order #13653 on climate change; the 2013 Forest Planning Rule’s increased emphasis on reducing carbon flux and protecting carbon stores; the Secretary’s explicit recognition of the Tongass’ global significance as the nation’s most carbon-rich national forest; the President’s State, Local, and Tribal Leaders Task Force on Climate Preparedness and Resilience[2]; and the UN resolution on slowing global deforestation by 2020 and ending it by 2030 that was also signed by the Obama Administration[3].
  • In accordance with new CEQ guidance on greenhouse gas emissions, limit emissions from land-use (i.e., logging) activities[4] on the Tongass. Doing so would put the Tongass on track with other national forests and with CEQ’s draft NEPA guidance.

Direct the Forest Service to prioritize climate change during the TLMP amendment process via the following specific actions:

  • End industrial logging of high-biomass, old-growth Tongass rainforests by 2020 as independent analysis shows there will be ample second growth by then to maintain a viable timber industry[5].
  • Require that the TLMP amendment display carbon flux by alternatives per new CEQ guidance.
  • Estimate social and ecological costs of net carbon flux from logging as compared to timber economic benefits.
  • Have carbon flux and carbon stores be an explicit decision criterion in the Record of Decision (ROD) and ensure the ROD is in compliance with the President’s climate action plan.
  • Ensure the Tongass National Forest has access to adequate staff and expertise to perform the carbon analyses listed above, integrate the analytical findings into the TLMP, and take appropriate actions to accomplish carbon-related goals.

 Additionally, we ask that you recognize or pursue the following points:

 Climate change impacts in Alaska highlight the need for immediate action

 We note that the impacts of human-caused climate change are scientifically indisputable and Alaska is already experiencing some of the most rapid and severe changes in the world. For instance, during the past thirty years, Alaska has experienced sharp reductions in snow-cover extent and duration, shorter river- and lake-ice seasons, melting glaciers (e.g., Mendenhall Glacier in Juneau), sea-ice and permafrost retreat, increased depth of summer thaw, and displacement of aboriginal villages from traditional lands[6]. Dieback of Alaska yellow-cedar has been documented in southeast Alaska and coastal BC, triggered presumably by exposure of shallow-root systems to late winter freezes and less snow pack[7]. Actions taken now should explicitly address such issues to avoid exacerbating consequences for Alaska’s natural resource-based economies as temperatures are projected to increase by another 2.4 to 4.6° C by mid-century[8].

Optimization of the amount of carbon stored on the Tongass would yield important co-benefits related to forest resiliency, biodiversity, and climate refugia

Notably, the Secretariat of the Convention on Biological Diversity, citing unanimous scientific support, stated that the capacity of forests to resist change, or recover following disturbance, is dependent on biodiversity at multiple scales[9]. There is widespread evidence from around the world that bio-diverse, primary (unlogged) forests are more resilient to human-caused disturbances and store 30-70% more carbon than managed or plantation forests[10]. Moreover, maintaining carbon stores in older forests is also associated with high levels of biodiversity and ecosystem services[11] and, therefore, optimizing carbon management would achieve multiple-use objectives. 

The Tongass may also function as a climate refuge since maritime influences may moderate extreme climate changes of the Alaska interior and further south[12]. Its relatively intact watersheds are most likely to be resilient to climate change[13], provide refugia for old-growth dependent species (including many that are important to subsistence use), and are strongholds for long-term carbon storage. Projections of net carbon flux from logging scenarios on the Tongass over a 100- to 200-year period showed that only a no-harvest scenario maintained carbon stores indefinitely[14]. Additionally, we note that there is overwhelming scientific support around this notion of the Tongass as a climate refuge and its globally important carbon stores as evidenced by the hundreds of scientists (October 31, 2014 and January 15, 2015), and professional scientific societies (January 15) that have sent similar letters to you commenting on the TLMP amendment process.

Explore potential economic benefits of carbon storage

Forgoing logging of high-biomass, old-growth forests would yield significant economic benefits by avoiding the social costs of carbon dioxide pollution. For instance, if carbon were optimized by protecting high-biomass forests on the Tongass it has been estimated that the potential annual economic value of carbon sequestration would be comparable to revenue generated from timber sales historically should markets for carbon emerge (ibid #14). Further, while total flux from proposed logging is unknown at this time, the Office of Management and Budget has estimated that the social cost per ton of carbon dioxide emitted into the atmosphere will be $12-109 (2007 dollars) for emissions in 2015, rising to $27-221 for emissions in 2050[15]. Considerable scientific evidence, however, suggests the actual social cost of carbon is much higher[16]. We urge the Forest Service to estimate the cost of carbon dioxide pollution from logging and the benefit of carbon stores in choosing an alternative that optimizes carbon stores and minimizes social costs.

Encourage carbon offsets in Southeast Alaska

Optimizing the amount of carbon stored on the Tongass would not only avoid large social costs, it also would create new opportunities for generating revenue. Southeast Alaska’s unique old-growth rainforests can become an incubator of market-based carbon offsets. The Forest Service could hasten developing carbon markets by choosing a TLMP alternative based on minimizing net carbon flux (i.e., preferring second growth over old-growth logging), and support more carbon-neutral forest management by partnering with native Alaskan corporations that are considering carbon offsets on their own lands (e.g., Sealaska). Thus, you have the potential to demonstrate more carbon-neutral forestry that could expand beyond the Tongass. The Forest Service would be prudent in highlighting the globally significant carbon stores in old-growth forests as one of the primary reasons for protecting these forests for their climate, subsistence, fisheries, and associated economic benefits.

The Tongass is our only national forest that is still practicing clearcut logging of old-growth forests. By connecting Tongass forest planning to national, regional, and global imperatives to optimize carbon, and by ensuring the TLMP planning process puts these imperatives into practice, the President can demonstrate to the world our nation’s commitment to climate change remediation. Given the global significance of Tongass carbon stores and the urgent need for climate change mitigation via responsible forest carbon management, designating special protections for Tongass old-growth rain forests through the current land management plan amendment is critical.

The FFCC members whose organizations are listed below support the contents of this letter.


Federal Forest Carbon Coalition Members

Bob Doppelt, Executive Director, The Resource Innovation Group and Co-Chair, Federal Forest Carbon Coalition

Ernie Niemi, President, Natural Resource Economics and Co-Chair, Federal Forest Carbon Coalition

Jim Furnish, Forest Service Deputy Chief NFS (Ret.) and Senior Advisor, Federal Forest Carbon Coalition 

Kristen Miller, Conservation Director, Alaska Wilderness League

Heather MacSlarrow, Lands Director, Colorado Mountain Club

David Graves, GIS Specialist, The Columbia River InterTribal Fish Commission

Dave Werntz, Science and Conservation Director, Conservation Northwest

Thomas Wheeler, Legal Coordinator, EPIC- Environmental Protection Information Center

Paul Hughes, Executive Director, Forests Forever

Dominick A. DellaSala, Ph.D., Chief Scientist/President, Geos Institute

Shelley Silbert, Executive Director, Great Old Broads for Wilderness

Sandy Shea, Board Secretary, High Country Conservation Advocates

Valerie Serrels , Kids vs. Global Warming/iMatter

Kimberly Baker, Executive Director, Klamath Forest Alliance

Katie Craney, Conservation Coordinator, Lynn Canal Conservation

Niel Lawrence, Alaska Project Director, Natural Resources Defense Council

Philip Fenner, Board Member, North Cascades Conservation Council

Shelley Spalding, Olympic Forest Coalition

Doug Heiken, Conservation and Restoration Coordinator, Oregon Wild

Greg Haller, Conservation Director, Pacific Rivers Council

Michael Kellett, Executive Director, RESTORE: The North Woods

Jimbo Buickerood, San Juan Citizens Alliance

Athan Manuel Director, Lands Protection Program, Sierra Club

Malena Marvin, Southeast Alaska Conservation Council

Alan R.P. Journet Ph.D., President and Co-facilitator, Southern Oregon Climate Action Now

Stanley Petrowski, President/Director, South Umpqua Rural Community Partnership

Joseph Patrick Quinn, Conservation Chair, Umpqua Watersheds, Inc.

Tammy Belinsky, Chair, Virginia Forest Watch

Bryan Bird, Program Director, WildEarth Guardians

John Sztukowski, Wildlands Conservation Coordinator, Wild Connections

Susan Jane M. Brown, Staff Attorney, Western Environmental Law Center

Paul Ruprecht, Western Watersheds Project

[1]Derived from published carbon stores in Krankina et al. 2014. High biomass forests of the Pacific Northwest: who manages them and how much is protected? Environmental Management. DOI 10.1007/s00267-014-0283-1

[3]Forest action statements and action plans. Climate Summit 2014. UN Headquarters, NY, 23 September, #CLIMATE2014.

[5]Mater, C. 2014. Transitioning to a second growth strategy in SE Alaska POW region. Mater report update based on 2014 GIS analysis. Available from Mater Ltd, Corvallis, OR.

[6]Alaska Department of Environmental Conservation. 2010. Final report submitted by the adaptation advisory group to the Alaska Climate Change Sub-Cabinet.

[7]Hennon, P. E., et al. 2012. Shifting climate, altered niche, and a dynamic conservation strategy for yellow-cedar in the North Pacific Coastal Rainforest. Bioscience 62:147-158.

[9]Secretariat of the Convention on Biological Diversity. Forest resilience, biodiversity, and climate change: a synthesis of the biodiversity/resilience, stability relationship in forest ecosystems. CBD Technical Series No. 43. UNEP

[10]Mackey B., et al. 2014. Policy options for the world’s primary forests in multilateral environmental agreements. Conservation Letters DOI: 10.1111/conl.12120

[11] Brandt, P., et al. 2014. Multifunctionality and biodiversity: Ecosystem services in temperate rainforests of the Pacific Northwest, USA. Biological Conservation 169: 362–371.

[12]DellaSala, D.A. et al. in press. Climate change may trigger broad shifts in North America’s Pacific coastal rainforests. Online module – Earth Systems and Environmental Sciences – published by Science Direct.

[13]For examples, see Watson, et al. 2013. Mapping vulnerability and conservation adaptation strategiesunder climate change. Nature Climate Change 3:989-994.

[14]Leighty, W.W. et al. 2006. Effects of management on carbon sequestration in forest biomass in southeast Alaska. Ecosystems 9:1051-1065.

[15] Interagency Working Group on Social Cost of Carbon, United States Government. 2013. Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis – Under Executive Order 12866. May.

[16] Pizer et al. 2014. Using and improving the social cost of carbon. Science 346:1189-1190. DOI:10.1126/science.125974

Meredith Herr,
Jan 19, 2015, 3:50 PM