February 23, 2015 Council on Environmental Quality 722 Jackson Place NW Washington, DC 20503 Email: guidance@ceq.eop.gov Re: Revised Draft CEQ Guidelines on Greenhouse Gas (GHGs) Emissions and Climate Change in NEPA Analysis Dear Mr. Greczmiel: On behalf of the Federal Forest Carbon Coalition (FFCC), we ask that you consider these comments on the Revised Draft CEQ Guidelines on Greenhouse Gas (GHGs) Emissions and Climate Change in NEPA Analysis, and incorporate them into CEQ’s development of final guidelines. The Federal Forest Carbon Coalition (FFCC) is a broad-­‐based national coalition of 69 organizations that is encouraging federal 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 federal forests in efficient and equitable ways. The FFCC includes national, regional and local organizations focused on forests conservation, biodiversity, fisheries, rivers, faith and spirituality, Native American treaty rights, youth, rural communities, recreation, and climate disruption. It also includes an advisory panel of leading forest-­‐carbon and forest-­‐
management scientists. The FFCC is especially interested in linking climate change policies to protection of forest carbon stores and climate resilience on forests managed by the Forest Service, Bureau of Land Management, National Park Service, and Fish and Wildlife Service. Accordingly, we commend CEQ for developing guidance for federal decision makers in compliance with existing NEPA principles and President Barack Obama’s November 2013 climate change executive order. We recommend that, as CEQ take all appropriate steps to ensure that actions affecting federal forests fully account for the effects on atmospheric carbon dioxide. Specifically, the accounting should show the effects on: • Atmospheric carbon dioxide. • The amount of carbon stored in federal forests,. • The rate of carbon sequestration by federal forests. • The environmental co-­‐benefits of forest-­‐carbon, such as clean water and habitat for aquatic species. • The economic costs of actions that increase atmospheric carbon dioxide and the economic benefits of actions that decrease atmospheric carbon dioxide. • The socio-­‐economic impacts on communities, including impacts associated with relationships between atmospheric carbon dioxide and temperature, weather, sea level, ocean acidification, threats to species, and changes in ecosystems. A broad-based national coalition that encourages federal forest management agencies to manage forests in ways that
protect the Earth’s climate.
www.forestcc.org
We have attached the FFCC’s Federal Forest Carbon Report Card: An Urgent Call to the Obama Administration to Modernize Federal Forest Management to Mitigate and Prepare for Climate Disruption. This Report Card can be useful to you insofar as it provides information in these four areas: I. The Role of Federal Forests in Mitigating and Preparing for the Climate Crisis Forests are the lungs of the Earth and have helped regulate global carbon for millennia. Excessive logging, road building, and other development activity have reduced the amount of carbon stored in America’s forests. Most of that carbon has been released into the Earth’s atmosphere where it contributes to global climate change. If forests are not managed to maintain their existing stocks of carbon and optimize additional carbon stores, climate change will grow much worse. However, with careful science-­‐based management, U.S. forests can help mitigate climate change, become more resilient to its affects, and generate numerous economic, social and ecological benefits. Federal forests, in particular, must play a leading role. The annual carbon emissions of the U.S. were 6.5 billion metric tonnes in 2012. National Forests in the U.S. hold more than 10 billion metric tonnes of carbon, which means they store about 50 percent more carbon than annual U.S. emissions.i Every possible action must be taken to prevent these existing stocks of carbon from being released into the atmosphere. If the right policies and practices are adopted, federal forests can store even more carbon. These actions will help minimize the likelihood of uncontrollable climate change. They will also offer a much-­‐needed exemplary model that state and private forest in the U.S., and forests managers worldwide can emulate to manage forest carbon. We recommend that, in its final guidance, CEQ highlight the importance of federal forests’ effects on atmospheric carbon as a concern that must be addressed in NEPA analysis. II. Three Case Studies Reveal the Failure of Federal Agencies to Manage Forest Carbon to Reduce the Risks of Uncontrollable Climate Disruption To protect the climate and serve as a role model, federal agencies must grasp how urgent it is to act now to maintain existing stores of carbon and increase the amount of carbon stored in federal forests. Our research has found, however, that federal forest managers fall far short of this imperative. In response to a request from federal officials for examples of how carbon is being managed in the field, in 2014 FFCC Senior Policy Advisor and Retired Deputy Chief of the Forest Service, Jim Furnish, with assistance from FFCC staff, completed a brief survey of National Forests. We found that, contrary to the urgency of responding to the climate crisis, the U.S. Forest Service is taking few, if any, meaningful on-­‐the-­‐ground actions to maintain existing stocks and A broad-based national coalition that encourages federal forest management agencies to manage forests in ways that
protect the Earth’s climate.
www.forestcc.org
increase the carbon stored in the nation’s 155 National Forests. We believe this failure is systemic. Our research found that the National Forest system has not: • Established an explicit goal of maintaining and increasing forest carbon on each forest. • Analyzed the quantity of carbon in specific forest locations or the implications for those stocks of different management options when completing environmental assessments, forest plans, or proposals for field projects. • Required that the effects on existing and future stores of carbon be considered in all decision-­‐making; to the contrary, often carbon is not even mentioned as a consideration. We recommend that CEQ recognize the current failure of federal forest managers to take meaningful steps to account for the impacts of their actions on forest carbon, or to manage forest carbon in a manner that optimizes its contributions to limiting the effects of climate change. III. Recommendations for Modernizing Federal Forest Management to Mitigate and Prepare for Climate Change Based on our analysis of the current state of the science of forest carbon management, the FFCC believes that federal forests should modernize their policies, regulations, planning processes, management programs and practices in accordance with the following six goals: Goal I: Recognize Carbon as a Significant Public Resource and Establish Carbon and Climate Change-­‐Centered Goals for All Decisions Affecting Federal Forest Management. Goal II: Maintain the Existing Stocks of Carbon on Federal Forests, Including Carbon in Live and Dead Materials, Above and Below Ground. Goal III: Increase the Amount of Carbon Stored in Federal Forests. Goal IV: Enhance, Consistent with Goals I, II, and III, the Resilience of Federal Forests to Climate Change-­‐Related and Other Natural Disturbances. Goal V: Generate Social, Economic, and Ecological Benefits Consistent with Goals I, II, III, and IV. Goal VI: Fully Account for the Benefits and Costs of Any Decreases or Increases in Atmospheric Carbon and Other Greenhouse Gasses in All Forest-­‐Related Policies, The Report Card provides detailed recommendations for accomplishing each of these goals. We recommend that, in the final Guidelines on Greenhouse Gas (GHGs) Emissions and Climate Change in NEPA Analysis, CEQ provide federal forest managers with guidance for accomplishing these goals. A broad-based national coalition that encourages federal forest management agencies to manage forests in ways that
protect the Earth’s climate.
www.forestcc.org
IV. Checklist for Managing Federal Forest Carbon The Report Card offers a checklist of the issues federal forest management agencies should address to manage forest carbon in a scientifically credible manner. We recommend that CEQ incorporate these issues in its guidance for NEPA analysis of actions affecting federal forests. In sum, we recommend that CEQ draw on the FFCC’s Report Card to ensure that federal forest managers understand their obligation to account fully for the effects of their actions on forest carbon and atmospheric carbon dioxide, take appropriate steps to optimize the forests’ ability to remove and withhold carbon dioxide from the atmosphere, and explain to the public the full slate of consequences of actions that would increase or decrease atmospheric carbon dioxide. If you have any questions, please feel free to contact us. Sincerely, 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 i U.S. Forest Service, Forest Inventory and Analysis National Program. 2013. ”Total Carbon Storage in U.S. Forests by State and Ownership Group.” http://www.fia.fs.fed.us/Forest%20Carbon/methods/docs/Total%20forest%20carbon20130717.xlsx; Environmental Protection Agency. 2014. “National Greenhouse Gas Emissions Data.” EPA. Found at:http://www.epa.gov/climatechange/ghgemissions/usinventoryreport.html A broad-based national coalition that encourages federal forest management agencies to manage forests in ways that
protect the Earth’s climate.
www.forestcc.org