Press Releases

Hoover Named President of Federal Forest Resource Coalition: December 11^th, 2024: Washington, DC: Robert Hoover of California was named President of the Federal Forest Resource Coalition today.

“I’m honored to take on this role at a pivotal time for America’s National Forests,” Hoover said. “Our industry is positioned to help improve the health and resilience of our National Forests which will protect habitats, watersheds, and communities from wildfires, while creating jobs in rural America. Working with our Federal partners and the new Administration, we are ready to finally turn the corner on the forest health crisis afflicting these critically important lands.”

Hoover is Vice President for Resources at Sierra Pacific Industries, a third-generation, family-owned forest products company based in California. He began his career with Sierra Pacific cruising timber as a summer intern while working toward his forestry degree from Humboldt State University. Hoover joined SPI full-time in 2003 and has held a variety of positions including his most recent role as California Log Resources Manager and previous log procurement roles at SPI’s Lincoln and Burney sawmills in California. He is a California Registered Forester and is active with a number of industry associations including FFRC and the California Forestry Association.

“Mills that rely on the National Forests are under significant strain as timber outputs have declined,” said FFRC Executive Director Bill Imbergamo. “With Robert’s experience and knowledge, we’re poised to demonstrate that forest management is a net plus for our public forests. I look forward to his leadership and to producing results for our mills, our forests, and the American public.”

To download the PDF, please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

About the FFRC: FFRC is a national coalition of wood products companies, local governments, conservation groups united by concern for the National Forests. FFRC supports improving the management of the federal lands to support healthy forests and vibrant rural communities.

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Press Statement on Forest Service National Old-Growth Plan Amendment: September 19, 2024: Washington, DC: FFRC Executive Director Bill Imbergamo issued the following statement regarding Draft EIS for the Forest Service National Old Growth Amendment:

“The proposed nation-wide Forest Plan amendment for old growth violates the National Forest Management Act, the Multiple Use Sustained Yield Act and conflicts with the statutory multiple use mandate the Forest Service functions under.

The DEIS fails to meet the minimum standards of NEPA for a “hard look” at the proposed action. It would impose significant new burdens on the staff of the Forest Service, through a forest planning process that is already barely functioning. Forest Planning has largely devolved to the point where it is an exercise in developing binding constraints on management, with optional goals that are subsequently not monitored in a meaningful or consistent way.

The Department is now proposing to throw this already dysfunctional process into further disarray, in the service of adding restrictive language on timber harvesting which has been shown to have little impact on the trajectory of older forests on the National Forest System. And they are proposing to do this while the Chief of the Forest Service is taking steps to reign in hiring because of what he characterized as a significant budget shortfall.

The proposed old-growth amendment will lead to the loss of additional old-growth forest across the National Forest System. The two-year period when adaptive strategies are developed will see both the loss of staff capacity for needed fuels reduction work and additional administrative objections and litigation. The combined delays in needed work will allow more catastrophic fire to destroy more acres of old-growth.

The Forest Service should spend the next two years implementing the badly needed forest management and hazardous fuels reduction projects that Congress provided funding for. Shifting gears to write complex new old-growth management approaches is at best a distraction, at worst a recipe for disaster.”

To download the PDF, please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Press Statement on Forest Service National Old Growth Plan Amendment: June 20, 2024: Washington, DC: FFRC Executive Director Bill Imbergamo issued the following statement regarding Draft EIS for the Forest Service National Old Growth Amendment:

“FFRC is disappointed that the Administration continues to pursue further restrictions on management of the National Forests in the face of unprecedented forest health and wildfire challenges. We do not believe focusing on older forests is a good way to address those challenges, and we are extremely concerned about the disruption this unprecedented approach will have on urgently needed management efforts.”

“The USDA’s recently released ‘threat assessment’ for old growth found that existing Forest Plans restrict tree cutting in old-growth forests to conditions where tree cutting benefits the durability of the old-growth through stewardship that maintains old-growth characteristics. Wildfire caused the destruction of over 700,000 acres of old growth since 2000, while insects and disease destroyed another 182,000 acres. That’s 98 times more acres than was impacted by timber harvest.”

“Rather than waste limited staff time and resources re-writing Forest Plans and developing old growth management approaches, the Forest Service ought to use the authorities and funding Congress has provided to focus on reducing the threat of catastrophic wildfires and insect outbreaks on our public lands before it’s too late.”

To download the PDF, please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

Press Statement on the Fix Our Forests Act of 2024: FFRC Executive Director Bill Imbergamo issued the following statement on the “Fix Our Forests Act”: June 18, 2024:

“We appreciate the bipartisan leadership Natural Resources Chairman Bruce Westerman and Rep. Scott Peters (D-CA) have demonstrated on forest management issues. We urge the Committee to take up the Fix Our Forests Act quickly so it can be passed this summer, before the wildfire season ramps up.

The Fix Our Forests Act includes key reforms that have been approved on a bipartisan basis by the Natural Resources Committee, including common sense reforms that will encourage active management of our Federal forests to protect watersheds and communities.

We believe the fireshed provisions, reforms to Stewardship Contracting, locally-led restoration, litigation reform, and expanded efforts to use utility corridors as fuel breaks, are a good starting point for reforms at the Forest Service.

The proposed litigation reforms are badly needed. According to data provided to us by the Forest Service, over 1.8 Billion Board Feet of Forest Service timber was under litigation in the fall of last year. That’s more than half a year’s worth of timber sales in an average year. The reforms included in the Fix Our Forests Act ensure that needed management can take place in a timely fashion.

We particularly applaud the provisions clarifying that there is no need for additional consultation on forest plans, particularly if the project itself has not raised any concerns about listed species. This misguided case law was opposed by the Obama Administration, which appealed it to the Supreme Court. Enacting these reforms will free up agency resources and prevent unnecessary delays in implementing badly needed management actions.

We are also strongly supportive of Good Neighbor Authority provisions. Allowing the retention of some receipts under GNA by agency partners, including tribes, counties, and states, will encourage further participation in and investment in Good Neighbor programs at those levels.

The National Forest System is a conservation achievement of which all Americans should be proud. More than half of the National Forests are already in low to no management designations like Wilderness Areas, Wild & Scenic River corridors, and Inventoried Roadless Areas. Less than 28 percent of the National Forest System is designated as “suitable for timber production.” Yet management of National Forests remains a daunting challenge.

The Fix Our Forests Act makes significant strides in reducing litigation and ensuring accountability. On behalf of the more than 300,000 American who rely at least in part on Forest Service timber for their livelihoods, we urge the House to act on this critical bill as soon as possible.”

To download the PDF, please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Press Statement on Forest Service Old Growth Threat Assessment: On Friday, June 14, 2024, the USDA Forest Service released the “Threat Assessment” for Mature and Old Growth Forests called for by President Biden’s April 2022 Executive Order. You can find the final, 210-page report at this link.

FFRC Executive Director Bill Imbergamo issued the following statement regarding the Threat Assessment:

“Fire, insects, and disease killed nearly 100 times more National Forest old growth than timber harvest in the last quarter century, and yet the Administration is pushing through an unprecedented nation-wide Forest Plan amendment that will make forest management on the National Forests even more difficult.”

“USDA’s decision to slow-walk the release of this report, culminating with choice to release it on a Friday afternoon, seems calculated to downplay the fact that timber harvest hasn’t been a major cause of old growth loss on the National Forests in decades.”

“The report documents what professional foresters have long known: timber harvest is a tool to develop and maintain a wide variety of forest and habitat types. It shows that most Forest Plans already restrict harvest in old growth stands. All it does is reinforce the fact that the old growth policies being pursued by this Administration are driven by pure politics, not ecological need.”

“Moreover, the report found that existing Forest Plans restrict tree cutting in old-growth forests to conditions where tree cutting benefits the durability of the old-growth through stewardship that maintains old-growth characteristics. Wildfire caused the destruction of over 700,000 acres of old growth since 2000, while insects and disease destroyed another 182,000 acres. That’s 98 times more acres than was impacted by timber harvest.”

To download the PDF, please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Press Statement: Senate GOP Farm Bill Framework: June 12, 2024: FFRC Executive Director Bill Imbergamo issued the following statement regarding the release of a Farm Bill “Framework” by Senator John Boozman (R-AR)

“We applaud Ranking Member Boozman for releasing a very strong forestry title in his Farm Bill framework. Communities that rely on National Forests can’t wait for the key reforms proposed today. It’s time for Congress to pass these critical provisions so the Forest Service can start using them this year.”

To download the PDF, please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Press Statement: Comments on Forest Service Proposed Old Growth Policy: January 29, 2024: FFRC Executive Director Bill Imbergamo issued the following statement on the Forest Service’s Notice of Intent on Old Growth:

“Older forests are a diverse and transitory set of ecosystems found throughout the United States, they are found across wide swaths of the National Forest System, including millions of acres in legally protected areas where no management will take place under current laws. Old growth forests have been expanding on the National Forest System, because current forest plans already provide for their management and protection. The Forest Service says the main threat to old growth are disturbances like megafires and large-scale insect and drought related mortality.

All of this demonstrates that there is little to no value with pursuing a nationwide forest plan amendment that inherently violates substantive provisions of the 2012 Planning Rule, and which would potentially hinder the Forest Service’s ability to meet other forest management objectives. Given the generally poor conditions on many acres of National Forests, dedicating limited staff time to a national plan amendment is a strategic misallocation of resources.

Rather than pursue this ill-advised strategy, we urge the Department to continue addressing old growth issues through the locally-led planning process, managing stocking levels appropriately for each forest type, engaging in regulated harvest on unreserved acres, with substantial carbon storage in long-lived wood products, and more aggressive recovery of damaged timber and reforestation following disturbances.

To download the PDF, please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Press Statement: Old Growth Policy Massive Distraction from Forest Health and Wildfire Crisis: December 19, 2023: FFRC Executive Director Bill Imbergamo issued the following statement on the Forest Service’s Notice of Intent on Old Growth:

“We are carefully reviewing the Forest Service’s proposal. It appears this effort continues to prioritize creating further management restrictions on the National Forest, even though it is well established that timber harvest is not a threat to these forests.”

“The Forest Service preliminary ‘threat assessment’ for Old Growth Forests shows the vast majority of old growth “losses” were from fire, insects, and disease, likely exacerbated by climate change. It found that timber harvest impacted about 0.03 percent of the agency’s old growth stands over the last two decades.”

“The Forest Service’s approach here is baffling. Congress has made it clear that job one is reducing the threat of catastrophic fires by thinning our National Forests, something our industry is more than capable of doing. Instead, the same staff who should be planning fuels treatments are going to be engaged in a rushed, top-down effort to amend every forest plan to restrict management options on even more acres of National Forests.”

“This is a massive misallocation of resources. The Forest Service admits in the Federal register notice that “nearly all” Forest plans already have specific requirements to protect and manage old growth stands. The Forest planning process is supposed to be a bottom up, locally led effort that builds on specific forest types and conditions. It’s not clear how a National, top-down effort helps here.”

To download the PDF, please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Press Statement: To Ensure Climate Resilience, Forest Service Must Manage National Forests: July 20, 2023: FFRC Executive Director Bill Imbergamo issued the following statement on the Forest Service’s Advanced Notice of Proposed Rulemaking on Climate Resilience:

“The Forest Service and BLM were tasked with reviewing the lands under their stewardship to determine the extent of “mature” and “old growth” forests. They found 39 million acres of mature and old growth forests on National Forest System Wilderness, Roadless, and National Monument areas alone. Forest Service and Bureau of Land Management lands have over 112 million acres of mature and old growth forest, more than 175,000 square miles. This is an area larger than all but three states, and is larger than the states of West Virginia, Maryland, Vermont, New Hampshire, Massachusetts, New Jersey, Hawaii, Connecticut, Delaware, and Rhode Island combined.

It is important to note that these impressive acreages of old growth and mature forests were found based on a review of less than 20 percent of total forest area of the United States. Notably, the review did not examine millions of acres of forests found in the National Park System, which is not open to commercial timber harvest.

We are extremely concerned the ANPR is a pretext for a broad and open-ended effort to fundamentally reorient the Forest Service – and the National Forest System in particular — away from its core mission absent a clear mandate to do so from Congress.

Rather than engage in an unfocused, legally dubious effort to develop a myriad of new policies, planning processes, and procedures, ostensibly in the service of climate adaptation, the Forest Service should, rather, focus on implementing the considerable new authorities and funding the Congress has provided to address the wildfire and forest health crisis that has been building on Federal lands over the last several decades.

The roots of the wildfire and forest health crisis on Federal lands are not complicated. The National Forest System has been made uniquely vulnerable to climate stresses by three decades of passive management and massive set asides from management. Even when presented with new authorities – such as the insect and disease treatment Categorical Exclusions provided in recent Farm Bills and the Fuel Break Categorical Exclusion created in the Bipartisan Infrastructure Law – the Forest Service has been unwilling to use these authorities for fear of litigation that takes advantage of dubious legal precedents, resulting in significant constraints on management.

Aggressively thinning forests on unreserved acres, creating fuel breaks around critical infrastructure, and using expedited authorities everywhere possible – should be the agency’s sole focus at this time. Eastern National Forests, which are generally less fire prone, can be managed to sequester more carbon through timber harvest on unreserved acres.”

FFRC’s official comments on the April Advanced Notice of Proposed Rulemaking on climate resilience were filed on July 25, 2023, and are attached along with this press release. The comments were joined by 20 forest industry associations.

To download the PDF please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

Embargoed Until 9:00 AM Thursday, April 20, 2023

FFRC Statement on Mature & Old Growth Forests: April 20, 2023: FFRC Executive Director Bill Imbergamo issued the following statement on the Forest Service’s inventory of “Mature and Old Growth Forests.”

“We’re pleased to see the Forest Service wrap up this inventory exercise. The Forest Service’s most recent science shows that fire, insects, and other factors are leading to large scale losses in mature forests, not timber harvest. Reforestation needs similarly are being driven by large fires.”

“We’re completely unsurprised that this limited inventory – which only looked at one-fifth of the Nation’s forests – found over 39 Million Acres of Mature & Old Growth National Forest is already in land uses that prohibit timber harvest. That’s more than 61,000 Square Miles, an area larger than the states of Hawaii, Massachusetts, Vermont, New Hampshire, New Jersey, Connecticut, Delaware, and Rhode Island combined. There are over 91 million acres of Mature and Old Growth on the National Forests, an area of over 143,000 square miles, larger than the state of Montana.”

“The Forest Service evaluated their own science and data sets and determined that no single definition of old growth or mature forests was feasible. Instead, we’ve got lots of data that doesn’t help the Forest Service do what needs to be done: manage unreserved forestlands to reduce fire danger, create wildlife habitat, and provide jobs in economically distressed rural areas.”

“Between the Forest Service, Bureau of Land Management, National Park Service, National Wildlife Refuges, and millions of acres of State parks, America has no shortage of public forestland, most of which is lightly managed, if it’s managed at all. Today’s inventory shows we’re not running out of mature trees.”

“On many National Forests, particularly those east of the Mississippi River, we have millions of acres of older forest that are not producing quality wildlife habitat, sequestering carbon, or providing support for local forest-based economies. We need to focus on the broad array of forest types and ages, not fixate on an a single type of forest.”

“FFRC will carefully review the Advanced Notice of Proposed Rulemaking on ‘climate resilience’ and file comments. We hope the Forest Service can get back to implementing the billions of dollars Congress provided to protect our forests from fires, bugs, and disease using proven management techniques, like forest thinning and the creation of fuel breaks.”

To download the PDF please click here

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Statement on Forest Service Wildfire Strategy: January 19, 2023: FFRC Executive Director Bill Imbergamo issued the following statement regarding USDA’s update on their 10-year Wildfire Strategy:

“Today’s announcement is a welcome but overdue step to begin turning the tide on the forest health and wildfire crisis on our National Forests. President Biden signed the Infrastructure Law more than 14 months ago. It’s perplexing that it’s taken that long for USDA to tell the Forest Service to begin using the “emergency” authority enacted in that landmark bill.

The forest products industry is a vital part of the Forest Service’s effort to restore forest health, reduce hazardous fuels, and protect communities. There are many, many more acres of National Forests that are overstocked, fire prone, and in need of restoration work. Timber harvest can help restore historic fire regimes on National Forests, while generating jobs for rural residents and wood products for the American people.

Time is not on our side. The fire behavior witnessed on National Forests in recent years confirms that without major fuels reduction work, we could see many more acres of National Forests convert to brush fields, compromising watersheds, wildlife habitat, and emitting millions of tons of carbon. There is no time to lose in moving forward with this critical work.”

To download the PDF, Please click HERE

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Announces Increased Support for Congressional Sportsmen’s Foundation: January 4, 2023: The Federal Forest Resource Coalition (FFRC) announced this week that they have become a Platinum Mission Partner of the Congressional Sportsmen’s Foundation, increasing their support for the critical work CSF does in support of wildlife, hunters, and anglers.

“Our industry helps public land managers create and maintain wildlife habitat for dozens of species. Many people in our sector are avid hunters and anglers. It only makes sense for us to increase our support for CSF in 2023,” said FFRC Executive Director Bill Imbergamo. “FFRC has worked closely with CSF on key issues like fixing “fire borrowing” and pushing for a reversal of the disastrous Cottonwood decision. We look forward to strengthening this working partnership in 2023.”

“We appreciate the increased support from FFRC for CSF’s mission,” said Jeff Crane, President and CEO of CSF. “Timber harvest is a critical tool to create critical wildlife habitat on public lands. We look forward to building on our record of successful partnership with FFRC in 2023 and beyond.”

To download the PDF, Please click HERE

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

Parma Named FFRC President: Will Lead National Coalition Through 2024: December 14, 2022: Jim Parma, the Eastern Fiber Manager for Bell Lumber and Pole, was named the Federal Forest Resource Coalition’s sixth president. He will lead the organization through 2024.

“It’s an honor to take on this leadership role at a challenging time for our industry and for our public land managers,” Parma said at the close of FFRC’s board meeting this week. “Our public lands are a conservation success story, but they are facing unprecedented challenges. Our industry can help improve forest health, store more carbon, and reduce the danger of catastrophic fires. I look forward to helping managers at the Forest Service and Bureau of Land Management meet those goals.”

Parma has been with Bell Lumber and Pole, a 113 year old wooden utility pole and other wood structures producer for 20 years and his responsibilities include managing fiber procurement in Bell’s Barron, Wisconsin and Broken Bow Oklahoma production yards, representing Bell Lumber and Pole on multiple Forestry and Timber Industry Boards and personally procuring timber in Central Minnesota.

Prior to joining Bell, Parma procured timber for several major wood consumers in the Lake States. He started his forestry career working for the USDA Forest Service in Oregon and Washington. Parma holds a forestry degree from the University of Wisconsin-Stevens Point, and a grandfather of six wonderful grandkids with a seventh arriving this coming May.

Parma takes over from Tom Schultz, Director of Resources and Government Affairs at Idaho Forest Group. Schultz will remain on FFRC’s Board of Directors.

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Praises Bipartisan Promoting Effective Forest Management Act: “It’s Time to Get Serious”

September 20, 2022: Today, Chairman Joe Manchin (D-WV) and Ranking Member John Barrasso (R-WY) introduced the bipartisan Effective Forest Management Act. FFRC Executive Director Bill Imbergamo issued the following statement:

“We applaud Chairman Manchin and Ranking Member Barrasso for setting clear expectations for forest management on our Federal forests. For the last decade, Congress has increasingly provided the tools and resources for the Forest Service and Bureau of Land Management to begin turning the tide on the fire and forest health crisis. Now it’s time to begin holding these agencies accountable for results.

The Effective Forest Management Act sets clear goals for the use of streamlined authorities and demands that the two land management agencies accurately report on effective steps to reduce the threat of wildfires. It also encourages forest managers to work their way up through the agency before moving into national leadership roles.

The bill also makes clear that unreserved forests – including mature forests – are available for management. Without opening a single new acre to harvest, this bill will encourage sustainable management of our National Forests and BLM lands.

Congress has addressed many of the concerns that Forest Service leaders have said were required to reverse the forest health and wildfire crisis on our public lands. The Effective Forest Management Act ensures that Forest Service leaders will be held accountable for using the authorities and resources Congress has provided.”

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

To download the PDF, Please click HERE

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

To download the PDF, Please click HERE

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

Parma takes over from Tom Schultz, Director of Resources and Government Affairs at Idaho Forest Group. Schultz will remain on FFRC’s Board of Directors.

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

FFRC Praises Bipartisan Promoting Effective Forest Management Act: “It’s Time to Get Serious”

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 1007

Washington, DC 20006

Forest Service. BLM Effort to Define Old-Growth and Mature Forests A Diversion from High Priority Forest Management:

August 30, 2022: The Federal Forest Resource Coalition filed comments on the “Request for Information” on Old-Growth and Mature Forests on August 29th. FFRC Executive Director Bill Imbergamo issued the following statement:

“FFRC is gravely concerned that the Forest Service and Bureau of Land Management are being forced to conduct an ill-advised effort to define “old- growth” and “mature” forests so that the White House can score points with anti-management groups who oppose all timber harvest on the National Forests.”

“Much like the 2001 Roadless Rule did, this new effort is a barely disguised ploy to find even more acres of Federal forests and place them off limits to management. Coming up with one nation-wide definition for this complex topic will not help Forest Service and Bureau of Land Management do a better job in executing their forest plans, will make it harder to create wildlife habitat, and will impede current efforts to reduce the hazardous fuels which have been driving the wildfire crisis on our Western forests.”

“About 120 Million Acres of National Forests are in restricted land uses – where very little or no forest management takes place. National Monuments, Wild & Scenic River Corridors, Designated Wilderness Areas, and Inventoried Roadless Areas make up 60 percent of the National Forest System. When restricted areas on other Federal ownerships are counted, some 300 million acres of Federal land is off limits to timber harvest.”

“More than 37 million acres of National Forests have burned since the 2001 Roadless Rule was adopted. That’s an area seven times larger than the number of acres where timber harvest of any kind has taken place. Every State where National Forests make up the majority of the timberland is a net carbon source, because of poor forest health and large fires on the National Forests. Adding to the stock of unmanaged lands will do nothing to improve this situation.”

“Americans are rightly proud of the conservation legacy we’ve created, including the National Forests, National Parks, and National Wildlife Refuges, not to mention millions of additional acres preserved in State Parks, State Wildlife Areas, and still more private land under conservation easements. But it’s time to grow up and realize we must actively manage the remainder of our National Forests before it’s too late. The current effort to define and inventory old forests does nothing to help with this important work.”

For more information, contact Bill Imbergamo, Executive Director, at 703- 629-6877 or [email protected]

Federal Forest Resource Coalition
1901 Pennsylvania Ave., NW Suite 303 Washington, DC 20006

FFRC Comments on Fed. Reg. 42493-42494 Vol. 87, No. 135 July 15, 2022

FFRC Comments on Fed. Reg. 42493-42494 Vol. 87, No. 135 July 15, 2022

August 29, 2022

Mr. Jamie Barbour

Ecosystem Management Coordination USDA Forest Service
Washington, DC:

Assistant Director

Dear Mr. Barbour:

Please see our comments regarding the above captioned Federal Register Notice.

The preamble to the Federal Register Notice states that the Department of Interior’s Bureau of Land Management and the USDA Forest Service “shall, within one year of the date of this order, define, identify, and complete an inventory of old-growth and mature forests on Federal lands.”

General Comments:

It is important to stress that such an inventory, fraught with numerous complications noted below, must consider all forested acres on all Federal lands. This includes 244.4 million acres of land managed by the Bureau of Land Management, 192.9 million acres of land administered by the USDA Forest Service, 89.2 million acres within the National Wildlife Refuge System, 79.9 million acres within the National Park System, and 8.8 million acres owned by the Department of Defenseⁱ.

It is worth noting that in addition to the more than 56 million acres of National Forest that USDA has identified as being more than 100 years old, the National Park Service has, at a minimum, 4.8 million acres of old-growth forests on which commercial management is prohibitedⁱⁱ. This 1991 estimate for the National Park Service is substantially outdated and should be updated. Every forested acre in the National Park System will eventually “mature,” and cutting trees on National Park land is mostly prohibited, except to protect life and property. Presumably, absent natural disturbances, all forested acres within the National Park System will attain “old-growth” or at least “maturity.”

Any such inventory must also recognize that the Forest Service and Bureau of Land Management already host significant areas reserved from most active timber management. 7.7 Million Acres of National Forests are in National Monumentsⁱⁱⁱ. 17.6 Million Acres of NFS lands are in Wild & Scenic River Corridors. 36.6 Million Acres of NFS lands are in Designated Wilderness Areas. 58.2 Million Acres of NFS lands are in Inventoried Roadless Areas. While theoretically some non-commercial fuels reduction work could take place in an Inventoried Roadless Area, for all practical purposes they are off limits to commercial timber harvest, meaning, if the trees in those areas are not killed by wildfires, insects, or other disturbances, they will all achieve “old-growth” status eventually. The total area of NFS lands in these restricted land use categories is three times larger than the 40 Million Acres of NFS lands designated as “suited for timber production,” and is 27 Million Acres larger than the entire National Park System.

Similarly, forest management is extremely limited on the 85 Million Acre National Wildlife Refuge System. The National Wildlife Refuge Act states that “No person shall disturb, injure, cut, burn, destroy, or possess any real property of the United States” (trees are considered real property) on a National Wildlife Refuge^iv. Most forested lands on National Wildlife Refuges, therefore, will also grow to the maximum extent possible, subject to the natural limitations of each site and natural disturbances.

If old-growth is defined as forests that are simply allowed to grow with no management, there are at least 60.8 million acres of old-growth existent on National Forests and National Parks alone. There are an additional 14 million acres of land in State park systems, where, generally speaking, timber management is either prohibited or discouraged^v. If even half these State park areas are forested, that’s an additional 7 million acres that will not be

managed and will eventually achieve “old-growth” status, however defined. At 67 million acres, this is an area larger than all but seven States and is 42 times larger than the State of Delaware.

Various advocates, on a local level, have suggested criteria such as age of trees, size, presence of down and decaying trees, define “old-growth.” We believe a universal definition, or even a “universal definition framework” inherently cannot be based on the best available science, limits the ability of the Forest Service to manage for specific species, and will lead to less old- growth on the landscape over time. Forests will mature, decay, and, in many cases, burn. Current trends suggest that many types of forest disturbance are becoming more common, from large fires to wind events. Without active management, stands experiencing stand-replacing disturbances will not mature into “old-growth” stands, and with no effort to control brush after such events, they may not return as forests at all.

In order to conserve forests of any successional stage, the ability to engage in adaptive management is critical. Information about typical successional processes and stages may help inform management, but it does not make it possible to stop forest succession or end disturbance regimes which will “reset forest to stand initiation phases, regardless of human management.

To download entire text of comments please download as PDF.

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Logo Description automatically generated Federal Forest Resource Coalition

1901 Pennsylvania Ave., NW Suite 303

Washington, DC 20006

Testimony of Tom Schultz, President, Federal Forest Resource Coalition

Farm Bill Oversight Hearing

House Agriculture Subcommittee on Conservation and Forestry July 13, 2022

Chairwoman Spanberger, Ranking Member LaMalfa, on behalf of the Federal Forest Resource Coalition, I appreciate the opportunity to testify before you today. My name is Tom Schultz and I am Vice President of Resources and Government Affairs at Idaho Forest Group (IFG), a family-owned business operating five sawmills in Idaho, as well as a new mill we are bringing online in rural Mississippi. I am here today as President of the Federal Forest Resource Coalition, which represents purchasers of Federal timber in 37 states, with over 650 member companies and affiliated associations, collectively representing over 390,000 employees.

By way of background, prior to joining IFG, I served in leadership roles for two decades at State land management agencies in both Montana and Idaho, roles I took on following a career in the U.S. Airforce. This diverse background has given me a unique perspective on the challenges facing the U.S. Forest Service.

FFRC is extremely grateful for the leadership this Subcommittee has shown on National Forest Management issues in the last several Farm Bills. Since 2014, the Farm Bill has advanced some of the most effective and important policy changes that have aided Forest Service efforts to begin reversing the forest health and wildfire crisis that is challenging the sustainability of our Federal Forests.

The 2014 and 2018 Farm Bills saw the expansion of Good Neighbor Authority, expansion of Designation by Description and Designation by Prescription, permanent reauthorization of Stewardship End-Results Contracting, and

enactment of streamlined authorities to treat forest insects, disease, and reduce hazardous fuel loads on National Forests. The next bill, scheduled for 2023, provides an opportunity to build on these successes to scale up management to meet the significant challenges facing the health and sustainability of the National Forest System.

Good Neighbor Reform: The 2014 Farm Bill expanded Good Neighbor Authority (GNA) to all 50 States, following years of pilot authorities which allowed small scale work in several States. The 2018 Farm bill expanded the eligibility of GNA to counties and Tribes. The program has been a resounding success and we urge the Subcommittee to build upon it in the 2023 Farm Bill. Since expanding the authority in the 2014 Bill, the number of acres treated annually under this program has grown by more than twenty-fold and is averaging more than 60,000 acres each year for the last four years.

Since the 2014 Bill, three dozen states have begun work on over 130 GNA projects. In addition to improving forest health, GNA has helped increase wood supply to bring additional needed forest products to market. According to the Congressional Research Service, the amount of Forest Service timber sold under GNAs has increased from 14.4 million board feet in FY2016 to

182.6 million board feet in FY2019. That’s enough lumber to frame about 11,000 single family homes. As many Americans struggle with finding affordable housing, this program is helping meet market needs.

With States investing substantial sums of money to support implementation of Good Neighbor Authority (GNA) projects, including cross-boundary projects, treatment of revenue from GNA projects must reflect this reality. However, the 2018 Farm Bill limited the ability of States to utilize GNA project receipts on non-Federal lands – despite the clear direction that these projects be conducted to improve forest health on both Federal and Non-Federal lands.

We note that this recommendation is consistent with those provided by the National Association of State Foresters.

Action Requested: Amend 16 U.S. Code § 2113b(2)(c) to allow States, Counties, and Tribes to utilize revenues generated on non-Federal lands, pursuant to conditions specified in Good Neighbor Agreements, and direct the Forest Service to update existing Good Neighbor Master Agreements and Project Agreements to use revenue from existing projects for this work.

We also recommend that Congress consider amendments to the GNA authority to allow new road construction and reconstruction under GNA contracts on a limited basis. Restoration work on the National Forest System is not limited the need to reduce hazardous fuels; in many cases, older roads, placed without adequate consideration of water quality impacts, should be retired and replaced by better engineered, correctly placed roads that address water quality issues as well as roads that are just worn out and need reconstruction such as crushed aggregate and vegetation removal for safe and efficient use.

As you move to reauthorize these programs, we urge you to make all of the above changes and extend the authority for this program to the Bureau of Land Management (BLM) as well. The 2014 and 2018 Bills extended several forest management authorities to the BLM, and this committee should build upon that precedent in the 2023 bill.

Stewardship Contracting Amendments: The 2014 Farm Bill made Stewardship Contracting authority permanent, responding to a request from then-Chief Tom Tidwell. Stewardship Contracting has been a vital authority allowing the Forest Service to move implement forest restoration and management projects. Stewardship Contracts now account for about 25 percent of overall Forest Service timber sale volume, and in some regions, this total has grown to exceed 50 percent.

As the use of this contracting tool has expanded, it has become clear that reforms are needed to ensure that the program doesn’t result in unintended consequences, including inadequate resources for reforestation. Moreover, as the Forest Service struggles to expand its treatment of at-risk acres of National Forest System lands, it’s become clear that retention of existing forest products infrastructure – loggers, trucking capacity, and wood products facilities – is critical to achieving the paradigm shift the Forest Service has called for.

In the last three years, we’ve seen the closure of five sawmills located near millions of acres of fire prone National Forests, including the IFG mill at St. Regis, Montana. All these closures were precipitated – at least in part – due to insufficient wood supply from nearby National Forests to keep these mills running. Loss of milling infrastructure is a major factor behind what the Forest Service calls its “low value material” problem.

Our initial analysis of Forest Service Forest Inventory & Analysis data show that there are substantial quantities of standing sawtimber on National Forest System lands across the United States. Using what are known as Integrated Resource Timber Contracts (IRTC’s), the Forest Service can generate additional revenues to expand treatments – including non-commercial thinning, prescribed fire, and improved fish passage – while supporting family-wage, year-round jobs in forest management and wood products industries.

By contrast, if nearby mills close, experience has taught us that attracting new investment – particularly where there are few non-Federal forests to support a forest products industry – can be extremely difficult. Following the loss of most sawmilling capacity in Arizona, the Forest Service has struggled for over 12 years to attract capable, well capitalized industry to help it accomplish forest management work that will protect watersheds and communities from catastrophic fire.

Action Requested: Amend 16 U.S. Code § 6591c to strike Section (e)(B) and add clarifying language that requires Deposits in the Knutson-Vandenberg Fund (authorized by 16 U.S.C. § 576) for Stewardship End-Results Contracts that include merchantable timber.

Further, amend the purposes of Stewardship End-Results Contracting Projects (16 U.S. Codes § 6591(c)) to add an eighth “land management goal” of retaining and expanding existing forest products infrastructure, including logging capacity and wood consuming facilities, in proximity to the National Forests.

Improving the Effectiveness of Farm Bill Insect and Disease, Hazardous Fuels Reduction Authorities: Beginning in the 2014 Farm Bill, Congress provided the Forest Service with the authority to “categorically exclude” insect and disease treatments on up to 3,000 acres of National Forest System lands. The 2018 Farm Bill expanded this authority to allow for hazardous fuels reduction work on acres designated using this authority.

These authorities have proven effective in expediting needed forest management work. However, the size of the areas allowed to be treated is too small to effectively prevent catastrophic fires. The Caldor Fire in California

provided numerous examples of effective fuels treatments using the Farm Bill CE. Within that fire’s 221,000-acre burned footprint, there were at least five areas treated using the Insect & Disease and hazardous fuels mitigation CE’s. In every case, where the Forest Service had completed all the steps of the fuels reduction process, the treatments reduced flame length, fire intensity, and rate of spread.

However, the treatments were not conducted on enough acres to prevent the fire from being the first in history to burn over the crest of the Sierra Nevada mountains. Assuming all five categorical exclusions treated the 3,000-acre maximum, the treatments on the Caldor fire area amounted to 15,000 acres, or about 7 percent of the fire area. If the Forest Service had been able to treat 15,000 acres under each CE, fire intensity and the damage resulting from it could have been reduced on fully one third of the fire and may have even allowed firefighters to control the fire sooner.

It is critical to remember that the Categorical Exclusions provided to the Forest Service through the last two Farm Bills do not open a single new acre of land to timber harvest. Use of all Categorical Exclusions requires compliance with existing Forest Plans, including land allocations like designated Wilderness Areas, Inventoried Roadless Areas, and other areas where removal of vegetation is prohibited. These CE’s merely allow the Forest Service to quickly approve needed treatments after a brief review, rather than engaging in lengthier NEPA processes that have delayed projects as small as 1,600 acres for as much as five years or more.

Requested Action: Amend 16 U.S. Code § 6591b to increase the number of acres which can be treated for fuels reduction and pest treatment from 3,000 to 15,000 acres.

Eliminate Unnecessary Restrictions on Infrastructure Spending: The Infrastructure Investments & Jobs Act (IIJA, Public Law 117-51) provided unprecedented investments over the next 5 years for a wide range of forest management actions on National Forest System lands. In effect, this bill both authorized and appropriated funds for several new programs that impact all operations of the National Forest System, including those created from outside the Public Domain. That places these programs firmly within the jurisdiction of the Agriculture Committee, and we’d urge you to carefully review them as the 2023 Farm Bill approaches.

Unfortunately, Congress chose to insert language limiting the application of these funds in ways that limits their effectiveness. For instance, the bill provided $500 million over 5 years for “mechanical thinning and timber harvesting” and “pre-commercial thinning in young growth stands.” However, each of these actions is limited with extraneous or redundant restrictions, including a limitation on precommercial thinning to include only those projects that produce “wildlife benefits to provide subsistence resources.”

This requirement could be construed to limit the application of these new funds to only those National Forest System lands where a recognized tribal government has valid subsistence rights, leaving large portions of the National Forest System ineligible for this important work.

Requested Action: Amend IIJA authorities to eliminate duplicative, unnecessary, or unhelpful limitations on management.

Streamline National Forest Management: Each National Forest is governed by a legally binding Forest Plan, developed through a collaborative process with ample opportunities for public involvement. Each Forest Plan designates some acres of National Forests as being “suited for timber production,” while also recommending areas for more restrictive land uses, like wilderness designations.

In practice, these Forest Plans take too long to develop, and frequently, they wind up producing binding restrictions on land management, while land management goals – like early seral habitat – are both difficult to achieve and are rarely monitored to determine whether they are attained. When the Forest Service proposes management actions – such as creation of young forests or thinning fire prone stands – the agency must begin entirely new NEPA processes that make fleeting – if any – reference to the underlying Forest Plan.

The result is both an overly long planning process, and project level analysis that is too dense and voluminous to be of any use to anyone except experts. While the quantity of information required to move forward with a management project is impressive, the quality and accessibility to the public, leaves much to be desired. Moreover, conflicting court precedents, such as the disastrous Cottonwood case, have left in legal limbo whether Forest Plans are “ongoing actions” under the law. This has left the Forest Service vulnerable to frivolous lawsuits that frequently block or delay needed management projects.

By one estimate, injunctions based on the erroneous Cottonwood precedent have stalled over 350 Million Board Feet of timber in the Forest Service Northern Region alone, enough timber to frame over 29,000 single family homes. Congress stepped in and provided a partial fix to this problem in the 2018 Omnibus Appropriations bill. The 2023 Farm Bill should be a vehicle to complete this work.

Requested Action: Clarify that Forest Plans are not “ongoing actions” for the purposes of Federal law and make clear that consultation under the Endangered Species Act Section 7 is not required at the plan level. Second, Congress should, through amendments to the National Forest Management Act, clarify that projects conducted on acres designated as suited for timber production should be subjected to reduced analytical requirements under other statutes. Planning for an accounting for “sensitive” resources on the National Forest System must grapple with the fact that about half the acres are in restricted land uses and will likely never see management.

Conclusion: FFRC appreciates the work this committee has done to provide the Forest Service with streamlined authorities to accomplish needed work on the National Forests. As we’ve seen, the only limitation with these authorities is that they haven’t gone far enough, fast enough. The forest health crisis on our National Forests threatens not only the sustainability of the forest industry that depends on those forests, but millions of Americans who need them for clean air, clean water, and places to recreate. The forest industry is a tool to help achieve management objectives on our National Forests — ranging from hazardous fuels reduction to the creation and maintenance of habitat for multiple wildlife species.

By taking the steps outlined above, this Committee can help arrest the declines in forest health we’ve been witnessing for the last 30 years and put our forests on a better path. We look forward to working with the Committee and the other stakeholders on today’s panel to achieve these goals.

Federal Forest Resource Coalition
1901 Pennsylvania Ave., NW Suite 303
Washington, DC 20006

Press Statement by the Federal Forest Resource Coalition on “Climate Forests” Campaign “Report” on Timber Projects:

July 12, 2022: The groups behind the “Climate Forests Campaign” –Sierra Club, Center for Biological Diversity, Natural Resources Defense Council, and the League of Conservation voters – have total annual budgets exceed $450 million. With all that money, you’d think they’d be able to afford a carbon calculator.

“Wildfires are the major threat to old growth, as Secretary of Agriculture Tom Vilsack noted recently,” said Bill Imbergamo, FRRC Executive Director. “If we are going to ‘save’ old growth, we have to manage it, removing less fire tolerant trees to reduce fire intensity.”

Wildfires on National Forest lands in California in 2020 released the C02 equivalent of emissions from about11 million cars. Wildfires in 2018 emitted enough carbon to charge over 17 trillion cell phones.

The Climate Forests Campaign claim that standing trees on the National Forests account for “more than 95 percent of forest carbon,” with less than 4 percent of carbon stored in products (like lumber or panels).

“The National Forests have supplied over half a trillion board feet of timber to meet the needs of the American people since 1940. Yet miraculously, these forests, by these groups own account, still store massive amounts of carbon. Seems like a good idea to keep managing them to me,” said Imbergamo.

“Species like the Red Cockaded Woodpecker strongly prefer mature Longleaf or Shortleaf pine forests, and the Forest Service’s timber sale program creates

millions of acres of those forests through active management, including the sale of sawtimber. Red Cockaded Woodpecker nesting clusters are thriving on the South’s National Forests.

The “green” groups clearly aren’t concerned about protecting old or big trees, as these trees have been going up in flames on the National Forests in droves since these groups jawboned the Clinton Administration into crashing the National Forest timber sale program in the early 1990’s.

“The objective here is to muddy the waters and throw up one more roadblock to management. Half the National Forest System is off limits to management – either roadless, wilderness, or wild and scenic rivers. Harvest on the rest is strictly limited, and groups like this have ample opportunities to sue if they have site specific concerns,” Imbergamo said. “There’s no accident that they rolled out this strategy just a few weeks after Chief Moore announced an effort to step up management on our fire prone forests.”

“Adopting a ‘mature tree’ conservation policy isn’t meant to conserve big trees. It’s an effort to distract from what everyone knows needs to happen. The Biden Administration would be wise to listen to their own forest scientists and managers, and to keep managing the unreserved National Forests to provide benefits to all Americans.”

Federal Forest Resource Coalition
1901 Pennsylvania Ave., NW Suite 303
Washington, DC 20006

Forest Management Helps Tame Wildfire, Even in High Winds

April 15, 2022: The Wabash Springs fire ignited on the Black Hills National Forest, near Custer, South Dakota, last week. The area was relatively dry and was experiencing high winds (estimated between 40 and 60 mph).

“Everybody just came together almost like it was clock work” said U.S. Forest Service Public Affairs Officer Scott Jacobsen. “The fuels treatment and the thinning that’s been done in and around that area for the last 8-10 years certainly made a difference.” (Quoted here).

“The firefighters did not sit back on this and used a dozer to connect forest roads and get a line around the fire quickly – undoubtedly helped by good roads access and thinned stand conditions,” said Ben Wudtke, Executive Director of the Intermountain Forest Association.

A picture containing outdoor, sky, nature Description automatically generated “Forest management played a critical role in reducing the fuel loads and forest density, creating stand conditions that exhibited textbook resilience to wildfire,” Wudtke added. “I walked a good portion of the burn area and flew over the entire fire with a drone. Based on what I saw, I could count the number of dead trees taller than breast height on one hand.”

Wudtke said this was the second fire the Black Hills had seen in recent months that ignited during critical fire weather conditions but was kept at bay through a combination of forest management and quick actions from firefighters.

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

FFRC Supports No Timber From Tyrants Act

Washington, DC: April 7, 2022 – Federal Forest Resource Coalition Executive Director Bill Imbergamo issued the following statement on the introduction of the No Timber From Tyrants Act”:

“The American people are facing significant challenges from inflation, including a staggering increase in housing costs. Our National Forests can help meet the needs of our domestic lumber and panel markets, and they can do so sustainably. In fact, right now, the National Forests are badly under managed, which contributes to both the ongoing forest health and wildfire crisis and to unsustainably high housing costs. Under current Forest Plans, we can double the amount of harvest, and do it sustainably.

The No Timber From Tyrants Act doesn’t open a single new acre of National Forest to harvest, and doesn’t waive any environmental laws. We can meet domestic timber market needs from National Forests and BLM lands without compromising our environmental standards or helping support international aggression.”

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Press Statement by the Federal Forest Resource Coalition on Fiscal Year 2023 Forest Service and BLM Budgets:

March 10, 2022: The Federal Forest Resource Coalition this week submitted testimony in support of improved management of Forest Service and Bureau of Land Management forests and called for increased timber outputs to restore forest health, reduce fire danger, and supply wood products for the American people.

“The National Forests are a conservation success story, but unless we invest in their management, they face an uncertain future,” FFRC Executive Director Bill Imbergamo said. “The Forest Service recently acknowledged that there is a forest health and wildfire crisis on our National Forests. The Infrastructure bill has provided significant new resources to the Forest Service, but the annual spending bill must ensure that the base program – which funds timber sales, restoration treatments, and road maintenance –be increased.”

“Forest restoration work is expensive – the Forest Service estimates that treating at risk acres and protecting communities will take $50 billion over a decade. Using value from forest products – through timber sales and Stewardship contracts – can help defray these costs, while generating wood products Americans need and employment in rural communities.”

FFRC’s testimony calls for 25 percent increases in both Forest Products and Road Maintenance funding. “These investments will produce benefits for every American by providing safe access to millions of acres of public land, as well as affordable wood products.”

“If Congress would adequately fund these programs, timber outputs from National Forests could easily replace imports from places like Russia – which

has no environmental standards and seems to enjoy invading it’s neighbors. We can produce those products right here in America, using our own resources, and following strict environmental standards. More than half the National Forest system is off limits to management – and the other half is badly under managed. We can do better, but only if Congress supports these investments.”

For more information, contact Bill Imbergamo, Executive Director, at 703-629-6877 or [email protected]

Federal Forest Resource Coalition
1901 Pennsylvania Ave., NW Suite 303
Washington, DC 20006