I was trying to help some groups with their comments on this USDA request, and perhaps someone more familiar with Regulations.gov can help. I was trying to find other comments of interest to round up ideas, both for my own comments and also for future TSW posts. What an opportunity for people from all over the country and working in all different areas to weigh in!
However, I ran into a couple of problems. First, they don’t separate out form letters, and you have to download any that are letters to read them. So it’s really not designed for reading comments. I also looked at posted comments to a scoping notice for a tiny Forest Service project, and it was easier to read them! The other thing I thought is that it would be interesting for something like this, which doesn’t have legal requirements, for some analysis group to pick out ideas (say, change EQIP to do ….) and then have people vote on them, in another “round” of comment.
I also had a flashback to when I worked at CSREES, now NIFA. Most of the form letters were about National Forests and how the best thing for climate was to not do anything. I’ve attached the two most common I found USDA-2021-0003-0381_attachment_1 2. It’s no wonder the rest of USDA can get tired of the FS. There they go doing all kinds of good and non-controversial work, and then there’s the FS.
Scientists recognize that forests sequester more carbon when they are protected than when forests are logged. For public land, the USDA can have a direct, positive impact by supporting proforestation in our national forests. “Proforestation” means purposefully growing the public’s existing forests intact for maximal carbon storage and sequestration. On the ground, proforestation means protecting older, larger trees and drastically reducing logging national forests.
Science suggests that we need the largest trees now because they sequester more carbon than seedlings. We don’t have much old growth, ancient trees, mature trees, and roadless areas remaining on our public forests. These areas provide the trees that can most efficiently sequester carbon now. They also provide refuge for animals and plants in this warming climate, so they serve both as areas of climate refugia and biodiversity. Please protect these areas from all tree cutting and road work. That will protect larger trees, more intact ecosystems, and consequently sequester more carbon.
Reduce logging. Activities such as reconstructing roads or building new ones (even temporary) to access trees, cutting those trees down and hauling them off public land are all activities that burn fossil fuels. Hammering ecosystems with logging and roadbuilding does not create resiliency to climate change—such activities exacerbate carbon emissions.
I did like this idea letter state conservation agencies which argued against a tendency to initiate new programs every time a problem shows up.. kind of “more programs, more administration and less money to do work.”
An increased focus on climate and resiliency issues is admirable, but USDA should avoid attempting to “reshuffle” its program delivery in the name of change. USDA already has a number of climate-smart conservation programs that are not only effective but over-subscribed. Several examples are the Environmental Quality Incentives Program (EQIP), the Conservation Reserve Program (CRP), the Conservation Stewardship Program (CSP), the Agricultural Management Assistance (AMA) Program, and the Small Watershed Program. During past administrations, there has been an unwritten rule that authorizing additional funding to any of these programs can only come at the expense of other USDA conservation programs. We are optimistic that this administration, with a supportive Congress, can move beyond this antiquated thinking and fund conservation programs at the levels needed by our country’s landowners and cooperators. Conversely, developing new programs in the name of climate will certainly slow our progress toward climate goals by increasing administrative requirements to get these programs up and running. There is no need to recreate this wheel, but there is an immediate need to better fund the programs that our delivery system can effectively use without delay.
Comments are due tonight, but we can still discuss ideas after they close, so please link to your organization’s letter in the comments below. And if you have an easier way to read comments on regulations.gov, please let me know.