Re: Bureau of Land Management’s “Conservation and Landscape Health” Proposal

A coalition of environmental organizations argues that mature and old-growth (MOG) forests are critical for carbon sequestration and biodiversity, and must be protected from logging via a national BLM rule. The document details the ecological value of MOG, identifies ongoing logging threats on BLM lands, and argues that such protections are consistent with the Federal Land Policy and Management Act (FLPMA) and Biden administration executive orders.

• Mature and old-growth (MOG) forests are essential for climate mitigation because they store and sequester vast quantities of carbon, with older trees holding significantly more carbon than younger ones.
• MOG forests provide critical ecological co-benefits, including habitat for endangered species like the northern spotted owl and marbled murrelet, and the regulation of water temperature and streamflow.
• Mature and old-growth trees are generally more fire-resistant than younger trees due to thicker bark and higher moisture content, and logging often results in higher carbon emissions than wildfires.
• Pinyon-juniper woodlands are a dominant part of BLM's forest portfolio and store the majority of carbon on forested BLM lands in the contiguous United States.
• The BLM continues to authorize logging in MOG stands through various projects in western Oregon, such as the North Landscape, Poor Windy, and 42 Divide projects, and through right-of-way agreements with private timber companies.
• The authors propose a binding rule with an age cutoff of 80 years to protect mature trees from logging, arguing that site-specific measures like conservation leases are insufficient.
• Protecting MOG is argued to be consistent with the Federal Land Policy and Management Act (FLPMA) by treating conservation as a use on par with other uses and preventing "unnecessary or undue degradation."
• The document asserts that BLM has the legal authority to protect MOG on Oregon and California Railroad Lands (O&C lands) under the O&C Act, the Clean Water Act, and the Endangered Species Act.
• A national rule to protect MOG would align with Biden administration directives, specifically Executive Order 14072 on forest conservation and Executive Order 14008 on the climate crisis.

APA

Earthjustice (2023). Re: Bureau of Land Management’s “Conservation and Landscape Health” Proposal. https://earthjustice.org/wp-content/uploads/2023/07/blm-conservation-and-landscape-health-technical-comments.pdf

Chicago

Earthjustice. Re: Bureau of Land Management’s “Conservation and Landscape Health” Proposal. 2023. https://earthjustice.org/wp-content/uploads/2023/07/blm-conservation-and-landscape-health-technical-comments.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Re: Bureau of Land Management’s “Conservation and Landscape Health” Proposal |date=5 July 2023 |url=https://earthjustice.org/wp-content/uploads/2023/07/blm-conservation-and-landscape-health-technical-comments.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2023bureau, author = {{Earthjustice}}, title = {{Re: Bureau of Land Management’s “Conservation and Landscape Health” Proposal}}, publisher = {Earthjustice}, year = {2023}, month = jul, url = {https://earthjustice.org/wp-content/uploads/2023/07/blm-conservation-and-landscape-health-technical-comments.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }