Patagonia's Official Comment on Protecting Old-Growth Forests in U.S.

Director, Policy Office 
USDA Forest Service Headquarters 
201 14th Street SW, Mailstop 1108 
Washington, DC 20250–1124 
 

RE: USDA Forest Service Docket FS-2023-0006-0002; Advanced notice of proposed rulemaking 

Dear Secretary Vilsack, 

Patagonia Works (“Patagonia”) appreciates the opportunity to provide comments on the advanced notice of proposed rulemaking on how the USDA Forest Service can protect, conserve and manage our national forests for climate resilience.  

Patagonia is an outdoor-apparel company with a 50-year history of environmental activism. Protecting and preserving the environment is a core business tenet as reflected in our company’s mission statement: “Patagonia is in business to save our home planet.” In 2012, Patagonia became a California benefit corporation, enshrining its blended goals of business and conservation into its articles of incorporation. Patagonia believes deeply in the urgent and shared responsibility to protect the environment.  

The future of Patagonia’s business depends on the health of the wild places that its customers explore, which include our national forests. Outdoor recreation creates $862 billion in consumer spending and contributes 4.5 million jobs to the U.S. economy. Land managed by the Forest Service plays a large role in supporting the recreation economy with estimates of 150 million recreational visits per year. Forest Service land contains158,000 miles of trails and 4,300 campgrounds, all available to the public. Protecting and conserving our national forests has never been more important in the face of a changing climate, and forests are a critical climate solution for keeping carbon in the ground and out of the air.  

To meet President Biden’s goals for tackling the climate and biodiversity crises, it is imperative that the USDA prioritize the protection of mature and old-growth forests and trees. We need a clear and meaningful rule to ensure mature and old growth trees are protected, including from logging. 

Older forests and trees are a key climate solution, provide ecosystem resilience and are critical to addressing the biodiversity crisis. These trees store most of the above-ground carbon in a forest and are far more adaptable to the impacts of climate change. While there are many threats to our forests, logging older forests and trees grossly undercuts these benefits. Nationally, carbon losses from clearcuts and other logging are up to five times higher than emissions from fire and other natural forest disturbances combined.  

We urge you to include in any future administrative rules an end to ecologically harmful logging of mature and old-growth forests and trees on federal land. While there are certainly other threats to our older forests, the threat of logging is fully under your control and can be quickly acted on.  

We applaud the Biden administration and the Forest Service for pursuing this rulemaking and recognizing the importance of mature and old-growth forests as a climate solution.