We know the importance of older and old-growth trees and forests. These trees are essential habitats for WV endemic and endangered species, helping to provide healthy forest ecosystems necessary to protect our Mon Forest headwaters and other waterways and store carbon.

Old-growth areas need protections to ensure that the carbon storage benefits from mature trees are enhanced. Executive Order (EO) 14072 requires the Forest Service to prioritize protections for our oldest trees. 

The Forest Service has released its draft Environmental Impact Statement (EIS) to amend all Forest plans and invites public comment. The Forest Service presents 4 options but recommends Alternative 2. 

First, we thank the Forest Service for deciding NOT to follow its initial idea to have only one definition for older and old growth trees and forests. Because of the West Virginia great clearcut, we have only limited areas that were not harvested by 1920 - and therefore limited "old" growth. The decision to consider conditions specific to each forest will benefit our Mon Forest and hopefully protect more areas in our crown jewel public land.

We also generally support "Alternative 2," which provides protections for older and old growth but, unfortunately, still permits some commercial timbering in old-growth areas. We think the Forest Service should revise its draft EIS and Alternative 2 to provide the following: 

• Alternative 2 should be clear that management of mature/older/old growth forests and trees is not tied to any commercial timbering -- and that any limited timbering will not occur on steep slopes at all, utilize an uneven-aged system, not clearcutting or some other even-aged system, and be permitted only when absolutely necessary and when there are strong ecological or forests reasons to do so (not merely or primarily economic reasons). 
• Each forest, in understanding its unique situation regarding older/old-growth trees, area, and forest, should be required to identify older/old trees and growth at a scale less than a "stand" -- and provide for the protection of those trees/areas even if the stand (or larger area) is otherwise considered appropriate for clear-cutting or other significant timber harvest (commercial or otherwise).
• Each forest, upon receiving information from local residents, Tribal interests, or other local groups identifying older/old trees in the local area, should be required to ‘ground truth” the report and, if substantiated, remove those trees/areas from any proposed cut or timbering.
• Waterways in the Mon Forest are life. These waterways provide drinking water for us and a habitat for hellbenders and candy darters, among other species. Clear guidelines as to the benefits to such waterways by protecting mature/older/old-growth forests – and the safeguards and procedures to be followed for all waterways including any waterway the Forest Service has found is a Wild and Scenic River eligible waterway.  

We hope the revised EIS and revised Alternative 2 will be strictly defined and inclusive enough to include even small areas of old growth so that these legacy trees and their essential carbon storage may be protected to the full extent as contemplated by EO 14072. It is critical to protect all older/mature/old-growth trees and areas in our National Forest System and in the Mon Forest. 

Thank you,
West Virginia Rivers Coalition and Members