This letter was submitted on 3/21/2025 by Environment America with the signatures of 105 organizations, including us.

To: Stephen Astle, Director, Defense Industrial Base Division, Office of Strategic Industries and Economic Security, Bureau of Industry and Security, U.S. Department of Commerce
Re: Request for Public Comments on Section 232 National Security Investigation of Imports of Timber
and Lumber Reference: X-RIN 0694-XC117
March 31, 2025
Docket No. 250310-0030

Thank you for the opportunity to submit a public comment on the relationship between national security and timber production in the United States. Our nation’s forest lands, especially our mature and old-growth forests on federal lands, play an important role in ensuring the security of our communities, wildlife, and climate across America. Our mature and old-growth forests intersect with national and economic security in five areas.

1. Drinking Water for Americans
According to the Forest Service, the lands the agency manages are the largest source of municipal water supply in our nation, providing water to more than 60 million people across 33 states. Access to enough clean water is critical for national security, and mature and old-growth forests protect and maintain essential drinking watersheds.

2. Mitigating Danger and Costly Risks from Flooding
The extensive root systems and healthy soils of mature and old-growth forests help reduce flooding risk as the country is forced to contend with more extreme weather events due to climate change. The dense overlaying layers of duff, moss, and vegetation in mature forests allows water to be soaked up and slows runoff, while filtering water. These ecosystems help support watershed integrity and retain soil moisture in the dry season, reducing drought impacts, preventing erosion, and regulating the transport of nutrients and sediments.

3. Aiding Our Efforts to Curb Climate Change
Our mature and old-growth forests absorb and store tons of carbon, keeping it out of the atmosphere and helping mitigate climate change. Climate change is a threat to national security – extreme weather events threaten lives and damage the economy, disrupting supply chains and destroying infrastructure. Extreme weather also threatens U.S. military bases and operations.

4. Supporting the Outdoor Recreation Economy
National forests and the recreation opportunities that abound in them support local economies, generating tens of billions of dollars of local spending and supporting more than 100,000 jobs. The Forest Service estimates that recreation visits to national forests generated $12.5 billion in GDP in 2019.

5. Habitats for Fish and Wildlife

The United States, along with the rest of our planet, is facing an extinction crisis and fish and wildlife need our help. Habitat loss, invasive species, disease, and climate change all threaten our fish and wildlife. Mature and old-growth forests protect vulnerable species across the country, and large protected areas in our national forests allow for habitat connectivity. These forests, and the cool, shaded habitats they provide are also critical to the life cycles of many valuable species that support commercial and subsistence fishing economies.
Any attempt to increase timber production on federal lands threatens the forests that provide these services. To achieve higher board feet targets, agencies will have to allow more logging of mature and old-growth trees and forests. Our organizations strongly oppose this change in direction on public lands.
Protecting our country means protecting all of the people who live here and the resources that help us to live healthy and happy lives, free from threats. Our forests provide myriad benefits to our health and are a source of happiness for millions of Americans every year.
To protect national security, we must protect our oldest trees. Our mature and old growth trees and forests are worth more standing.