To: Secretary Kathleen A. Theoharides, Massachusetts Executive Office of Energy and Environmental Affairs; Claire Miziolek, Decarbonization Roadmap Manager; Hong-Hanh Chu, GWSA Program Manager; Benjamin Miller, Decarbonization Roadmap Technical Lead; and staff of the relevant agencies
CC: Representative Susannah Whipps; Representative William Pignatelli; Representative Denise Provost; Senator Ann Gobi; Senator Karen Spilka; Senator Jo Comerford; Representative Mindy Domb; Jim Montgomery, Department of Conservation and Recreation; State Forester Peter Church; Janet Sinclair; Michael Kellett; Franklin Land Trust, Mass Audubon, the Trustees of Reservations, the Nature Conservancy of Massachusetts and the Environmental League of Massachusetts, E.O. Wilson of Harvard University, writer and activist Bill McKibben, Green Berkshires, Climate Action Now, the Center for Biological Diversity, the Walden Woods Project and Biodiversity for a Livable Climate, and Jonathan Thompson of Harvard Forest
Date: April 10, 2020
Re: Open Letter on Proforestation (submitted as a public comment to the Decarbonization Roadmap/Emissions Limits for 2050)
Dear Honorable Officials (elected and appointed), employees of the Commonwealth, and esteemed citizen-activists and scientists,
You are aware of the struggle to preserve Massachusett’s commonly-held state forests from lumbering and biomass production. Citizens and scientists, especially forestry researchers, have been arguing directly with you—the government of the Commonwealth—for a paradigm shift in land management for more than a decade.
It was discouraging to participate in the virtual public meeting on March 27, 2020 and listen to the obfuscation of your representatives as they fielded specific questions about proforestation by pretending there is insufficient data or that the science is somehow unclear. This is not true. The scientific evidence has been consistent and provided to you regularly, repeatedly, in a timely manner. The questions were also not new. To those who have been engaged in and following the process for years, the disrespect is obvious. That the EOEEA continues to fail to lead in this fundamental and essential component of mitigating climate change is disturbing in and of itself. Worst is that the adverse consequences are increasing exponentially.
As “the first state in the nation to combine energy and environmental agencies under one Cabinet secretary”[i] there is an incredible responsibility upon you to establish policy that actually does the dual work of “promoting efficient energy use…while protecting and preserving Massachusetts’ natural environment” (emphasis added).[ii] It appears as if you have interpreted this dual charge in a hierarchical way, putting energy before the environment.
Researchers in 2009-2010[iii] documented two pathways to improved carbon sequestration by forests, concluding that “a shift to less intensive forest management alternatives will result in a net increase in C sequestration in northern hardwood ecosystems (Nunery & Keeton, p. 1374). One path involves “unmanaged northern hardwood forests [which can then] sequester 39 to 118% more C than any of the active management options evaluated;” and another path involving “a shift from high frequency management with low structural retention to low frequency management with high structural retention [that] can sequester up to 57% more C” (Nunery & Keeton, p. 1374). Increasing carbon sequestration is vital to reaching the 2050 zero emissions target. (And why aren’t we trying to reach it sooner?)
Technical Committee Members of the Forest Futures Visioning Process, initiated by the Massachusetts’ Department of Conservation and Recreation (DCR) in 2009, submitted a final report in which they explicitly and specifically laid out the imperative to shift the forest management paradigm to “an ecosystem services model” (see endnote for details)[iv] which is another way of saying the new paradigm must be based on the principle of “forest as infrastructure”—which was introduced by the Harvard Forest in their 2013 preview video, Changes to the Land, and elaborated in their 2014 report (with the Smithsonian Institute).[v] The press release for these findings explicitly warned of the “peril of land use decisions”[vi] if we continue in the current paradigm of business as usual.
DCR was reminded, in 2016, in another public comment period, that the Forest Futures Visioning Process had made these plain recommendations.[vii] And there have been thousands of other submissions over the past decade along these same lines.
Finally, in 2019, a perspective article for Frontiers in Forests and Global Change, synthesized the evidence and urgent need for the proforestation approach.
“…growing existing forests intact to their ecological potential—termed proforestation—is a more effective, immediate, and low-cost approach that could be mobilized across suitable forests of all types. Proforestation serves the greatest public good by maximizing co-benefits such as nature-based biological carbon sequestration and unparalleled ecosystem services such as biodiversity enhancement, water and air quality, flood and erosion control, public health benefits, low impact recreation, and scenic beauty.” (Moomaw, Masino & Faison, 2019, p. 1)[viii]
The argument for proforestation is clear. In truth we need to also protect private forests from further development, too. The hurdles involve overcoming centuries of legalized habits of allowing monied interests to dictate public policy.
In the “10 Year Progress Report” (2019) on Massachusetts’ progress on the Global Warming Solutions Act, the emphasis is on planting trees in urban and residential areas to achieve a (so-called) “density” of 5 trees per acre.[i] While the gains of shade for energy consumption are real, this strategy alone is insufficient.
Folks, the forest in Massachusetts helps everyone! It is the largest intact forest in the United States. The southeastern forest has been decimated. The northwestern forests are badly pockmarked. Our neighbor to the north has logged the heck out of their part of the formerly extensive northeastern woodlands.
WE NEED the Massachusetts forest to fight climate change! We need old trees and big Big BIG stretches of untouched forest. Here are the key points:
- proforestation, which is net gain in forest, as in absolutely zero loss + regain the losses of the last three years and continue to increase!
- stop cutting any/all old growth, full stop! Because the bigger older trees sequester more carbon.
- stop pretending that “the science” isn’t clear or “the data” isn’t available – it’s been established consistently over more than a decade.
- follow the recommendations from the Harvard Forest/Smithsonian study for clustered development and rewarding “forest as infrastructure.”
- create/invent alternative financial rewards for maintaining and preserving forests intact as “ecosystem services” that contribute to the general welfare and health of everyone (in MA and beyond).
- do not count wood fuels/biomass as an efficient or positive/good energy fuel.
- do not trade forest for solar.
- recognize the value of forests for clean water and wildlife and all the ‘intangibles’ these add to quality of life and climate stability.
- find another way that people who have made their incomes (and profits) from harvesting lumber and wood products to contribute to the economy through retooling and repurposing their assets ~ instead of continuing to operate via sneaky ways of allowing abuse of the forest by unfairly permitting class/money privilege to buy state legislation favorable to their personal interests rather than the public good.
It seems, from the outside anyway, that you are prioritizing carefully selected, pre-existing forestry-related industries to guide your decision-making. There is no other explanation for the willful ignoring of, by now, thousands of comments and contributions of time and energy by dedicated individuals who are trusting that this administration in this state will do the right thing and change the guiding framework for land management away from monetary generation and profit to a stewardship model that literally puts the forests first.
It can be done. You are smart enough; you understand the principles well enough — you must find the will to overcome the legacy of privilege that some legislators and certain companies and particular individuals are trying to protect.
This legislature has bills before it that would protect the Massachusetts forest. This is your moment to prove that democracy works by adopting and applying the wisdom coming from citizens of the Commonwealth.
Thank you sincerely,
Stephanie Jo Kent
[i] https://www.mass.gov/about-the-executive-office-of-energy-and-environmental-affairs retrieved April 10, 2020.
[ii] https://en.wikipedia.org/wiki/Massachusetts_Executive_Office_of_Energy_and_Environmental_Affairs retrieved April 10, 2020.
[iii] Nunery, J.S., and Keeton, W.S. (2010). “Forest carbon storage in the northeastern United States: Net effects of harvesting frequency, post-harvest retention, and wood products” in Forest Ecology and Management 259, pp. 1363–1375. Retrieved April 10, 2020.
[iv] State Library of Massachusetts Archives (July 30, 2010). The Forest Futures Visioning Process Recommendations of the Technical Steering Committee: final report states: “Recommendation 1: Adoption of an Ecosystem Services Model to Guide Forest Protection and Management — The fundamental guiding principle for all forest protection and management policies in the Commonwealth should be to ensure the sustainable provision of a comprehensive suite of forest ecosystem services. Moreover, DCR should adopt a planning framework for the state parks and forests that focuses on the provision of key ecosystem services not expected to be provided, or not provided in adequate amounts, from private lands in the Commonwealth. The adoption and prioritization of ecosystem services is intended, in part, to address conflicts inherent in competing demands on our forests. Essential ecosystem services represent primary management goals for DCR lands. These include biodiversity protection, clean water, carbon sequestration, soil formation and nutrient cycling, and public recreation including wilderness/old growth/spiritual experiences. In addition to these services, some DCR lands will serve to demonstrate how forests can be managed to provide sustainably grown wood products, and others will emphasize quality outdoor recreation experiences.” (p. 7) https://archives.lib.state.ma.us/handle/2452/50079, retrieved April 10, 2020.
[v] Harvard Forest Changes to the Land preview (2013) https://www.youtube.com/watch?v=dFf8H3e-X0E; Changes to the Land: Four Scenarios for the Future of the Massachusetts Landscape (2014) https://harvardforest.fas.harvard.edu/changes-to-the-land , retrieved April 10, 2020.
[vi] Harvard Forest Press Release (2013) https://harvardforest.fas.harvard.edu/sites/harvardforest.fas.harvard.edu/files/HF%20Changes%20to%20the%20Land%20press%20release%20-%20for%20immediate%20release.pdf, retrieved April 10, 2020.
[vii] Comments submitted to Jessica Rowcroft, Project Manager, DCR April 10, 2016. http://ellenmoyerphd.com/wp-content/uploads/2014/08/DCR_forest_projects_ltr_RESTORE_etal.pdf retrieved April 10, 2020.
[viii] Moomaw, W.R., Masino, S.A. and Faison, E.K. (2019) “Intact Forests in the United States: Proforestation Mitigates Climate Change and Serves the Greatest Good” in Frontiers in Forests and Global Change, Volume 2, Article 27. https://www.frontiersin.org/articles/10.3389/ffgc.2019.00027/full retrieved April 10, 2020.
[ix] [i] Global Warming Solutions Act: 10-Year Progress Report (2019). https://www.mass.gov/files/documents/2019/04/02/GWSA-10-Year-Progress-Report.pdf?_ga=2.55017835.1768772727.1586451057-1946861827.1578661505 retrieved April 10, 2020.