This story by Inside Climate News is part of Deforestation Inc., a global investigation by the International Consortium of Investigative Journalists.

U.S. government agencies are expected to quantify the climate impact of their actions under new guidance issued by President Joe Biden’s administration at the start of this year.

But last month, the U.S. Forest Service decided to move forward with a 16,000-acre logging project on the border of Yellowstone National Park without applying the new White House guidance, which would have involved a detailed projection of the resulting greenhouse gas emissions.

The Forest Service said it was already in the final stages of developing its management plan for the South Plateau in Custer Gallatin National Forest in Montana when the White House Council on Environmental Quality delivered the new guidance to federal agencies on Jan. 9. 

As a result, the agency announced its decision on March 15 without calculating the cost of the sequestered carbon that would be released under the plan, which includes clear-cutting 5,500 acres of mature lodgepole pine trees and constructing 57 miles of logging roads in the heart of grizzly bear country. 

Instead, the Forest Service produced a brief analysis concluding that the climate impact was likely to be small and “temporary.”

The decision raises questions about the practical import of such presidential “guidance” and other White House declarations and the Biden administration’s overall commitment to arresting climate change. Even though Biden embraces the climate science that President Donald Trump rejected and has signed legislation pouring billions of federal dollars into addressing the crisis, the logging controversies suggest that he is far from achieving the kind of “all of government” urgency on climate that has been his stated goal. 

National forests hold the country’s greatest concentration of mature and old-growth trees, which play an outsize role in storing and absorbing carbon dioxide emissions. But so far, no law or regulation is in place to prioritize carbon sequestration over the Forest Service’s other long-standing mandates, including timber production. 

“The notion that clear-cutting more than 5,000 acres of mature forest has a negligible effect on carbon sequestration just doesn’t hold up against the science,” said Ellen Montgomery, director of the public lands campaign at Environment America.

Federal agencies have broad discretion on how and when to apply the new guidance from the Council on Environmental Quality, or CEQ. Such guidance is not binding or legally enforceable, but is the administration’s view of what the law requires. Biden has directed the Forest Service to conduct the first-ever inventory of mature and old-growth stands in national forests, due to be completed by mid-April. But such trees are on the chopping block in more than 20 advancing projects. Many of them, like the Custer Gallatin plan, were originally proposed during the Trump administration.

Putting Emissions Into a Real-Life Context 

The White House CEQ, responsible for coordinating policy across the executive branch, said that agencies should be including far more detailed climate accounting in the environmental assessments they are required to conduct for all major actions under the 1970 National Environmental Policy Act, or NEPA. 

“The United States faces a profound climate crisis and there is little time left to avoid a dangerous—potentially catastrophic—climate trajectory,” said the new guidance signed by the CEQ’s chair, Brenda Mallory. “Climate change is a fundamental environmental issue, and its effects on the human environment fall squarely within NEPA’s purview.”

The key change urged by the White House council was for agencies to provide more context in their environmental assessments, preferably by calculating the “social cost” of the carbon emissions produced or reduced by a federal action.

Agencies typically have not calculated the social costs of carbon under the National Environmental Policy Act. But for years, they have used the social cost of carbon under a separate law—the Administrative Procedure Act—when they write federal regulations. That law requires agencies to estimate the costs and benefits of rules, which often involves quantifying concepts such as the value of human lives saved. Since President Barack Obama’s administration, agencies have used the social cost of carbon to translate the impact of greenhouse gas emissions on health, environment and the economy into dollars.

During the Trump years, agencies set the social cost of carbon at as little as $1 per ton, reflecting the low value put on climate action. But in 2021 the Biden White House brought back the metric used by the Obama administration, about $52 per ton. Recently, in new proposed methane regulations, Biden’s Environmental Protection Agency has asked for public comment on setting the social cost of carbon as high as $190 per ton, as some economists have recommended.

Without context, however, a raw estimate of metric tons of carbon doesn’t provide much helpful information to the public. In its new guidance, CEQ said agencies should take steps such as illustrating how an action will help the nation meet its climate commitments. For example, an agency can discuss how the emissions impact of an action squares with Biden’s pledge to cut U.S. emissions in half by 2030 under the 2015 Paris accord. The CEQ also recommended that agencies use familiar comparisons to show the size of emissions—for example, in terms of the number of cars on the road or the gallons of gasoline burned.

“There’s no perfect way to contextualize greenhouse gas emissions,” said Max Sarinsky, senior attorney at the Institute for Policy Integrity at the New York University School of Law. “I think the ways that CEQ suggests—particularly, the social costs of greenhouse gases and considering carbon budgets and climate commitments—is really a thoughtful way to show what the emissions mean.” 

Sarinsky said agencies had previously provided either no context or misleading comparisons in their NEPA analyses, particularly during the Trump administration.

For example, in 2019, the Forest Service approved a 14,270-acre logging project in Vermont’s Green Mountain National Forest on the basis of an environmental assessment that said only that the carbon emissions would be “negligible” by comparison with total global or national emissions.

The new guidance says such statements don’t pass muster under NEPA. “This approach does not reveal anything beyond the nature of the climate change challenge itself—the fact that diverse individual sources of emissions each make a relatively small addition to global atmospheric GHG concentrations that collectively have a large effect,” the CEQ said.

‘Death by a Thousand Small Cuts’’

In the NEPA analysis for the South Plateau logging project in Custer Gallatin, the Forest Service isn’t quite as dismissive of the carbon impact question as it was in some of the Trump-era environmental assessments. But the agency still frames the loss of old trees, most of them more than 90 years old, as an action with little climate impact.

For example, the Forest Service estimates that its logging plan would affect just 0.25 percent of the forested area of the 2.5 million-acre Custer Gallatin, a wild and diverse landscape that includes hundreds of glaciers as well as pine savannas. The logging would remove “much less than” 1 million metric tons annually over the 10-year project, a small portion of the 110 million metric tons of stored carbon in Custer Gallatin, the service said.

But a social cost of carbon analysis would project that even under the lower estimate used by the Biden administration, $52 per ton, 500,000 metric tons of annual carbon emissions annually—only half the number given by the Forest Service in its example—would cost about $27 million a year in greenhouse gas impact in the early years of the project. 

That is a cost of some significance, in light of the agency’s own economic analysis showing the South Plateau logging plan would operate at a financial loss. At current timber prices, the labor and other costs of logging would exceed the anticipated timber sale revenue by anywhere from $1.1 million to $3.2 million, the Forest Service’s economist calculated. (The economist said many of the costs and benefits associated with a project—for example, wildlife habitat improvement—are not quantifiable in financial terms.)

Using other metrics suggested by the CEQ guidance, annual emissions of 500,000 metric tons of carbon would exceed the impact of putting an additional 100,000 cars on the road each year or opening a new natural gas-fired power plant, according to the EPA’s greenhouse gas equivalency calculations.

“The excuse that this is just an infinitesimal amount of carbon doesn’t hold up,” said Randi Spivak, public lands director for the Center for Biological Diversity. “Climate change by nature is death by a thousand small cuts.”

Spivak’s group is part of a broad coalition of environmental organizations, the Climate Forests campaign, that is urging the Forest Service to abandon this and other logging projects planned or underway that target more than 370,000 acres of mature and old-growth trees nationwide.

At a time when the federal government is investing billions of dollars in research and development of carbon capture technology under the infrastructure and clean energy spending bills signed by Biden, environmentalists say it makes no sense to release carbon already being stored in trees on public land.

“Think of the value that our old-growth or mature forests have,” Montgomery said. “We don’t have to get them online, we don’t need to transport them. They’re literally standing there, sucking up carbon for us.”

The Forest Service maintains that the South Plateau logging project will increase the landscape’s resilience to insects and disease, reduce wildfire risk and “contribute to a sustained yield of timber products.” Those wood products also will provide long-term storage of carbon, the agency says.

Environmentalists argue that the Forest Service overstates the carbon storage value of wood products. They also dispute the benefit of thinning and clearing remote lodgepole pine forest that relies on wildfire to regenerate. 

But the Forest Service maintains that such management is likely to increase carbon storage and reduce emissions over the long term by reducing the risk of the insects, disease and wildfire that are causing the greatest loss of carbon from forests in the West.

“Any carbon initially emitted from this proposed project’s actions will only have a temporary influence on atmospheric CO2 concentrations as carbon will be removed from the atmosphere over time as the forest regrows,” the Forest Service’s three-page summary of the project’s potential carbon effect says.

Asked about the logging decision, the White House CEQ pointed to language in the new greenhouse gas guidance showing that agencies have leeway in deciding whether to apply it. “Agencies should exercise judgment when considering whether to apply this guidance to the extent practicable to an ongoing NEPA process,” the text says.

A spokesperson for Custer Gallatin National Forest said that officials anticipate applying the guidance to projects that started after its Jan. 9 effective date and may abide by it where practical to those that began earlier.

“The Custer Gallatin National Forest strives to continually improve our NEPA process for decision-makers and the public,” the spokesperson said. “We anticipate using the new guidance to improve our analysis of greenhouse gas and climate change effects, particularly employing the social cost of greenhouse gas emissions and improving project-level quantitative analysis of greenhouse gas effects when it is reasonable to do so.” 

Harnessing Federal Guidance as a Legal Tool

Environmentalists note that previous clear-cuts in nearby Caribou-Targhee National Forest were visible from space, in sharp contrast with the forest in neighboring Yellowstone National Park, where no logging is allowed. They also point out that the Forest Service’s own analysis concluded that the Custer Gallatin logging and road-building is “likely to have adverse effects” on grizzly bears, though not on the species as a whole. 

The South Plateau, a corridor within the Greater Yellowstone Ecosystem, is used by grizzlies and other endangered species pressured by climate change.

NEPA doesn’t require agencies to choose the least environmentally harmful option in weighing project alternatives, but the law has been a powerful tool for opponents of federal actions. Even under Trump, who sought to weaken scrutiny of climate effects in the assessment process, federal courts stopped at least a dozen mining, fracking and pipeline projects approved by his administration—including Keystone XL—because agencies had failed to adequately consider greenhouse gas impacts.

And although the new CEQ guidance does not have the force of law, it could serve as important proof in legal challenges. “There have been numerous court cases in the past that have cited CEQ guidance—not as binding, but as evidentiary of what best practices are,” Sarinsky said.

Already, the Biden administration faces at least two lawsuits—over its approval of ConocoPhillips’ Willow oil drilling project in the Arctic and over a large offshore oil lease sale that was held on March 29 in the Gulf of Mexico—claiming, among other issues, that agencies failed to follow the new guidance on NEPA. Meanwhile, the oil and gas industry appears to be alarmed by the new guidance. The American Petroleum Institute, which has made speeding the NEPA process a top lobbying priority, has called on the Biden administration to rescind its guidance on climate-impact accounting as “unprecedented and unsound.”

Environmentalists counter that the guidance needs to be strengthened. For one thing, they say, the language should make clear that carbon impact of such projects should not be dismissed as “temporary,” given the relentless pace of climate change. 

The public has until the end of April to file objections to the Custer Gallatin plan, and the White House has signaled it may amend the CEQ’s guidance in response to public comments it is accepting through April 10. Carolyn Ramírez, a staff scientist at the Natural Resources Defense Council, said environmental groups are submitting comments to CEQ urging that agencies supply an explicit timeline for any claimed offset or reversal of a project’s total carbon emissions. 

“If you cut down a bunch of 80-year-old stands that are starting to have old-growth characteristics, it will obviously take 80 years or more to get those qualities back in that forest,” Ramírez said. “And that’s too much time for us to say that the current greenhouse gas impacts are minimal. We don’t have 100 years.”

This article is part of “Deforestation Inc.,” a global investigation organized and led by the International Consortium of Investigative Journalists in collaboration with 39 media partners. At climate talks in 2021, world leaders pledged to halt forest loss and degradation by 2030. During a nine-month investigation, 140 journalists from 27 countries delved into why and how nations are falling short of meeting that goal.