March 1, the Trump administration announced two forestry-related executive orders that seem designed to discourage imports of timber and lumber--and encourage more harvesting in the U.S. It remains to be seen whether they will work, and at what economic and environmental costs.
These forestry executive orders take on longstanding challenges
This week's announcement shows President Trump's interest in boosting domestic production of forest and wood products. The tandem effort to increase domestic production while reducing reliance on imports takes aim at two longstanding challenges in the sector.
The first is the buildup of trees and biomass in federal forests due to very limited harvests on national land over the past 25 years. This backlog has increased wildfire risk and severity while also causing economic decline in mill towns close to federal lands. At the same time, environmental champions say these limits on harvests are vital to protect biodiversity and other environmental outcomes.
The second is U.S. reliance on imports. This challenge shows up in different ways, from imports of Chinese wood furniture or plywood to the softwood lumber dispute between the U.S. and Canada, which has continued for over 40 years without a permanent resolution.
Cascade lays out the two executive orders (EOs) below.
EO #1: Section 232 investigation
President Trump ordered a Section 232 investigation into "lumber and timber" imports in Executive Order 14223. A Section 232 is a type of trade investigation that looks into whether certain imports threaten the U.S. industrial base.
For Section 232 investigations, the Department of Commerce’s Bureau of Industry and Security (BIS) conducts an investigation into a particular sector to determine the effect of imports into national security. Where most actions on trade require approval from Congress, Section 232 allows the President to unilaterally act to “adjust the imports of an article and its derivatives” – that is, to impose tariffs or take other measures.
The Secretary of Commerce must provide a report and recommendation for action to the President within 270 days. The President then has another 90 days to take action (or not). For lumber and timber, President Trump has indicated he wishes to move quickly.
Based on other Section 232 investigations initiated by the Trump administration in his first term, the likely outcome of this investigation is higher tariffs on imported products.
The investigation will include a full supply chain analysis
Trump has directed this study to include:
Current and projected demand for timber and lumber in the U.S.;
Ability of domestic production of timber and lumber to meet domestic demand;
The role of foreign supply chains, including the role of major exporters to the U.S.;
Feasibility of increasing domestic timber and lumber production;
Impact of current trade policies on "domestic timber, lumber, and derivative product production;" and
Whether additional measures are necessary to reduce imports.
It is unclear at this point which specific products will be covered by the investigation because the terms given, "lumber and timber," are fairly general. Cascade assumes the majority of wood products will fall under the scope of the investigation, though it remains to be seen which (if any) products will have tariffs levied on them.
There will be opportunities for public participation
During the process, there will be opportunities for companies and organizations to submit formal comments and meet with the government officials carrying out the probe. There may be questionnaires provided to companies or trade associations, and there may be special hearings.
EO #2: Increased harvest on federal lands
Immediate Expansion of American Timber Production, Executive Order 14225, takes several actions to speed up harvest on federal lands. It sets out the following timeline:
Within 30 Days: The Bureau of Land Management (BLM) and the U.S. Forest Service are to provide recommendations to "facilitate increased timber production and sound forest management, reduce time to deliver timber, and decrease timber supply uncertainty."
Within 60 Days: The Fish and Wildlife Service (FWS) and NOAA Fisheries must submit recommendations on how BLM and USFS can streamline forest management practices under Section 7 of the Endangered Species Act (ESA).
Within 90 Days: Interior and USDA provide recommendations to the President for four-year targets of timber sales from federal lands.
Within 120 Days: BLM, FWS, and USFS complete the Whitebark Pine Rangewide Programmatic Consultation under section 7 of the ESA.
Within 180 Days: BLM and USFS must adopt categorical exclusions from other agencies to comply with NEPA permitting requirements to "reduce unnecessarily lengthy processes and associated costs related to administrative approvals for timber production, forest management, and wildfire risk reduction treatments."
Within 280 Days: Secretary of the Interior to establish a categorical exclusion for thinning and re-establish a categorical exclusion for salvage harvest.
The EO also calls on agencies to streamline and minimize all permitting. Finally, it encourages substantial use of the emergency provisions of ESA to minimize ESA compliance requirements.
Is this good policy?
Yes and no. Increasing harvest levels can thin forests, reduce wildfire risk, and reinvigorate these communities. USFS and BLM have very slow and cumbersome policies to arrange harvests and timber sales, meaning they currently happen very rarely. With harvest on federal lands at near record lows for the past two decades, fuel has built up on public lands, increasing the risk of very hot and very dangerous wildfires. At the same time, lack of harvest has led to the closure of sawmills that depended on harvests from federal lands, along with all the jobs in those communities that supported the sector.
There are also risks. Bypassing important permitting checks could lead to negative impacts for the environment, including soil and water quality. Limiting reviews under ESA could also potentially lead to negative outcomes for the wildlife that depends on those forests.
There are also questions about whether the Forest Service and BLM could actually complete the work laid out. These concerns are especially urgent given recent announcements about additional planned staffing cuts to agencies that already say they are understaffed.
Opportunities for public participation are likely
While no specific opportunities for participation have been laid out, it is likely that at least some of the actions in this EO will have to go through the federal rulemaking process, providing opportunities for public comment. USFS and BLM will also need industry participation in order to meet any updated harvest targets.
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