Submitted Electronically via eRulemaking Portal

black-backed woodpecker are clearly threatened by the cumulative effects of a variety of activities on federal and non-federal lands including all forms of logging (salvage, sanitation, regen, fuel reduction, thinning, hazard tree removal, firewood cutting, biomass utilization) that export mortality, plus fire suppression, road construction, land conversion, etc. Practices on non-federal lands are unlikely to change. Some practices on federal land are changing but not enough. The scope and extent of ongoing and planned fuel reduction logging is staggering and will have significant effects on the recruitment of snag habitat for black-backed woodpecker and other species. In a natural forest virtually all the trees that die in the forest stay in the forest and provide a variety of ecosystem services, including woodpecker habitat. Dead trees are mostly removed when they are converted to CO2 through combustion or respiration. Under current management, the vast majority of trees are killed prematurely and exported/diverted to human uses which means that they cannot perform habitat functions in the forest. The Blue Mountains Forest Plan Revisions produced a viability assessment for the pileated woodpecker that highlights the cumulative consequences of all the human actions that reduce recruitment of dead wood. This has implications for black-backed woodpeckers as well. The viability assessment at page 4 reports that historically, about half the landscape had abundant snags and half had few snags. Now about 90% of the landscape has few snags and 10% has many snags. That is a huge shift in snag abundance. The black-backed woodpecker should be listed as threatened until forest mangers can adjust their thinking about the full cycle of forest establishment/growth/death of forests and actions to retain and recruit more mortality processes and dead trees.