21″ Screens Action Alert!

The Forest Service’s Final Environmental Assessment for their proposal to roll back protections for large trees is due out in January of 2021. While there is not currently an open public comment period (as of December 2020), you can still contact the Regional Forester’s office and tell them to withdraw their proposal to gut protections for large trees. 

You can contact the Regional Forester, Glenn Casamassa, at: glenn.casamassa@usda.gov. 

Let the Regional Forester and the Forest Service know that you support more protections for forests, not less!

Tell the Forest Service: do not eliminate protections for large trees on public lands in eastern Oregon. Mature and old growth forests need more protection, not more logging. 

Under pressure from the Trump administration to increase logging, the Forest Service is proposing to gut protections for large trees on approximately 9.5 million acres across several National Forests in eastern Oregon.

The Forest Service’s proposal to roll back protections and dramatically increase logging of large trees directly threatens biodiversity and wildlife habitats, and would increase carbon emissions and exacerbate the negative ecological impacts of climate change.

The Forest Service is pushing this timber grab through on an unusually tight timeline, during multiple national crises. While most people are struggling to stay safe and many are worried about where their next paycheck is coming from, the Forest Service is fast-tracking this proposal which would jeopardize old and mature forests across millions of acres of public lands.

Currently, the Forest Plans that guide management on these National Forests prohibits most logging of large trees (those ≥21” diameter at breast height (dbh)). This prohibition on logging large trees– known as the 21” Eastside Screens or the “Wildlife Screens”— was put into place in the mid-1990’s because of the well-documented deficit of large trees across the landscape due to logging and mismanagement.

Now, the Forest Service is proposing to eliminate or severely weaken the 21” Wildlife Screens on six National Forests: the Deschutes, Ochoco, Malheur, Umatilla, Wallowa-Whitman, and Fremont-Winema National Forests.

The Forest Service proposal to roll back protections for large trees would:

• Eliminate protections for large Grand fir and Douglas fir up to 30” dbh.

Tell the Forest Service: Large trees are biological legacies that are crucial for wildlife and ecological integrity— they need protection, not logging!

• Replace the current “standard” with a “guideline”. The current standard prohibits the logging of large trees, while the proposed guideline would merely suggest that large trees be protected. Adherence to the proposed guideline would be entirely up to the discretion of the agency, and largely unenforceable. The agency’s proposal not only allows the agency to log large trees through the elimination of the current standard— it actively encourages the logging of large trees.

Tell the Forest Service: Withdraw their proposal to gut protections for large trees and the wildlife species that depend on them. The Forest Service needs to cancel their plans to increase large tree logging. Tell the agency to drop their attempt to replace a protective standards with an unenforceable guideline.

• Eliminate the current protective standard for snags (standing dead trees) that seeks to provide adequate habitat for wildlife. Many species of wildlife depend on snags for key portions of their life histories, such as nesting. The agency’s proposed guidelines do not have clear goals or benchmarks for meeting the habitat needs of wildlife. Wildlife already face a deficit of snags in many forests, due to past and ongoing logging. The new guidelines, if implemented, would put many species that are already struggling or imperiled at further risk, and would also lack meaningful mechanisms for enforcement.

Tell the Forest Service: Increased logging of large trees will dramatically reduce the number of large snags, as far fewer large trees will be left to die and become snags in the future. It is essential to prioritize the protection of large trees and large snags in order to protect wildlife.

The ecological realities on the ground have not changed since the 21” Wildlife Screens were implemented: 

• There is still a deficit of large trees on the landscape in eastern Oregon. The 21” Wildlife Screens have only been in place for 25 years, and so trees across the landscape have had very limited time in which to become larger and begin to ameliorate this deficit. Since the Screens were implemented, the Forest Service has also continued to misuse loopholes and log large trees.

Tell the Forest Service: Logging large trees is ecologically destructive and ignores the values such as wildlife habitat and contributions to clean water to which large trees are essential. Logging got us into the current situation of not having enough large trees across the landscape— logging will not get us out of this situation. In addition, logging large trees will make forests more flammable.

• Many species of wildlife depend on large tree structure for their survival. The 21” Wildlife Screens were meant to protect this crucial wildlife habitat. Wildlife species such as Pileated woodpeckers, American marten, and numerous others still very much depend on large trees. Logging large trees will further threaten old-growth dependent species, especially species which are already imperiled, at-risk, or that depend on fir trees, complex canopies, and mature forests.

Tell the Forest Service: you care about wildlife species that rely on mature and old forests, including species such as Pileated woodpeckers, marten, lynx, goshawks, Great grey owls, and others.

• The Forest Service does not have any evidence to suggest that increased logging of large trees benefit wildlife or mimic the natural processes that forests depend upon, or result in the forest conditions the agency claims; or that it will not result in long-term and irreparable harm to wildlife, ecosystem processes, biodiversity, or water quality.

Tell the Forest Service: The agency is entrusted with protecting public forests and ensuring that wildlife, clean water, and recreational opportunities are preserved for future generations. The Forest Service’s proposal to increase logging of large trees violates the public’s trust and would decimate key wildlife habitats which are already at a deficit on the landscape. Logging does not mimic natural processes, and comes with a well-documented, long list of serious negative effects on wildlife, water, fish, soils, climate change, and more.

• Logging large trees would increase carbon emissions, and is exactly the wrong direction for addressing climate change.

Tell the Forest Service: We need to increase carbon sequestration and retain large trees and mature forests, which store the most carbon. The Forest Service’s proposal to increase logging of large trees is the wrong direction for forests, wildlife, and people.

• In order to allow species the best chance at surviving and adapting to climate change, we need to preserve wildlife corridors and large, un-fragmented high-quality wildlife habitats. Preserving large trees are key to these efforts. Unfortunately, increased logging of large trees will exacerbate some of the negative ecological effects of climate change and further limit the available high-quality wildlife habitat.

Tell the Forest Service: Large blocks of core habitat and wildlife connectivity corridors need to be protected from logging and ecological degradation. Increasing logging of large trees will degrade high-quality wildlife habitats, and make it harder for wildlife to adapt to or survive climate change. 

The Forest Service’s process for this proposal is deeply flawed:

Amidst the multiple ongoing crises we are currently facing, such as the pandemic, economic uncertainty, social upheaval, and the wildfires that have displaced hundreds of Oregonians, the Trump administration has ramped up proposals to gut environmental protections and to increase logging on public lands. Despite the suffering and uncertainty people are facing at this time, we are seeing an even greater push from the current administration to increase ecologically destructive extractive projects on public lands (such as logging and drilling), eliminate or curtail public transparency and participation, and roll back or severely weaken environmental protections. Federal agencies such as the Forest Service are now regularly proposing timber sales and other major projects with fewer opportunities for public comments, shorter comment periods, less public transparency, and less information regarding environmental impacts.

The Forest Service is using an abbreviated process with inadequate analysis to push through their proposal to gut protections for large trees:

• The 21” Wildlife Screens were put into place in the mid-90s in order to address the deficit of large trees across the landscape, and to protect the wildlife that depend on the habitats provided by those large trees. The Screens were meant to be an interim measure until the Forest Service could put a large, more comprehensive plan into place. By only focusing on this narrow proposal to greatly increase the logging of large trees, the agency is ignoring the need for a holistic analysis that considers crucial issues such as wildlife habitat, carbon sequestration, the importance of expanding core habitats and connectivity corridors, and other key ecological issues.

Tell the Forest Service: The agency needs to withdraw this ecologically destructive proposal, and instead develop a holistic and comprehensive plan that addresses issues such as ameliorating climate change and its ecological effects; ensuring robust wildlife populations and the recovery of imperiled species; preserving clean water; and providing quiet recreational opportunities.

• The Forest Service did not produce an Environmental Impact Statement which would be much more rigorous than the analysis the agency has put forward— despite the fact that increased large tree logging across six National Forests would clearly have significant environmental impacts. By claiming that changes to the 21” Wildlife Screens will not have significant effects, the Forest Service can skirt more stringent requirements which would otherwise force them to consider the cumulative impacts of their proposal and include longer public comment periods.

Tell the Forest Service: This project requires an Environmental Impact Statement.

• In an unusual move for such a controversial and environmentally significant proposal, the agency did not invite the public to submit written ‘scoping’ comments, as is usually done.

Tell the Forest Service: The agency should not be rushing this process through on a fast-tracked schedule, particularly during a time of multiple public crises, including a pandemic. Curtailing public input for this proposal is wholly inappropriate for such a significant proposal that would affect approximately 9.5 million acres of public forests. The Forest Service should restart this process, but with a comprehensive plan that prioritizes ecological protections for forests and includes an Environmental Impact Statement.

Taking a deeper dive— more details on the Forest Service’s proposal:

The Forest Service’s Draft Environmental Assessment, titled “Forest Plans Amendment: Forest Management Direction for Large Diameter Trees in Eastern Oregon” includes the agency’s proposed action, as well as two other alternative actions that the agency is analyzing for possible implementation. The proposed action is most likely to be the alternative that the Forest Service attempts to implement. Below is a brief description of the agency’s proposed action, as well as the alternatives they are analyzing. You can find the Forest Service’s Draft Environmental Assessment at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd779174.pdf.

1) “Old and Large Tree Guideline with Adaptive Management” (Proposed Action)

The Forest Service’s proposed action would completely remove protections for large Douglas fir, White fir, and Grand fir trees between 21” and 30” diameter at breast height (dbh)). Replacing the standard with a guideline also puts large trees of all species of at risk, including large Ponderosa pine trees.

The proposed action suggests, through a largely unenforceable guideline, that forest managers “should retain and generally emphasize recruitment of old trees and large trees.” The proposed guideline goes on to suggest that logging should “first prioritize old trees for retention and recruitment. If there are no old trees, the largest trees should be retained. Old trees are defined as having visual characteristics that suggest an age ≥150 years. Large trees are defined as grand fir, white fir, or Douglas-fir ≥ 30” dbh or trees of any other species ≥21” dbh. Old and large trees should be identified through best available science.”

Some issues specific to the Forest Service’s Proposed Action:

• The existing 21” diameter limit on logging was developed as a reliable, practical, easy-to-implement, and enforceable protection for large and old trees. Abandoning this common-sense standard and replacing it with subjective, non-existent, and extremely subjective guidance in the form of a non-enforceable guideline makes little sense.
• Many wildlife species need large trees, regardless of age. In particular, large trees with cavities are at a severe deficit on the landscape, and are especially valuable to wildlife.
• The Forest Service does not have a way to reliably identify ‘old’ Grand fir. The guidelines the agency is using to identify old trees specifically discuss that the visual attributes they utilize are not reliable for identifying old Grand fir. Studies that the Forest Service has used to try to bolster these guidelines in relation to Grand fir demonstrate that, for example, the best predictors of the age are attributes such as ground water availability and growth of adjacent vegetation. None of these guidelines provide clear, reliable, enforceable, or even practical guidance for implementation in the field to determine the age of Grand fir.

The Proposed Action includes an ‘adaptive management’ portion, which refers to the agency’s intent to monitor mortality of old trees in relation to the increased logging of large trees.

• The Forest Service has chosen not to monitor the effects of this proposal on key ecological components such as wildlife, snag densities, or water quality. Instead, the agency is proposing to focus on mortality of large trees— an overly narrow focus that says little about the overall ecological integrity, biodiversity, or wildlife habitat available in the forest.

  

• The agency has shown again and again that they are not able to reliably conduct basic monitoring of easily measurable attributes, such as water quality, on National Forests. Monitoring data and related information are usually not transparent, not well-organized by the agency, and not made easily available to the public. The public and environmental organizations are often forced to submit repeated requests and formal Freedom of Information Act requests in order to obtain (often incomplete and conflicting) monitoring data. The agency has demonstrated, time and again for decades, that it does not have adequate funding, organization, or political will to conduct basic monitoring on National Forests.

2) “Old Tree Standard Alternative”

This alternative would replace the current 21” dbh standard with a standard to protect trees 150 years old. Some issues with this standard include (also please see above for more in-depth discussion of the following issues):

• Large tree structure is important to wildlife, regardless of age.
• The Forest Service has no reliable, enforceable, and practical method for identifying old Grand fir trees.
• Logging mature large trees less than 150 years old would decrease the number of trees that would grow into old trees.

3) “Adaptive Management Alternative”

This alternative would eliminate the current 21” diameter standard, and all associated protections with large and old trees. The only ‘protection’ this alternative would offer is the same overly narrow and unenforceable adaptive management approach as described in the Proposed Action, which also does not consider wildlife, wildlife habitat, clean water, etc.

The current administration is pushing this proposal through while many people are overwhelmed and distracted with basic issues of safety and their basic needs, and are far less likely to be able to engage or participate fully in the public process. Don’t let them get away with it!

Please speak up to defend large trees, wildlife habitat, and mature and old growth forests!

Even brief comments are important! You can copy or paste from the talking points above, or use it as inspiration for writing your own. Personalizing your comments helps to ensure they are counted as unique. If you’ve spent time in any of the National Forests which would be affected by the proposed changes, please mention this in your comments. 

Blue Mountains Biodiversity Project is working with Greater Hells Canyon Council, Oregon Wild, Central Oregon Landwatch, Earthrise Law Center, and other allies to ensure we mount a strong challenge to the Forest Service’s attempt to gut protections for large trees. A helpful resource from our allies at Oregon Wild is their blog on the 21″ Screens, which includes some history on the screens. Thanks to all of these groups and everyone working hard to protect amazing forests and wildlands!

Thank you for commenting!