21″ Wildlife Screens: Proposed Changes

BMBP’s Statement on the Forest Service’s proposed changes to the 21″ Wildlife Screens:

Under pressure from the Trump administration to increase logging, the Forest Service is proposing to gut protections for large trees on National Forests in eastern Oregon 

The Forest Service is proposing to gut protections for large trees in eastern Oregon and dramatically increase logging of large trees across over 9 million acres on several National Forests. The agency’s proposal to roll back protections and 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 a proposal that would jeopardize old and mature forests across millions of acres of public lands.

Currently, the Forest Plans that guide management on these National Forests prohibit most logging of large trees (those ≥21” diameter at breast height (dbh)). This prohibition on logging large trees– known as the 21” 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. The Forest Service is proposing to 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’s proposal to severely weaken protections for large trees includes changing protections for large trees from a “standard” to a “guideline”. The current standard prohibits the logging of large trees; a guideline would merely suggest that large trees be protected, but is up to the complete discretion of the agency and therefore largely unenforceable.

The Forest Service has published an Environmental Assessment, rather than a more rigorous Environmental Impact Statement– 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. 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.

In the years since the 21” Wildlife Screens were implemented, the Forest Service has repeatedly pushed for increased logging of large trees, less oversight, and less public transparency. This push from the agency has become increasingly loud in recent years, usually in the context of timber sales and in their (now withdrawn) Blue Mountains Forest Plan Revision.

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.
  • 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.
  • 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.
  • We need to increase carbon sequestration and retain large trees and mature forests, which store the most carbon. Logging large trees would increase carbon emissions, and is exactly the wrong direction for addressing climate change.

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. 

While the Forest Service has primarily focused their public messaging on logging Grand fir trees ≥21” dbh, the agency also logs large Ponderosa pines and other trees. For example, timber sales such as the proposed Crow sale on the Malheur National Forest also include logging of  ≥21” dbh  Ponderosa pine and Douglas-fir trees (in this case, logging of Ponderosa pine and Douglas fir is proposed on approximately 3,378 acres of forest). 

BMBP is working with Tom Buchele at Earthrise Law Center, as well as coordinating with other allied environmental organizations, to challenge the Trump administration and US Forest Service decision to revise the 21” Wildlife Screens, and to ensure that large trees and structure, mature forests, and wildlife  habitats are protected across the landscape. We and our allies will continue to be fully engaged and keep the public informed on this issue.

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