Eastside Forest Scam: the Proposed Removal of the 21-Inch Rule

Old-growth grand fir on the Ochoco National Forest could be logged if the proposed removal of the 21-inch rule is adopted. Photo by George Wuerthner.

The Forest Service has begun a 30 day comment period on its proposal to eliminate the 21-inch rule or what is known as the Eastside screens. The plan would remove a prohibition against cutting trees larger than 21 inches in the drier forests east of the Cascades in Oregon and Washington. The agency suggests that forests are denser than historical conditions and have shifted in their species composition. Not all researchers agree with this interpretation, but since these scientific studies don’t support more logging, they are usually ignored.[1] [2]

The agency researchers conclude that thinning forests is necessary to promote “forest health” and cutting of larger trees will hasten this transition.[3] Since big trees enhance the profitability of timber sales, there is intense pressure from the timber industry for cutting big trees.

However, the elimination of the 21- inch rule will increase the removal of large trees critical to healthy forest ecosystems.

The 21-inch rule was implemented in 1994 to protect larger trees larger from logging, partially in response to the realization that big trees have a disproportional ecological influence. Unlike the ancient forests west of the Cascades inhabited by the spotted owls, which gained some protection from the Endangered Species Act, eastside forests were vulnerable to the removal of old-growth forests.

Large trees, even if dead, provide important ecological functions such as carbon storage and wildlife habitat. Photo by George Wuerthner.

In response to the loss of large trees created by excessive logging, Congress convened a scientific panel to review the issue. However, unlike many such scientific panels that rely exclusively on forestry schools and/or the Forest Service for advice, Congress asked the Wildlife Society, the American Fisheries Society, the Society for Conservation Biology, and the American Ornithologists’ Union to produce the Eastside Forests Scientific Society Panel report.  The panel came out with 13 suggestions, including a prohibition on cutting larger trees older than 150. The Forest Service adopted this policy recommendation.

But times have changed. With the advent of the Trump Administration, there is intense pressure to increase the cut of timber. This pressure, along with collaborators who are more than willing to accommodate the timber industry’s and Forest Service demands (and rely exclusively on their science), many members of collaboratives including some so-called environmental groups support more logging.

In yet another example of the tail wagging the dog, the Forest Service now suggests that to “restore” eastside forests, and “save” them from (god forbid) death from wildfire or beetles, the agency must log the forest.

Part of the underlying assumption behind restoration is that forests are denser now than in the historical past due to fire suppression. The idea that you can restore the forest to some “historic” condition ignores the fact that all vegetation is a reflection of climate. The reason we see more mortality from fires, beetles, drought, and other ecological processes is primarily to changing climate. It’s warmer and drier. With less precipitation, higher temperatures, and more drought, you have the perfect ingredients for wildfire and bark beetle mortality.

There are many things wrong with this perspective. Trying to emulate the historic forest condition created by the climate at that point in time, is not relevant to the forest structure today.

Part of the assumption behind removal of 21-inch screens is that eastside forests were characterized by open stands dominated by ponderosa pine as seen here. However, some researchers challenge the assumption that such forest structure was as common as presumed. Photo by George Wuerthner.

Furthermore, natural evolutionary processes like bark beetles, drought, and fire are better, selecting which trees should and will survive than a logger with a chainsaw.  For instance, it has been demonstrated that some trees have greater resilience to bark beetle predation, but this genetic advantage is not readily visible to foresters. [4] By randomly logging/thinning the forest, logging may reduce the number of trees with genetic resistance to natural stresses, degrading the “resiliency” of the forest.

In a sense, the Forest Service and its collaborative allies see natural ecological processes like fire and beetles as the “enemy”. Somewhat like the attitude of some hunters view predators like wolves and cougars as “damaging” the deer and elk herds, many foresters and agency personnel view natural mortality from fires and beetles as counter to forestry goals of “green trees” and a source of fodder for sawmills.

Western larch, Glacier Mountain, Strawberry Mountains, Malheur National Forest, Oregon.

This industrial forestry perspective is widely held in the timber industry, Forest Service, and its collaborative allies.

Yet dead trees are essential to healthy forest ecosystems. They store carbon. They provide habitat as snags and down wood to many species from salamanders to animals as large as bears. For instance, grizzly bears rely on ants found in down trees for a significant proportion of their summer diet. And down trees in streams enhance the productivity of aquatic ecosystems. A substantial portion of birds and other wildlife utilize snags and dead trees at some point in their lifecycles. This is why some researchers have reported high biodiversity in the snag forests that result after a wildfire or bark beetle attacks. [5]

Another rationale for eliminating the 21-inch rule is to reduce competition for resources and increase the remaining trees’ growth. Fast-growing trees are a goal of the Industrial Forestry Paradigm, but it is not necessarily good for healthy forest ecosystems. Slow-growing trees have denser wood, which makes the snags and down wood that remains after they die more resistant to rotting. Therefore, such dense wood is retained longer in the environment providing the above wildlife habitat and carbon storage benefits.

Although it is seldom admitted, one of the chief reasons for removing the 21-inch rule is to increase the economic viability of logging projects. This is revealed in a recent review of the 21 inch rule in a paper recently published by the Forest Service.[6] In that review, the authors suggest, ” Including larger trees in restoration prescriptions can increase the acreages where fuel treatments are financially feasible. Prestemon et al. (2012) showed that allowing the harvest of live trees over 21 inches increased the acreage in the West where fuel treatments were economically viable, even without considering avoided damage values”.

The paper goes on to note that: “Throughout the West, including live trees over 21 inches in fuel treatment harvests increased the viable treatment area by 2.6 times.”

The review also notes: “It is important for managers and stakeholders to consider how large harvested trees can be processed locally to support local mills and be consistent with collaborative group goals.”

Here we see that meeting the goals of the collaboratives is more important than preserving healthy forest ecosystems.

The review admits that: “if no timber products could be sold from forest restoration actions, there was no place on the east side where the expected net economic benefit from fuel treatment would be positive, even when accounting for avoided wildfire damage.”

As a consequence, we get to the heart of the issue. Without logging big trees, most thinning and other projects on eastside forests make no economic sense.

One way logging is further justified is by stewardship contracts. Stewardship contracts permit the Forest Service to take profits from timber sales and utilize for other forest projects like mitigating the ecological damage from previous logging projects by removal of culverts or closure of roads.  I have often heard the so-called environmental representatives on collaboratives justify logging to me by saying, “don’t you support removing culverts and closing roads?” Of course, I support closing roads, but we don’t need to build more roads and log the forest to get some money to fix the damage from previous logging projects. Given the amount of money, the FS typically loses on timber sales. Putting agency funds towards road closure and other real restoration could be accomplished without having to log the forest to pay for these projects.

If you wish to send in your comments on the proposal to eliminate the 21-inch rule, individuals and entities are encouraged to submit comments via webform at https://cara.ecosystem- management.org/Public/CommentInput?project=58050. Comments may also be sent via e-mail to SM.FS.EScreens21@usda.gov.


[1]Baker, WIliam. (2017) Restoring and managing low-severity fire in dry-forest landscapes of the western USA https://doi.org/10.1371/journal.pone.0172288

[2] Baker WL, Ehle D. Uncertainty in surface-fire history: the case of ponderosa pine forests in the western United States. Canadian Journal of Forest Research 2001; 31: 1205–1226.

[3] The 1994 Eastside Screens, Large-Tree Harvest Limit: Review of Science Relevant to Forest, Planning 25 Years Later

Paul F. Hessburg, Susan Charnley, Kendra L. Wendel, Eric M. White,

Peter H. Singleton, David W. Peterson, Jessica E. Halofsky, Andrew N. Gray,

Thomas A. Spies, Rebecca L. Flitcroft, and Rachel White General Technical Report, PNW-GTR-990, August 2020

[4]Diana L. Six, 1*, Clare Vergobbi, 1 and Mitchell Cutter 2 Are Survivors Different? Genetic-Based Selection of Trees by Mountain Pine Beetle During a Climate Change-Driven Outbreak in a High-Elevation Pine Forest Front Plant Sci. 2018; 9: 993.

[5] Hutto, Richard. Toward Meaningful Snag-Management Guidelines for Postfire Salvage Logging in North American Conifer Forests Conservation Biology, Volume 20, No. 4, August 2006

[6] The 1994 Eastside Screens, Large-Tree Harvest Limit: Review of Science Relevant to Forest, Planning 25 Years Later

Paul F. Hessburg, Susan Charnley, Kendra L. Wendel, Eric M. White,

Peter H. Singleton, David W. Peterson, Jessica E. Halofsky, Andrew N. Gray,

Thomas A. Spies, Rebecca L. Flitcroft, and Rachel White General Technical Report, PNW-GTR-990, August 2020

George Wuerthner has published 36 books including Wildfire: A Century of Failed Forest Policy. He serves on the board of the Western Watersheds Project.