Protecting Large and Mature Trees: What's at Stake in the Blue Mountains Forest Plan

Forest in the foreground, Hells Canyon in the background. The view of Freezeout Saddle from Harl Butte.

The public comment period for the forest management plan that will become the new rulebook for how three eastside forests will be managed is open until September 30th. The Umatilla, Malheur, and Wallowa-Whitman National Forests are due to receive a new management plan by the end of this long-overdue process.

During these last weeks where we have the opportunity to weigh in, we will be sharing a series of blog posts focusing on specific issues that are top of mind as an organization and as a community of people who care deeply about the health of the ecosystems within eastside forests. This blog focuses on the threats that the proposed plans pose to old and mature trees, an irrefutably vital character in the story of ecosystem health. Before we dive too deep into the weeds, though, here are the basics.

Forest Management Plans... What are they?

Forest management plans are the overarching documents that decide how an individual National Forest will be managed for the next 15+ years. They set intentions for how landscapes will be treated during that time, and at their best, plan for a future where the agency can achieve all of its competing goals under one plan (like logging, providing habitat for endangered species, etc.).

Historically, forest plans in this region have included guardrails for a range of activities in order to strike a balance between industrial activities and ecological considerations. This included guidance on questions like: where is it appropriate to commercially log, graze cows, or build roads? They also included clear protections (with some flexibility built in) for old growth trees, roadless landscapes, and other special features.

GHCC does not broadly oppose all logging, but we do oppose what’s currently proposed in the new draft forest plans: removing all protections for mature and old-growth forests, and opening up previously protected roadless areas to huge amounts of commercial logging. The proposed plans intend to increase logging by three to four times the current baseline, and the way they’d achieve this objective is by logging our last intact and ancient forests.

What Protections Currently Exist for Mature and Old Trees?

The Wallowa-Whitman, Umatilla, and Malheur National Forests (among other eastside forests in the region) all have a rule in the existing forest plans called the "Eastside Screens" or the "21-inch rule". This Forest Service policy was enacted in 1995 to protect many trees measuring over 21 inches in diameter at breast height (DBH) from being cut. It was created after over a century of liquidating old growth forests in the northwest. Once it became apparent that the remaining old growth habitat was dwindling rapidly, the Eastside Screens were put into place to "stop the bleeding" and "right the ship." The decision to heavily regulate logging of the few remaining large trees still left on the landscape is based in science, but protections for these trees are absent from the new draft plans.

Why Mature and Old Trees Matter

Picture one of those huge, gnarled old trees you’d be lucky to come across on a hike, the kind that makes you stop and put your hand on the bark or engage in tree-hugging behavior. Trees like this are supporting entire ecosystems.

Since the Eastside Screens were enacted in 1995, we have come to understand much more about how wildlife and the broader ecosystem rely on large trees. The “21-inch rule” was originally adopted as a wildlife conservation standard due to the large amount of native large tree, large snag, and old-growth-associated wildlife in the region (Bull et al. 2005; Interior Columbia Basin Ecosystem Management Project 2000). Species like American marten and Northern goshawk depend heavily on the habitat provided by large and mature trees. Grand fir in particular plays an outsized role here: its relatively soft wood forms natural hollows and cavities that species like American marten and pileated woodpecker depend on for shelter, nesting, and foraging. These “late seral” (or mature) stands make up less than 3% of the forested landscape across the interior Columbia River basin, and young stands can't reproduce this structure for 150 to 200 years.

These trees also do outsized work as carbon sinks. Despite comprising only about 3% of all trees on Forest Service lands, large trees store roughly 42% of aboveground carbon in these forests (Mildrexler et al. 2020).

And ironically, the trees now being targeted are the ones best equipped to survive fire. Large trees of all species are the most fire-resistant on the landscape. Trees native to this region evolved alongside wildfire as part of a natural disturbance regime, and as they grow, their thick bark and height give them a natural resistance to it (Moris et al. 2022).

How "The Screens" Work

The general goal of this rule is to ensure that we don't lose more old-growth forests and that young forests stay on track to replace large and mature trees once they die. It has a general diameter limit on cutting (hence, the 21"), but it also contains flexibility that allows the Forest Service to cut big trees on a case-by-case basis in situations where they can show big trees are already abundant “enough” in a specified area. All that to say, this is already a compromise-type rule where special cases to harvest old and mature trees can be (and are) made.

The 2021 Rollback of the Eastside Screens

Since the Eastside Screens were created in 1995, getting rid of the 21-inch rule has been on the timber industry's wish list. In 2021, they got their wish, at least for a while. The Eastside Screens Amendment rescinded the mandatory rule, replacing it with a loosely defined and borderline unenforceable guideline about which trees could be removed from eastside forests.

In 2022, GHCC, along with Oregon Wild, Central Oregon LandWatch, Great Old Broads for Wilderness, WildEarth Guardians, and the Sierra Club, filed a lawsuit, arguing the amendment violated the National Environmental Policy Act and the National Forest Management Act. GHCC also submitted a notice of intent to enforce Endangered Species Act protections for old-forest-dependent fish and wildlife. We were successful, and the 21-inch rule stayed in place. But here we are again: The Blue Mountains Forest Plan revision is another attempt to strip away the same protections, and once again, it's happening without the proper analysis and amount of public input an important decision like this deserves.

Forest Types in the Blues - Getting into the Weeds

It's often assumed that much of eastern Oregon's forests are dry, ponderosa pine-dominant forests, but we have a rich diversity of forest types in our region. There are also moist mixed conifer stands, where grand fir plays a central role.

Different forest types perform different functions. Dry ponderosa stands recover from fire quickly and support species that thrive in open, sun-dappled conditions, while moist mixed conifer stands stay cooler and wetter, giving grand fir and the wildlife that depend on it room to establish. A landscape made up of only one forest type has only one way of responding to disturbance, whether that's fire, drought, or a warming climate. A mosaic of forest types means more options for the forest and for the species that rely on it.

The proposed draft plan’s focus seems to be mostly on dry forests – and overlooks the importance of moist forests almost entirely. This is compounded by an ongoing, unresolved problem: how to accurately age grand fir. The Forest Service has regularly stated that "old" trees will be protected from logging, while treating grand fir over 21 inches DBH as "young," even when those trees are between 80 and 150 years old. This has repeatedly been the agency's justification for logging grand fir under 31 inches DBH. But according to the agency's own coring data, many grand fir trees are over 150 years old at 21 inches DBH and above, and there isn't a reliable method to age them in the field. Unlike species with more distinctive bark or crown changes as they age, grand fir gives few reliable outward clues to its age. Size is one of the only things that indicates age, which makes raising the diameter threshold for logging grand fir especially consequential. All this to say, we need to use the right type of management for the type of forest that we are proposing a management plan for. We know better.

What the Proposed Alternatives to the Plan Do (and Don't Do)

We are at another very important juncture and decision-making point for large trees in eastside forests. There are so many elements of the proposed plan worth considering: riparian habitat protections, protecting roadless areas from unnecessary road construction, and more. But here we are again, asking you to speak up for a major, outsized player on the landscape: large and mature trees. The Forest Service’s preferred alternative removes all protections for large trees, and would allow the logging of any tree regardless of age, size, or species. We're playing tug-of-war with the future of what little old growth remains.

The Forest Service's own language acknowledges that these trees are necessary for resilience and wildlife habitat, but it (at best) backs that acknowledgement with flimsy guidelines, not standards. Guidelines are not the same as enforceable protections. Throughout the Draft Plan, the agency relies on voluntary, discretionary language rather than mandatory standards, which means the Forest Service can log large trees in nearly any situation so long as it can point to some indication that doing so still moves the landscape toward its own loosely defined desired conditions. See how murky that sounds? It's not a coincidence.

It feels like we are in an era where nothing means anything anymore, and this is a precarious and dangerous place to be for the natural world, which relies on ecosystem function to survive. We're seeing simultaneous attacks on the Endangered Species Act, the Roadless Rule, and the Travel Management Rule — all efforts that seek to fundamentally reshape how fish and wildlife are valued on public lands.

As GHCC member Pete Sandrock wrote in his December newsletter, "habitat will no longer be protected by the ESA under a pending rule change; degrading the habitat of an imperiled species will no longer count as harming it. Only direct harm will be prohibited. Timber companies, for example, will be able to log coastal forests so long as they don't cut the specific trees containing [ESA-listed species]. Everything else, including the adjacent trees, is fair game."

Without the protection provided by the Eastside Screens, which risks being washed away as the new forest plan alternatives ratchet up timber targets, we fear that this same kind of redefinition will be weaponized against eastside forests in the most devastating way. Strong protections in forest plans are the only buffer against this national turmoil.

What's at Risk

Just like every piece of an intact ecosystem plays a vital role, every piece that gets eroded affects the entire system. Much of our work focuses on how the Blue Mountains ecoregion is a habitat connectivity super-corridor: the "road" that wildlife travel as they migrate and seek refuge from a warming climate in our dense, wet, mixed conifer forests. These forests shade rivers and streams used by salmon and trout to spawn. Forests provide home, shelter, and resilience. Large and mature trees are the ones most able to withstand the disastrous effects of a warming climate, and they support other species in doing the same. This includes charismatic megafauna like elk, keystone species like salmon, and humans. We need forests. We need large trees.

When we talk about removing large trees from the landscape, we're talking about large-scale degradation and fragmentation of some of the last best habitat that makes the Blue Mountains so special. When we talk about harvesting trees over 21 inches, we're talking about logging the next generation of legacy trees. You can plant new trees, but how long will it take for them to become a fully functioning forest? And will they ever be able to replicate the complexity of what we currently have? This is not a good solution, and it's far less fire-safe.

As always, we are also concerned about Indigenous treaty rights and consultation when it comes to decision-making on public lands. Tribes hold treaty-reserved rights, including fishing, gathering, and cultural uses, that are in part tied to intact forest ecosystems. Big trees and old-growth stands are part of that ecological base, not separate from it. With timber targets tripled or even quadrupled, roadless areas opened to new road construction, and protections under the Eastside Screens on the chopping block, this administration's intentions for eastside forests seem clear, and the impacts will be felt for generations to come.

What You Can Do

The public comment period on the Blue Mountains Forest Plan is open through September 30, 2026, and we encourage you to speak up for eastside forests and large and mature trees. When you do, your comments become part of the official record, and that matters. We have resources available to help you craft an impactful comment, which the Forest Service is legally required to consider. Please use this link to learn more about how you can speak up for big trees in the Umatilla, Malheur, and Wallowa-Whitman National Forests.

Blue Mountains Forest Plan comment resources