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DNR Ignores its Own Policy Commitments

Continues to Clearcut Many of the Oldest Remaining Lowland Legacy Forests in Western Washington


Existing DNR plans, policies, and statutes provide a solid framework for the management of our publicly owned state forestlands.  This framework is built (in part) on the assumption that DNR will protect and manage structurally complex forests to restore old growth conditions across a minimum of 10 to 15 percent of state forestlands in Western Washington.  Approved procedures for preparing regional plans to manage structurally complex forests to meet these targets are provided HCP implementation procedures for Managing Structurally Complex Forests to Meet Older Forest Targets (PR 14-004-046).


Since these procedures were approved in 2007, DNR has only completed plans for two regions (or HCP “planning units”).  No plan has been completed for the other four regions of Western Washington. Furthermore, the plan for the South Puget Sound planning unit has not been updated since 2010, and planning unit boundaries are outdated and inconsistent with currently established ecoregional boundaries.


DNR has tried to argue both in public, and in court, that the Estep & Buffo analysis, conducted in 2021, demonstrates that DNR is on track to meet their old growth targets.[1]  However, the Estep & Buffo analysis does not constitute a plan, as defined under PR 14-004-046, which requires that DNR:

 

  1. Identify structurally complex stands within each region or planning unit that are currently protected (i.e. located within a conservation area that is excluded from commercial logging).

  2. Determine if protected, structurally complex forests constitute at least 10% of the planning unit.

  3. If less than 10% of the HCP planning unit contains protected structurally complex forests, designate additional suitable structurally complex forest stands to be protected and managed to meet the 10-15% old growth target.

 

[1]  See 2nd part of Chair Report on Older Forest Policy, prepared by Mike Buffo (begins on Slide No. 75): https://www.dnr.wa.gov/publications/em_bc_bnr_olderforestchr_060121.pdf 


According to PR 14-004-046, suitable structurally complex stands are to be prioritized for protection, based on criteria such as (a) stand size; (b) proximity to old growth or other structurally complex stands in the ownership block; (c) scarcity of other structurally complex stands in the ownership block, landscape, or watershed; and (d) other existing strategic plans.

 

The Estep & Buffo analysis does none of these things:

 

  • Estep & Buffo made no attempt to identify or map structurally complex forests within each planning unit.

  • Estep & Buffo provided no information on the distribution of structurally complex forests across each planning unit, or how many acres of structurally complex are currently protected.

  • Estep & Buffo never identified or mapped suitable structurally complex stands to be managed to meet the 10-15% target. 

 

PR 14-004-046 further requires that the SEPA checklist for any proposed timber sale in stands with structurally complex forests must include information about “the role of the structurally complex stand in meeting older forest targets.”  DNR has failed to provide this information for any of its timber sales.

 

Instead, DNR management staff have consistently misinterpreted Board policies, and relied on false and misleading information to support the unfounded assumption that most structurally complex forests have already been protected.  DNR staff have done this by misclassifying areas that are available for commercial harvest as conservation areas, and vastly overestimating the fraction of the land base that has actually been set aside for conservation.

 

The Legacy Forest Defense Coalition has lead the way in modeling natural forests across Western Washington that are either structurally complex or close to becoming structurally complex.  Results reveal that DNR is clearcut logging many of the oldest and most structurally complex lowland forests that remain in Western Washington.


Timber Sales Planned Over the Next 18 Months Would Clearcut 7,000 Acres of Legacy Forests


State timber sales planned for auction over the next 18 months would clearcut close to 7,000 acres of legacy forests, and seriously undermine the agency’s ability to comply with its own legal and policy requirements. It is important to understand that while most legacy forests exhibit characteristics of structurally complex forests, not all legacy forests are structurally complex.  While our models show that close to two-thirds of all legacy forests in Western Washington are protected, this does not mean that DNR has met their obligation to protect structurally complex forests.  DNR has been quick to point this out, and has denied that many legacy forests mapped by LFDC are structurally complex.  In fact, an unpublished analysis conducted by DNR found that protected, structurally complex forests constitute less than 5% of state forestlands across Western Washington as a whole (excluding the OESF), and less than 2% of some planning units.

 

RCW 43.30.215 directs the Board of Natural Resources to “establish policies to ensure that the acquisition, management, and disposition of all lands and resources within the department's jurisdiction are based on sound principles designed to achieve the maximum effective development and use of such lands and resources consistent with laws applicable thereto.”  The Board has the authority to ensure that the already-established policies, including PR 14-004-046, are implemented by:

 

  • Asking questions;

  • Reminding DNR staff of their obligations;

  • Proposing new Board resolutions that provide opportunities for greater public participation and oversight to ensure DNR compliance with Board-approved policies.

  • Voting "no" on timber sales that would clearcut structurally complex forests. 

 

There is no plan, policy, or statute that requires or encourages DNR to target the oldest, most carbon dense, biologically diverse, and structurally complex forests for commercial logging. Before proposing any more timber sales in forests that pre-date World War II, or exhibit characteristics of structurally complex forests, it is imperative that DNR staff:

 

  1. Work with stakeholders to reach a common understanding of how much of the land base has set aside for conservation.  This should be a top priority for the Carbon and Forest Management Work Group.

  2. Develop a clear protocol for classifying stands by development stage.

  3. Identify and map all remaining natural and structurally complex forests in Western Washington – both protected and unprotected.

  4. Update planning unit boundaries so that they are consistent with ecoregional boundaries mapped by DNR in cooperation with the US Forest Service, EPA, USGS, Natural Resources Conservation Service, Nature Conservancy, and Washington State Department of Ecology.

 

This will provide an essential foundation for further planning and analysis necessary to meet DNR’s legal commitments.

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