The state legislature passed a proviso last year, as part of the 2023-2025 biennial budget, that requires DNR to develop a new strategy to protect structurally complex forests and increase carbon storage and sequestration on state forestlands in Western Washington. The Climate and Forest Management Work Group was assembled last fall to guide and oversee this work. The work group is composed of tribal representatives, timber industry representatives, local elected officials, and three individuals who represent environmental and conservation interests. The first meeting was held on November 8th of last year, and meetings are scheduled to continue through June of 2025.
Tap here for list of work group members:
This Climate and Forest Management Work Group has the potential to dramatically change the way in which our state forestlands are managed, but faces a number of significant obstacles:
1. The legislation that created the work group does not require that DNR adopt the recommendations of the work group, nor does it specify how the work group's recommendations are to be interpreted or implemented by DNR. Duane Emmons, who spoke for DNR, said during the November 8th meeting that the purpose of the work group is to develop a "list of approaches for DNR to consider" which suggests that he does not view the work group's recommendations as binding on the agency. This lack of clarity is troubling, given DNR's track record, and could render all of the work that the group is doing irrelevant, unless there is some mechanism provided to hold DNR accountable for its actions.
2. Up to 8,000 acres of structurally complex forests are scheduled to be sold by DNR at auction over the next 18 months in Western Washington alone. The logging of these forests will dramatically alter the carbon storage and sequestration potential of the land base as a whole, and the climate resilience, and biological diversity of the watersheds in which these timber sales are located. There was no mention of upcoming timber sales during the first two meetings of the work group, and the formation of this work group does nothing to address this imminent crisis.
3. Dan Donato, a forest ecologist at DNR, began the December 6th meeting by giving a presentation to the work group on stand development stages. During this presentation, Donato described structurally complex forests as those that are over 150 years old, and have "abundant large wood and snags" and large trees with epicormic branches. There are three big problems with Donato’s definition of structurally complex forests:
(a) it effectively limits the universe of stands that are structurally complex to those that are already protected;
(b) it would eliminate virtually all unprotected legacy forests from consideration; and
(c) it is inconsistent with DNR's own planning and policy documents.
DNR's Policy for Sustainable Forests, 2004 Sustainable Harvest FEIS, 2007 Sustainable Harvest FEIS Amendment, and procedures for "Managing Structurally Complex Forests to Meet Older Forest Targets" all define "botanically diverse" forests as a subset of structurally complex forests in which "decayed and fallen trees are lacking in abundance.” Donato's characterization of structurally complex forests is therefore in direct conflict with DNR's own policy and planning documents.
In the real world, most of the structurally complex forests found on DNR managed lands defy classification because of the way in which they were logged. Prior to World War II, loggers typically left behind large snags, downed wood, and smaller understory trees. As a result, the forests that replaced them tend to be patchy, and composed of multiple tree species, including conifers like Douglas fir, spruce, hemlock, and western red cedar, often growing in dispersed clumps and inter-mixed with deciduous trees such as big leaf maple, red alder, and black cottonwood. Multiple stand assessments conducted by DNR have found that these legacy forests exhibit many features that are typically found only in old growth forests.
5. DNR has provided little to no information on how contractors will model different management scenarios or how those models may be used by DNR to establish sustainable harvest targets for the next planning decade. If the contractors’ models are not compatible with DNR’s Forest Estate Model, then it will be difficult if not impossible for DNR staff to replicate them. In addition, there has been no mention during the work group meetings of BNR resolution 1591, which instructs DNR to incorporate multiple objectives into its Forest Estate Model. It is essential that the contractors work in cooperation with DNR staff to revise and update the Forest Estate Model, so that the modeled scenarios can be easily replicated and implemented by DNR.
6. In order to protect structurally complex forests, they must be mapped. In the past, DNR has mapped structurally complex forests using various metrics extracted from their forest inventory database. However, DNR’s forest inventory data is fundamentally flawed and based on outdated forest inventory unit boundaries. These boundaries are often meaningless, crossing multiple stands with different origin dates. DNR also consistently underestimates the age of legacy forests by 10 to 15 years, and in some parts of the state, the origin dates provided in their forest inventory database are off by 30 or more years. It is impossible to model structurally complex forests without updating the forest inventory unit boundaries.
7. Paula Swedeen, a member of the work group, who represents Conservation Northwest, suggested during the December 6th meeting that the work group should examine a scenario that includes protecting the remaining 70,000 acres of unprotected legacy forests in Western Washington. John Talberth, Director of the Center for Sustainable Economy, echoed the need to protect existing legacy forests, explaining that DNR is "nowhere near" meeting its older forest targets, and that it makes no sense to sacrifice the most biologically diverse, carbon dense, and fire resistant stands that remain. However, the overwhelming emphasis during the first two work group meetings was on "managing" older forests, including those in currently protected areas. (The word “managing” is often used by DNR as a euphemism for “logging”). Before DNR requests more funds to do more logging to accelerate the development of structurally complex habitat, it needs to emphasize first the need to stop clearcutting existing structurally complex forests.
8. DNR needs to provide the work group with honest and accurate information on the distribution of high quality spotted owl habitat within Spotted Owl Management Units (SOMU’s). Currently, DNR is exploiting a loophole in their Habitat Conservation Plan by clearcut logging the best remaining spotted owl habitat, and using the argument that younger stands can be managed to restore spotted owl habitat as an excuse to do so. For example, although it appears that over 50% of DNR managed lands within the Cougar SOMU currently provide either high quality nesting, sub-mature, or Type A or B owl habitat, the most recent DNR forest inventory data indicates that many of the sub-mature stands, which comprise the majority of owl habitat within the SOMU, have been logged within the past 60 years. Only 2,300 acres, or approximately 20% of the lands managed by DNR within the Cougar SOMU, have been classified as Type A or high quality owl nesting habitat. Furthermore, DNR forest inventory data indicate that there are currently only about 520 acres within the Cougar SOMU that are over 80 years old. These stands are being specifically targeted for commercial logging by DNR. Recent examples of commercial timber sales in high quality Type A spotted owl habitat include Serenity Now, Beehive, Rocky Top, Black Hole, and Dabbler. It is much easier to protect existing habitat than to create new habitat in areas that have been clearcut and historically managed as industrial tree farms or monocultures, and DNR is doing the exact opposite, by aggressively targeting the oldest and most structurally complex stands in the SOMU's for clearcut logging.
9. Hilary Franz and others within DNR continue to tell the BNR and the public that half of all DNR forestlands in Western Washington have been set aside for conservation, and that the vast majority of structurally complex forests are protected. These assertions are often repeated by local elected officials and timber industry representatives. For example, Randy Johnson, a Clallum County commissioner, insisted during the December 6th work group meeting that over 60% of state forestlands in Clallum County have been set aside for conservation. In fact, only about 18% of state forestlands in Western Washington have been truly set aside as conservation areas. Many of the lands that are commonly characterized by DNR "protected" or "set aside for conservation" are actually unforested, or temporarily inaccessible or unavailable for harvest for various reasons. Timber sales are being actively planned in many of these "protected" areas, and DNR has never been held accountable for logging areas that they describe as protected. DNR needs to provide the work group with honest and accurate information on how much land has actually been set aside for conservation.
10. The work group needs to have a serious discussion about whether 50-foot wide stream buffers constitute "structurally complex forests”. In southwestern Washington in particular, virtually all protected structurally complex forests are contained within narrow stream buffers, while most of the structurally complex upland forests are unprotected. DNR consistently argues that stream buffers should be counted as protected, structurally complex forests. However, narrow, 50-100 foot stream buffers are often dominated by shrubs, lack large conifers, and were never intended to function as conservation areas or provide suitable wildlife habitat for sensitive wildlife species.
11. There was a lot of talk on December 6th about the benefits of thinning, but no discussion of the adverse environmental impacts of thinning, especially in older, intact forests. The work group needs to have an open discussion about the impacts of thinning on mature forests. There isn't a lot of data on this, but the general consensus within the scientific community is that thinning of natural, mature forests does more harm than good. One of the biggest drawbacks is that thinning operations often require the construction of a lot of new roads that further fragment the landscape. Ironically, roads can also function as corridors that accelerate the spread of noxious weeds, damaging pests, parasites, pathogens, and wildfires. Recently, DNR has been actively targeting the oldest and most structurally diverse, native forests in Western Washington for variable density thinning. Considering the high level of interest in thinning, the work group should make it a top priority to evaluate the adverse impacts of thinning operations on mature forests.
The next meeting will begin at 9 am tomorrow, January 10th. Members of the public are allowed to attend the meeting, but are not allowed to speak.