2023 State of our Forests & Public Lands Report

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at a Glance Introduction Environmental Justice Tribal Relations Statewide Forestry Issues Community Resilience to Wildfire Prescribed Fire 20-Year Forest Health Strategic Plan Webster Forest Nursery and Seed Orchards Carbon Sequestration and Storage in Forests Across Washington Issues on State Trust Forest Lands Governance and Management of State Lands for Multiple Benefits Older Forests & Critical Habitats on State Lands Managing for Carbon & Climate on State Lands Eastern Washington Sustainable Harvest Calculation Trust Land Transfer Olympic Experimental State Forest Issues on Private Forest Lands Overview of Forests & Fish and the Adaptive Management Program Protecting Stream Temperature in Headwater Streams and Clean Water Act Assurances Water Typing Rulemaking Adaptive Management Program Governance and Administration Issues on Aquatic Lands Clean Energy Project Review & Siting Special Legislative Thanks Other Notable Work Topics We’re Tracking Conclusion 3 6 8 10 12 13 16 18 20 22 24 26 28 30 32 34 36 38 39 40 42 44 46 48 50 51 52 53

Evaluating the performance of the Commissioner of Public Lands and the Department of Natural Resources is critical to ensuring our state’s precious resources are maintained for future generations. The report applies the following grades to DNR’s work during the past 12 months: SUCCESS, WORK IN PROGRESS, or NEEDS IMPROVEMENT. These measure progress toward ensuring that Washington’s forests, aquatic lands, and other vital resources are healthy and thriving. Our assessment of each topic is based on whether DNR has achieved meaningful progress and accomplishments and whether DNR is on track to achieve milestones that we hope to see.


Significant accomplishments or milestones achieved. If the current trajectory continues, DNR will meet or exceed all milestones WCA hopes to see.

Notable progress or interim milestones achieved, which may serve as stepping stones for subsequent progress. If the current trajectory continues, DNR will likely achieve some or all milestones WCA hopes to see.

Limited progress, or DNR has not demonstrated strong commitment and active engagement. Progress is not significant or comprehensive across important elements of the topic. If the current trajectory continues, DNR will not achieve milestones WCA hopes to see.

We choose topics based on WCA’s assessment of their importance and timeliness, our organizational priorities, relevance to DNR’s core mandate, and DNR’s involvement. We strive to maintain continuity of core topics year-on-year, as well as to incorporate new, emerging topics. Each topic includes an introduction providing context and the history of a topic from prior years, an evaluation section describing progress during the past twelve months, and a section identifying opportunities WCA sees moving forward. These opportunities will be considered in the next report. As overarching topics that should show up across DNR’s programmatic work, we do not assign a grade to Tribal Relations nor to Environmental Justice. It is most appropriate for impacted communities and sovereign Tribal nations to decide how DNR is advancing this work. However, we want to provide high level information about the agency’s work in these areas.




DNR continues to develop community wildfire resilience work. For these efforts to respond effectively to local community needs, greater direct funding of community organizations is vital, as well as increased collaboration with community organizations and other agencies. Substantive changes to the Wildfire Ready Neighbors program are also needed. Additional funding secured via House Bill 1578 supports interagency collaboration as well as expanded post-fire recovery efforts. Since last year, some improvements have been made to problematic contracting processes.


Strategic planning and investment in training have laid the groundwork for greater use of prescribed fire. However, the scale and pace of burning must increase significantly to have a meaningful impact on forest and community health. Continued work to address barriers for local-level training and burning are needed. Increased, dedicated funding and capacity can support this increase of prescribed fire.


DNR continues to make progress on scientific analysis and acres treated. However, greater emphasis on prescribed fire and non-commercial thinning are needed to improve ecological health. A shift away from the prevalence of regeneration harvest as forest health treatments on state lands is also important. DNR has provided long-requested information about the agency’s use of categorical exclusions. Moving forward, we hope to see to the agency pursue effectiveness monitoring to understand how treatments impact wildfire behavior.


Webster Nursery is a critical seedling and seed source for restoration and replanting. Recent investments from the legislature will expand production. The nursery produces a range of seed types to promote genetic diversity. Greater emphasis on research and production of climate-change adapted seed supply will become critical as climate change impacts worsen.


A statewide strategy to accelerate land and forest management practices that reduce carbon in the atmosphere persists as a gap in our state’s climate response. This topic is aligned with DNR’s core expertise in the management of forests across the landscape, which hold the greatest untapped potential for carbon sequestration in our state. The agency has not supported collaboration with other agencies to develop a natural and working lands carbon sequestration strategy. Nor has it leveraged past efforts like the Carbon Sequestration Advisory Group and Carbon Playbook to advance a science-based, statewide approach.



In July 2022, the Washington State Supreme Court issued a unanimous ruling in the CNW v. Franz litigation brought forth by WCA and partners. The decision affirms DNR’s authority to manage state lands for both monetary and non-monetary benefits, and clarifies that DNR is not obligated to manage for maximum revenue from timber harvest. To achieve this balance, DNR must consider both issues impacting the public, like climate change, and revenue for beneficiaries. To date, DNR has maintained the status quo in its approach to managing forestlands. The agency has not taken steps to incorporate managing for multiple benefits in the guiding Policy for Sustainable Forests nor in the Sustainable Harvest Calculation process. DNR’s timber sale program does not reflect DNR’s newly affirmed authority to manage for multiple goals.


Mature, structurally complex forests are ecologically valuable and provide many ecosystem services that homogenous, young forests do not. Public concern continues to grow regarding the loss of these older forests on state lands—which, once logged, cannot be replaced within a human lifetime. Logging these older forests also releases significant carbon. Despite past commitments to explore solutions, DNR has neither utilized existing policies that justify the protection of older forests, nor developed new strategies to retain older forests on the landscape. Harvest of mature forests has continued unaltered.


DNR has not taken steps to promote carbon storage and sequestration on the lands the agency manages, despite including this as a goal in its 2022-2025 Strategic Plan. DNR has not developed a policy to guide management for carbon on state lands. Progress has stalled in the development of the 10,000-acre carbon offset project announced last year. DNR put forward legislation intended to allow the sale of ecosystem services on state lands, but the bill in its final state would have prevented improved forest management projects—the only forest carbon project type with a proven track record to date.



The Eastern Washington SHC sets DNR’s timber harvest goals for the next decade (2025-2034) on DNR-managed lands east of the Cascade Crest. Climate change will continue to increase the severity of drought, heat, and wildfire, which will negatively impact forest health and productivity, as well as community health. Addressing these growing risks will require new methods of assessment, such as multi-optimization modeling. While DNR has made several public presentations about aspects under consideration, it is not yet clear if or how DNR will incorporate climate threats and management for multiple benefits in the SHC.


After several years of working with stakeholders and conservation organizations to make improvements to the important Trust Land Transfer program, DNR successfully passed a bill to strengthen the program and secured $19.5 million from the legislature to permanently protect 4,425 acres of ecologically valuable lands across Washington.


Independent monitoring by OFCO shows expansion of forest roads, inadequate mapping of hydrologic features and unstable slopes, and the continued spread of invasive species in the OESF. There are opportunities to expand the Type-3 (T3) Watershed Experiment to consider variables in non-fish bearing streams and adjacent old growth forests.



The process to update rules for riparian buffers on non-fish bearing streams was stalled and disrupted this year. New rules are needed to address Adaptive Management Program science demonstrating that current forest practices for logging along headwater streams are not maintaining cool, clean water required by state law and by the federal Clean Water Act. DNR enabled delays in this process: First, at the last minute, DNR changed its position to be the sole state agency not to support the proposal developed by the Department of Ecology, Tribes, and the conservation community. Later, DNR allowed litigation threats from the timber industry to divert the process.


For the past 25 years, forest practices regulations have operated under an interim water typing rule that does not provide adequate protection for fish. While the process to create a permanent water typing rule has long been mired in delay, the process has advanced incrementally this year. DNR was directed to begin rulemaking analysis. A workgroup was convened to continue to develop rule language after a 4-year hiatus.


DNR plays a dual role in the AMP: as both a participant and an administrator. In DNR’s role as administrator, the agency has initiated, and then largely abandoned, several efforts to address growing participant tensions and to improve AMP functioning. Meetings of the principals were stopped without explanation. Progress is mixed on DNR’s plan to address recommendations from the State Auditor’s Office. Additionally, The AMP was created specifically as an alternative to litigation as the driving force behind forest practices. DNR’s acquiescence to litigation threats in August sets a precedent that risks harming the effectiveness and credibility of the AMP moving forward.



DNR successfully passed a new law that expands the agency’s authority to remove derelict structures and that expedites the judicial process for derelict vessel recovery. The agency secured funding to pursue kelp restoration and to maintain a monitoring network to track aquatic conditions over time. DNR also appropriately denied extensions of aquatic shoreline leases that would permit companies to raise non-native fish species in Puget Sound. To protect native salmon, Commissioner Franz also issued an executive order prohibiting commercial finfish net pen aquaculture on state-owned aquatic lands.


DNR’s work and approach to establishing leases for wind, solar, and geothermal continues to develop. As the agency makes progress towards the goal of creating 1,000 megawatts of renewable energy production in a way that promotes the greatest environmental, social, and economic good, more progress is required to implement Tribal consultation, to uphold Tribal sovereignty, and to ensure public engagement. As part of this work, it will be important to continue to apply lessons learned for how to best use a public mapping tool for identifying potential renewable energy sites.


Whether we live in cities or towns, mountains or farmlands, we all deserve clean air and water for ourselves and future generations.

Washington's forests are one of the state's and our communities’ most valuable resources. Forests provide beautiful places to rest and recharge, critical for our physical and mental health. Forests create livelihoods for rural families. Forests inform and influence cultures. Healthy forests create healthy waterways that support salmon and other wildlife. Forests store carbon and must play a major role in our response to the climate crisis. This report is part of an effort to advocate for responsible, creative stewardship of the forestlands that sustain us all.

Washington Conservation Action (WCA) is a statewide non-profit organization. We advocate to protect people and nature as one. We work to mobilize the public, to elect champions for the environment, and to hold our leaders accountable. In January 2023, we brought together Washington Environmental Council and Washington Conservation Action under one unified brand: Washington Conservation Action.

Since the early days of our organization in the 1960s, we have monitored the work of the Washington Department of Natural Resources (DNR) and of the Commissioner of Public Lands (CPL), the elected official who leads and sets the direction of DNR. Commissioner Hilary Franz was elected to her second term as the CPL in 2020.

This is the eighth annual State of our Forests and Public Lands Report. WCA began documenting the progress of the CPL in 2015, while Commissioner Peter Goldmark was in office. The report has two goals: First, to provide our fellow Washingtonians with credible information and analysis on DNR and the CPL’s work on behalf of our state. Second, we want to make clear recommendations to DNR and to the CPL to support the achievement of the agency’s mission: “Manage, sustain, and protect the health and productivity of Washington's lands and waters to meet the needs of present and future generations.”

As the statewide elected official leading DNR, the CPL is responsible for the management, regulation, and protection of 13 million acres of state (public) and private forests, 2.6 million acres of state aquatic lands (tidelands, shorelands and harbors), and 1 million acres of state grazing lands. The CPL manages our state’s wildfire protection. The CPL chairs the Board of Natural Resources (BNR). The BNR sets policies to guide how DNR manages our state-owned forests, aquatic lands, and rangelands. The CPL’s designee also chairs the


Forest Practices Board (FPB). The FPB adopts rules for private and state forests that DNR implements and enforces.

The report does not endeavor to provide a comprehensive evaluation of all DNR’s work. We select topics that are core to DNR’s mandate, and in which DNR plays a unique role. We only cover areas in which Washington Conservation Action engages and therefore can evaluate credibly, and topics for which input from our partners provides a multifaceted view of the agency’s work.

The report emphasizes forests because of DNR’s unique leadership role in forestry on both public and private lands. We believe DNR’s role in stewarding our forest resources is vital and challenging— particularly given the range of powerful special interests in the forest sector. With the impacts of climate change intensifying, we need innovation in forest management now more than ever.

harvest plan for eastside state trust lands for the next 10 years, and on Webster Nursery, highlighting an important role DNR plays in providing seeds and seedlings across the state.

Reflecting on the agency’s work over the past 12 months, we see a continuation of the patterns of prior years.

The CPL has chosen to focus attention on wildfire during her tenure, and DNR has made progress on prescribed fire and forest health. New work is underway to support community wildfire resilience with strong legislative backing, though opportunities for improvement remain.

We see continued progress and good outcomes in aquatics, including the cleanup of derelict vessels. Additionally, the Trust Land Transfer program was updated and funded this year, strengthening a tool for protecting ecologically important lands. However, DNR does not challenge special interests, namely timber industry associations. As a result, DNR falls short in managing resources for all the people in the state. This pattern has been particularly striking this year with regard to state lands and forest practices. It has shown up in the agency’s failure to advance its carbon offset project, in the lack of evolution in response to the historic CNW v. Franz decision, in the lack of action to manage for climate change on state lands, the absence of a statewide strategy to support carbon sequestration in natural and working lands, and in the failure to heed the call to protect mature, structurally complex forests on state lands.

This year’s report focuses on the core issues we have consistently covered in past reports, including state trust lands, managing for climate change, regulation of private forests, wildfire, aquatic lands, and renewable energy. We continue last year’s new additions on environmental justice and Tribal relations, which must be at the core of the agency’s approach to natural resources management. We’ve included new sections on the Eastern Washington Sustainable Harvest Calculation, which will set the

The Adaptive Management Program continues to be mired in conflict and delay due to timber industry obstruction and to DNR’s lack of leadership, but we are within striking distance of new science-based rules for timber harvest. We hope to see DNR lead these processes to a rapid conclusion.

In a time of climate and biodiversity crises, the status quo no longer serves our state. We must boldly reimagine natural resources management. Exciting opportunities exist for Commissioner Franz, or the next CPL, to seize.

In a time of climate and biodiversity crises, the status quo no longer serves our state. We must boldly reimagine natural resources management. Exciting opportunities exist for Commissioner Franz, or the next CPL, to seize.

Humans are not separate from nature. Thus, the thread of environmental justice weaves through all spaces in which humans interact with their environment. The HEAL (Healthy Environment for All) Act provides a framework to integrate environmental justice into the planning and decision-making of state agencies. Meaningful environmental justice work must be embedded throughout agency policies, on-the-ground activities, stakeholder engagement, and human resources. This work takes vision, care, and time.

DNR hired the agency’s first Director of Equity and Environmental Justice in late 2021. Since then, DNR has been building an Office of Equity and Environmental Justice. This office is now beginning to build momentum. The office has progressed from an initial focus on building a team and focusing on HEAL Act compliance. Now, it is starting to identify tangible ways to incorporate environmental justice into DNR’s operations.



• An agency environmental justice implementation plan, developed in compliance with the HEAL Act, was published in August. This plan will provide a framework for forthcoming plans for specific DNR divisions.

• Each DNR division will develop an environmental justice plan. The first plan was developed by the Forest Resilience Division and published in July.

• New plans and policies to facilitate engagement have been drafted and are under review, including a community engagement plan and a Tribal consultation policy.

• Initial environmental justice assessments began on July 1st, as required by the HEAL Act. Assessments are underway on agency rulemaking, loan programs, large grants or loans, and agency request legislation.

• New positions were hired in the Office of Equity and Environmental Justice, including a Boards and Commissions Manager, a Manager of External Affairs, and a Communications Specialist. Work led by new staff include:

• Completion of demographic audits of the existing 70-plus boards and commissions led by DNR.

• Planned updates to improve transparency and access in the selection process for boards and commission members.

• Planned updates to streamline the public comment process, including a centralized portal with electronic submission for all open comment periods.

• Planned listening sessions related to the HEAL Act and to the Climate Commitment Act.

• Plans to establish an external steering committee to guide the agency’s environmental justice work. This will compensate participants for their time, which is key to ensuring diversity.


• Ensure each division has dedicated staff with environmental justice as a core component of their job description. Periodically bring these staff together to promote cross-division collaboration and to share ideas, resources, and strategies.

• Support innovation within divisions to expand environmental justice work above and beyond the scope of the HEAL Act, including activities exempt from the HEAL Act, such as timber sales.

• Empower underrepresented communities to provide input into agency actions and strategies through direct engagement with community members. Directly engage with community members, and incorporate feedback from community members in future updates to boards and commissions and public comment processes to make engagement possible and comfortable for all.

• Update DNR hiring processes and policies across regions to reduce barriers to employment such as removing requirements to have a physical address, to have long-term driving records, and no history of court involvement.

• Seek legislative funding to address barriers to recruiting workers from underserved communities and to support mental health for high-risk jobs such as wildland firefighting.

• Support the Board of Natural Resources in efforts to determine how environmental justice is reflected in management of state trust lands moving forward. In light of the CNW v. Franz decision affirming that DNR is not required to maximize timber revenue, this topic is timelier than ever.

Meaningful environmental justice work must be embedded throughout agency policies, onthe-ground activities, stakeholder engagement, and human resources.

“A clean energy future must uphold federal trust and treaty obligations that consider the cultural and health impacts of these projects on sacred sites. These parts of our identity – the land, the roots, and the water – are a part of our collective history and we must not erase them. . . if it harms Tribes, then it’s not clean energy.”

– Alyssa Macy, Citizen of Confederated Tribes of Warm Springs, Oregon, CEO, Washington Conservation Action


DNR’s core mandate to manage Washington’s lands and waters, including forest and aquatic lands, has significant implications for the fulfillment of the rights of Tribal nations and Tribal sovereignty. Tribal Nations (treaty and nontreaty) are natural resource co-managers with the State of Washington. Multiple nontreaty Tribal nations steward large forests in the state. All Tribal nations have sovereign and inherent rights. They should be meaningfully consulted, preferably under principles of “free, prior and informed consent.” They should be included in the stewardship of cultural resources. Close collaboration with Tribal nations is critical in decisions that impact fisheries and forests.

DNR created a Tribal liaison position in 1991 and elevated the title to director of Tribal relations in 2012. In last year’s report, we noted that ideally, DNR would have Tribal relations staff in both the operations and the executive teams.


• DNR hosted a Tribal Summit on July 10 with representatives from 19 Tribal Nations in attendance, in line with the goal to convene Tribal leaders every year.

• New positions were hired in the Office of Tribal Relations, including a deputy director and an executive assistant. A cultural resources specialist will be joining the Tribal relations team as well, following the legislature allocating partial funding for DNR’s staffing expansion request in 2023.

• Funding and plans to initiate a First Foods Program, currently funded at $200,000. This effort was a result of input from Tribal governments during the 2022 DNR Tribal Summit.

• Providing information to Tribal Nations about the Forest Legacy Program including webinars for Tribal leaders.

• Launching a Tribal Government Consultation Policy in January 2023.

• Launching the Outdoor Access and Responsible Recreation planning project at 2023 Tribal Summit.

Clean energy siting and mapping of potential clean energy properties on DNR lands is viewed by the agency as an ongoing discussion and an evolving process. DNR has been hearing from, and having discussions with, Tribal Nations about protection of cultural resources, including hunting and gathering rights.


• Expand the capacity of the DNR Tribal Relations Team with additions including cultural resources specialists and regional Tribal liaisons. This added capacity would enable the Tribal Relations team to add expertise and proactive Tribal engagement to its work.

• Continue and deepen consultation with Tribal governments in connection with clean energy siting. This may include updating if, and how, the mapping tool is used as well as other ways to ensure consultation is reflected in department processes.

• Explore with Tribal Nations how to integrate co-management into the agency’s natural resources management decisions. For example, DNR could center co-management in forest practices work via Forests & Fish, and on state trust lands. The new Tribal Government Consultation Policy could support this engagement. The CNW v. Franz decision—which affirms DNR’s discretion to manage state trust lands for a range of benefits rather than maximizing revenue—provides a significant opportunity to explore deeper co-management in state lands management. The priorities of Tribal governments must be part of defining what non-monetary benefits the agency prioritizes on state lands.


This section addresses topics that are relevant to all forests statewide, across different land ownership types such as private, state, federal, and Tribal.


Each year, the effects of more frequent and severe wildfire become more apparent and the need for investment in community wildfire resilience grows. Supporting communities to coexist with fire saves lives and structures. It also furthers environmental justice since many at-risk areas are home to communities of color or those who have limited income.

In the last couple years, DNR has taken on work related to community wildfire resilience. This has been supported by the passage of HB 1168 in 2021 and the Cascading Impacts of Wildfire bill, HB 1578, that passed this year. DNR has identified community wildfire resilience as an agency priority within the 20-Year Forest Health Strategic Plan, the 10Year Wildland Fire Strategic Plan, and the 2020 Forest Action Plan.

At the local level, communities and Tribal nations across Washington have been leading wildfire resilience activities for many years. National and state efforts, such as the Washington Fire Adapted Communities Learning Network and the Firewise USA program, support these activities. In many community wildfire resilience efforts, local, state and national jurisdictions, and funding sources, overlap. Thus, collaboration is critical to success.


• From June 2022–June 2023 (FY 2023), DNR awarded $1.6 million in community resilience grants to Washington community organizations. Thus, community organizations only received approximately 14% of the subset of HB 1168 funding appropriated to community resilience (about 2% of overall HB 1168 funds appropriated to DNR for the year).2 Community resilience grants include equity and inclusion grants, support to conservation districts via the Conservation Commission, Firewise micro-grants for Wildfire Awareness Month events, and partner grants to fire districts for Wildfire Ready Neighbors activities.

2 This is calculated based on the legislature's appropriation of $19.7 million for community resilience activities in the 2021-2023 biennium and appropriating $8.2 million for community resilience activities in FY 2022, leaving $11.5 million available for community resilience activities in FY 2023. DNR expenditures for community resilience in FY 2022 totaled $7.3 million, meaning approximately $900,000 for community resilience lapsed into the general fund.


• Some improvements have been made to DNR processes for contracting with community organizations for wildfire resilience work. DNR has filled seven regional community resilience positions. For federal passthrough dollars, processes have begun to streamline contracting by allowing subawards in addition to direct contracts. However, some contracting issues have persisted in the past year, including delays in contracting that create time pressures for community organizations.

• Wildfire Ready Neighbors (WRN) program— which was expanded into western Washington this year—has not substantively changed at the state level in response to feedback from local organizations. Significant room for improvement remains. WRN provides a way for homeowners to connect to DNR’s cost-share program for fuel reduction work. The program is beneficial to those communities or organizations that do not have an established wildfire risk assessment program and where DNR and local organizations have the capacity to leverage increased community interest generated by WRN. However, WRN does not provide funding to help homeowners implement other wildfire protection actions such as home-hardening. It also does

not offer support to renters, an often underresourced group. WRN creates additional work for community resilience organizations with limited capacity without supporting their existing work nor their innovative projects. Implementation in some regions has reflected input from local organizations. However, the program as a whole has not been updated to reflect these insights. WRN still duplicates preparedness efforts such as those developed by Firewise USA and by local organizations.

• The Cascading Impacts of Wildfire bill (HB 1578)—DNR request legislation passed this year—allocates resources to address impacts of wildfire, particularly in western Washington, including smoke, development of wildfire evacuation strategies, and post-fire debris flow. The bill paves the way for greater interagency coordination on wildfire. It also allocates additional funding to expand community resilience programming in western Washington, including WRN. As mentioned above, improvement is needed to WRN systems for delivering funds to local communities, so expansion of funding must be closely monitored to ensure timely delivery to meet community needs.


• HB 1168, which passed in 2021, provides $125 million per biennium over eight years to address wildfire in Washington. The bill established the Wildfire Resilience, Forest Restoration, and Community Resilience account. It stipulated that 15% or more of the funding would be allocated to community resilience activities and at least 25% to forest resilience. The bill is now in its third year of implementation.

• The first implementation report was published December 1, 2022.i It covered the first year of implementation (FY 2022). DNR expended approximately $40 million: $16.7 million to wildfire response, $16.1 million to forest restoration, and $7.3 million to community resilience. These expenditures exceed the minimum percentage thresholds established in HB 1168 for forest restoration and community resilience. Approximately $3 million in appropriated funds were not spent by DNR and lapsed into the state general fund.

• Of the $7.3 million of reported spending on community resilience, only $2.4 million was categorized as expenditures in the "DNR major program area" titled "community resilience.” The remaining $4.9 million of community resilience spending was incurred in other program areas, with expenditures including central services and administration, state service forestry, fire district assistance, hand crews, heavy equipment, aerial response, and increased local fire service capacity.

• Of the $2.4 million spent in the “community resilience” program area, only $5,263.67 was distributed via DNR’s community resilience grants program in FY 2022.

• A joint subcommittee of Wildland Fire Advisory Committee and Forest Health Advisory Committee members recently developed recommendations for ongoing implementation of HB 1168.



• Establish ongoing, increased funding for community organizations doing wildfire resilience work—including funding through HB 1168 and HB 1578. This should extend beyond the scope of WRN to include community preparedness and planning, education, landowner and renter assistance, and locally-developed projects that address the unique opportunities and needs of communities.

• Increase the impact of the WRN program by incorporating feedback from community organizations. For example: ongoing support for vegetation management and home hardening activities identified by assessments, addressing insurance exposure risk posed by home assessments being subject to public information requests, and increasing accessibility through different forms of communication (i.e., provisions for community members who may be more comfortable making a phone call or filling out a paper form rather than submitting online).

• Improve and expand cost sharing, or other financial support, to implement actions identified during WRN home site assessments. Community resilience funding to date has largely focused on awareness. It has emphasized home assessments rather than implementation and support for acting on the findings of the assessments. The high cost of implementing home hardening recommendations poses a barrier to many lower-income homeowners who are unable to meet financial requirements to access costshare funding.

• Expand metrics to measure the success of community resilience work and timely delivery of funding. Measures should expand beyond output counts and activities completed—like home assessments completed and community events held—to incorporate metrics that address outcomes such as planning, education, community engagement and support, partnerships, and recovery.

• Increase collaboration to leverage complementary expertise and increase efficiency. DNR should foster teamwork with the Emergency Management Division, the Conservation Commission, and communitybased organizations. DNR can support development and updates of local Community Wildfire Protection Plans to ground collaboration in community values, priorities, and challenges.

• Hold listening sessions to better understand the resilience work that community members and organizations are doing, where they need support, and what strategies are, and are not, successful in their communities.

• Foster an agency culture across regions and staffing levels that encourages staff to bring forward best practices and lessons learned from local voices and build capacity through partnerships.

• Demonstrate how community resilience work funded by HB 1168 and other sources aligns with goals in the 10-Year Wildland Fire Protection Plan, particularly: “Communities are prepared and adapted for current and future fire regimes.”


Both east and west of the Cascades, the health of Washington’s forests depends upon fire. Our forests are adapted to regular fire, due to both climate factors and to the use of intentional fire by Indigenous peoples over millennia. The relationship between fire and forests was disrupted in the 19th and 20th centuries due to suppression policies that failed to recognize the ecological importance of fire. Suppression and climate change have resulted in more severe and catastrophic wildfire in the 21st century. Fortunately, progress is being made to restore the role of fire. Prescribed burning is one of the key tools for restoring natural fire regimes.

In 2022, DNR reinitiated the agency’s prescribed fire program and conducted its first prescribed burns in more than a decade. This was a notable success, which we hope marks the beginning of scaled-up prescribed fire across the state. Now that the program is relaunched, we are tracking whether prescribed burning is occurring on significant acreage and whether DNR is creating the necessary conditions to support the expansion of prescribed fire.


• This spring, DNR conducted four burns totaling 543 acres on state trust lands. This is twice as many burns and 296 more acres than last spring. These additional burns are positive, though they remain limited in scope.

• An additional six prescribed burns are planned for fall.

• DNR has increased prescribed fire program staff from two to three. DNR continues to support prescribed fire training exchanges (TREX), leads certified burn manager training, and engages in “learn and burns.” These trainings expand knowledge and capacity to conduct burns on all lands—private, local, state, federal, and Tribal— in Washington.

• In early 2023, DNR developed a prescribed fire strategic action plan informed by a series of meetings with approximately 60 DNR staff, stakeholders, and representatives from several Tribes. Washington Prescribed Fire Council will facilitate implementation. The plan identifies more than 60 actions related to regulation, training, planning, implementation and operations, and public engagement to be carried out by the end of 2024. Implementing these actions can increase the pace, scale, and quality of prescribed burning across the state.

• In August 2023, the EPA approved Washington’s Smoke Management Plan (SMP) update, which provides more flexibility to pursue prescribed burning in the state. In previous years, DNR led work to study prescribed fire practices and needed improvements to the SMP, which was submitted to the EPA for approval in August 2022.




• Expand internal staffing and allocate additional funding to increase the scale and pace of prescribed burning and to improve coordination across regions.

• Assess whether prescribed fire activity is effectively moderating wildfire severity.

• Update contracting methods to support purchasing equipment and infrastructure for prescribed burning. Explore models used by other state agencies.

• Develop a strategy to establish baseline liability coverage. Recognize multiple training and experience pathways to qualify burn implementers. These actions can enable more cross-boundary coordination and alllands prescribed burning.

• Create consistent standards for prescribed burn permitting across regions. Differentiate broadcast and pile burns by updating the permitting process and by training permit review staff to differentiate between broadcast and pile burns.

• When planning prescribed burns, take into consideration local priorities, such as those identified in Community Wildfire Protection Plans, as well as forest health objectives. This will support outcomes that support both community and ecological resilience.

• Assess public perception of prescribed burning in Washington to inform outreach and public education. This will support the scale-up of prescribed fire in a way that is socially viable.

• Engage with Tribal governments to understand how the agency can support cultural burning and learn from traditional ecological knowledge.

• Convene a broader group of local stakeholders and Tribes to develop longerterm actions that expand on the 2023 strategic planning workshops.

• Collaborate with other state agencies, including the Department of Health and Department of Ecology, to support air quality in overburdened communities while increasing prescribed burning.


Now in its sixth year, the 20-Year Forest Health Strategic Planii for Eastern Washington is intended to “restore and manage forested landscapes at a pace and scale that reduces the risk of uncharacteristic wildfires and increases the health and resilience of forest and aquatic ecosystems in a changing climate.” The strategy is designed to ensure landscape-scale treatments and coordination across all ownerships including state, federal, Tribal, and private.

Treatments carried out under the plan include commercial thinning, non-commercial thinning, and prescribed burns. DNR plays a dual role in both implementing the plan across land ownership types in Washington and in carrying out forest health treatments on the state lands managed by the agency.

Goal C2 of DNR’s 2022-25 Strategic Plan,iii “Healthy forest ecosystems in priority watersheds,” outlines an intent to expand on the 20-Year Forest Health Plan both by expanding into western Washington and by creating incentives for forest health work.


• DNR has carried out 544,937 acres of treatments across eastern Washington. This represents 43.6% of the goal of 1.25 million acres by 2037.

• Of the total acres treated, 225,518 acres (41.4%) are in the 37 existing priority areas. Each biennium, DNR adds additional priority landscapes. Once an area is designated as a priority landscape, DNR carries out scientific evaluation and assessment to inform forest health treatments. Analysis on the next eight areas will be completed in 2024. Priority area analysis provides a scientific baseline that is beneficial from an all-lands management perspective and in some instances is utilized by other land managers. However, a majority of treatments have not been conducted in these priority areas. Thus, most treatments do not benefit from scientific baselines and assessments, which is a missed opportunity.

• DNR no longer provides data on treatment acres by lead implementer and by treatment type in current priority areas (this was previously included as part of Table 1 of the Forest Health Tracking Memoiv , parallel to data displayed for eastern Washington). This reflects DNR’s framing that all areas in eastern Washington are effectively priority areas, since all will be priority areas by the end of the plan. This reduces transparency compared to previous years.

• On state trust lands, 58.4% of treatments from 2017 to 2023 were non-commercial thinning, 33.0% commercial thinning, and 8.6% prescribed burns based on forest health tracker data.


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• The vast majority of non-commercial treatments on state lands are “regeneration harvests.” A regeneration harvest is a clearcut or a harvest of the majority of trees in order to establish a new stand for commercial harvest. Among commercial treatments, 81% of treatments (73% of acres) were regeneration harvests, 5% (8% of acres) were thinning, and 14% (19% of acres) were “other.” This is comparable to figures from last year: less (1% of acres) regeneration harvest and slightly more thinning (4% of acres) compared to last year.

• The forest health tracker is a valuable information portal, but opportunities remain for improvements to transparency and usability. Information is not up-to-date, which may at times be due to delay in partners reporting. Some available information, such as treatment type detail and year of completion could be made more visible and easily accessible.

• For the second year, DNR published a Work of Wildfire report this March and expanded the scope to include western Washington. This report supports the trend towards a more holistic understanding of beneficial and negative outcomes of wildfire.

• DNR provided requested clarification on its approach to categorical exclusions (CEs). This information should be made available to the general public. CEs are a class of actions that bypass National Environmental Policy Act requirements for environmental assessment or an environmental impact statement.

• DNR has not gathered information on the outcomes or effectiveness of forest health treatments.


• Focus forest health treatments on noncommercial thinning and prescribed burning to support ecological health, and strongly encourage partners to do the same. These treatments are most in need of funding because they do not pay for themselves through timber revenue.

• Evaluate forest health treatments on state lands to understand the predominance of regeneration harvests, and work with the uplands division to invest forest health funds in the most impactful treatments. This could include establishing criteria for what constitutes a forest health treatment, providing additional information with each treatment to describe forest health outcomes, and establishing a prioritization process for treatments.

• Differentiate between pile burning versus broadcast burning in the Forest Health Tracker. These two actions have vastly different impacts on forest health. Pile burning is standard practice in conventional forest management. Prescribed burning requires concerted effort and should be prioritized as a forest health treatment.

• Add definitions of project types to the main forest health tracker page for better information on treatments, including what subtypes fall within each, such as regeneration harvest under “commercial thinning.”

• Utilize a data visualization tool like Tableau on the DNR forest health website to provide a more accessible, interactive dashboard for forest health data.

• Develop a framework for effectiveness monitoring to demonstrate the impact of treatments on forest health over time. Ensure that reporting includes measures of Goal 2 of the plan, which pertains to reducing risk of wildfire and other disturbances.


Across our state and region, Webster Forest Nursery is an important seedling and seed source. The nursery’s products aid replanting after logging on state and private lands, forest restoration after wildfire or restoration of forests that border aquatic habitat. The nursery was established in 1950 and currently produces 8 to 10 million seedlings each year. The nursery uses seed stock from DNR-operated seed orchards or cones collected in the wild, which the agency processes and stores. The nursery grows 15 species of bareroot and greenhouse inventory for agency use and for sale to the public.


• This year, the legislature fully funded DNR’s $7.4 million capital budget request to expand the nursery, including $663,000 for scoping and design and $6.7 million for construction. This funding pays for the construction of a new seed plant and is expected to result in a 50% increase in seedling production and capacity to meet the growing demand for reforestation. Approximately $1.5 million of US Forest Service (USFS) grant funding will be used to conduct analyses that could increase production efficiencies.

• Nursery staff coordinate with the USFS and nonprofits such as the Arbor Day Foundation and participate in seed collaborative groups. Up to 25% of the nursery’s capacity is used to support contracted growing operations for other entities. This demonstrates the significant role the nursery plays in regional seed production.

[T]he legislature fully funded DNR’s $7.4 million capital budget request to expand the nursery...this funding will allow for construction of a new seed plant and is expected to result in a 50% increase in seedling production and capacity to meet the growing demand for reforestation.

• Approximately $900,000 allocated by the legislature in the 2023 session will allow DNR to begin the work of restoring 25 seed orchards. A number of USFS seed orchards in Washington were abandoned due to federal funding cuts in the 1990s. These sites have potential to be restored and to serve as contributors to forest restoration and climate adaptation.

• DNR’s seed orchards and the Webster Nursery are key to supporting genetic diversity. Across species and seed zones, DNR manages over 300 categories of seeds suited for different climate and soil conditions across the state. Webster Nursery is also engaging with landowners to initiate assisted migration trials of Douglas fir on nine sites, and has plans to expand the work to include additional species.

• DNR is engaging in the Experimental Network for Assisted Migration and Establishment Silviculture.


Proactively invest in further research to support climate change adapted seed supply and planting. As we continue to experience the impacts of climate change, climate adaptation research and development is needed to maintain the health of our state’s forests. DNR is well positioned to lead this work given the agency’s management of the nursery and seed orchards, as well as technical expertise, and land management activities. We hope to see DNR expand beyond existing efforts. DNR could grow in-house scientific expertise, support identification of climatically adapted seed, promote seed transfer, gather data on growth and survival of seedlings in different conditions, promote more collaboration among research entities and landowners, and support citizen science.


This section focuses on DNR’s leadership role in forest management statewide. Washington’s forests are among the most carbon-dense in the world. They will be crucial in achieving our state’s goal of carbon neutrality by 2050.v Peer-reviewed research has found that among all natural climate solutions, more than 80% of our state’s potential to drawdown additional carbon in natural systems lies in forest ecosystems.vi The state does not currently have a statewide plan to guide carbon sequestration work or to connect carbon sequestration directly to achieving our state greenhouse gas limits.

As the leading state agency on forestry, promoting forest carbon sequestration and storage aligns with DNR’s 20222025 Strategic Plan goal: “Reduce net greenhouse gas emissions and strengthen local economies.”

In fulfillment of a 2019 budget proviso,vii in 2020 DNR published two documents: 1) A report from the Carbon Sequestration Advisory Group (CSAG), intended to guide the agency’s work in carbon sequestration in natural and working lands, and 2) A Forest Ecosystem Carbon Inventory documenting carbon dynamics across land ownership types in Washington’s forests.viii It was hoped this work would serve as a building block for a state-wide strategy.

The 2021 Climate Commitment Act (CCA) created opportunities to encourage forest carbon sequestration and storage, including via carbon offsets and via Natural Climate Solutions Account investment. The first biennium of funding was appropriated this legislative session in the 2023-2025 budget. DNR was charged with contracting with Washington Farm Forestry Association (WFFA) to create a Small Forest Landowner Carbon Workgroup. This group was asked to explore carbon market opportunities for small forest landowners.


• Nearly three years after publishing the final CSAG report, DNR has not acted upon recommendations in the report nor upon the findings of the Forest Ecosystem Carbon Inventory. Although the CSAG recommendations were not as ambitious as needed, they were an opportunity for the agency to deliver on commitments and to create forward momentum to promote natural climate solutions.

• In October 2022, DNR published a “Carbon Playbook”—an extensive document outlining opportunities and challenges of carbon projects on forestlands, aquatic lands, and agricultural lands, among others. The plan included credible principles and a comprehensive menu of options. It could have provided a launching point for DNR leadership on carbon sequestration, but it did not outline a path forward. DNR uses the document as a reference for parties potentially interested in pursuing carbon projects rather than as a roadmap for state action.


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• The lack of a coordinated plan for enhancing carbon sequestration continues to be a void in the state’s climate strategy. To fill this void, experts advocated for a budget proviso that would have directed DNR and Ecology (DOE) to co-create a comprehensive natural and working lands carbon sequestration strategy tied to the state’s greenhouse gas limits. DNR did not support the proviso as proposed due to the allocation of resources and agency roles, nor did they engage with advocates to align on progress. As a result of DNR’s lack of support, it was ultimately struck from the budget.

• The Small Forest Landowner Carbon Workgroup has begun work, after delay due to budgetary and administrative issues. DNR received funding in the 2022 supplemental budget and in November finalized a contract with WFFA to lead the process.ix This work is now advancing.

• A proviso passed by the legislature this year directs DNR and DOE to convene a stakeholder group to conduct a state ecosystem services inventory and to develop a state lands ecosystem services asset plan. A report to the legislature is due at the end of 2024.

• As described in the state lands section, DNR has not taken actions to increase carbon sequestration and storage on the state trust lands that it manages directly—the land the agency has the greatest ability to influence.


• Support a Natural and Working Lands Carbon Sequestration Strategy in collaboration with other agencies. A strategy could identify priority interventions and direct investment, including from the CCA. This could integrate findings from past efforts: the 2020 CSAG report and Forest Ecosystem Carbon Inventory, and the 2022 Carbon Playbook. In the absence of such a strategy, clarify how DNR intends to collaborate with partners and build on the recommendations and opportunities in these previous efforts.

• Leverage the upcoming ecosystem services inventory to identify pathways and priorities to enhance carbon sequestration and storage statewide. The inventory could serve as an input into a statewide strategy.

• In the Small Forest Landowner Carbon Work Group, ensure a diversity of workgroup and contractor expertise beyond WFFA affiliates, including elevating the needs of Tribal governments. Leverage work group expertise to overcome barriers facing small forest landowners in on-the-ground implementation, rather than focusing on carbon accounting methodologies. This would ideally include recommendations on 1) aggregation to guide future CCA rulemaking, and 2) technical support needs in carbon offset project development that DNR can support in small forest landowner outreach.

• Lead by example in demonstrating climatesmart forest management on state trust lands. This topic is addressed in the subsequent section of the report.


This section addresses topics relevant to the 2.1 million acres of public forests that are managed by DNR on behalf of trust beneficiaries such as counties and school districts, and that generate revenue for those beneficiaries. The Washington State Trust Lands Habitat Conservation Plan guides management of these lands. The Board of Natural Resources (BNR) sets policy to guide management of state lands, and the Commissioner of Public Lands serves as Board Chair.


In 2020, Washington Conservation Action, Conservation Northwest, Olympic Forest Coalition, and eight individuals filed a lawsuit regarding DNR’s mandate in managing state trust lands. The State Supreme Court’s unanimous decision in 2022 affirmed DNR’s broad discretion to balance a commitment to both trust beneficiaries and to the general public. This section considers how DNR has evolved governance and management of state trust lands in response to this change to the legal framework.

Washington’s Constitution states that “all the public lands granted to the state are held in trust for all the people.” Our lawsuit urged the courts to hold that this language authorizes and requires management of these lands in the long-term best interest of all Washingtonians, and that the adoption of the Sustainable Harvest Calculation (SHC) and Marbled Murrelet Long-Term Conservation Strategy (LTCS) in 2019 violated this constitutional requirement.

In July 2022, the State Supreme Court ruled on Conservation NW et al v. Commissioner of Public Lands et al. x While the Court’s decision dismissed the specific legal challenges related to the SHC and the LTCS, the Court affirmed that DNR has the discretion to manage our federally granted public forestlands for both monetary and non-monetary benefit. The decision removed a long-perceived central tenet of state trust land management: that DNR is required to maximize revenue for beneficiaries.2

DNR is not required to maximize revenue, and has the option to generate revenue from timber sales. DNR may balance revenue generation with public benefits, such as social and ecological values. The agency is able to err on the side of public safety, such as avoiding potential landslides from clearcuts. It may also take into account Tribal rights to hunt and fish. The Court stated, “[t]here appear to be myriad ways DNR could choose to generate revenue from the state and forest board lands or otherwise put them to use for the benefit of the enumerated beneficiaries.”

2 Note: the Court affirmed that the forested lands DNR manages on behalf of counties, the “state forests,“ are separate entities and are managed as directed by the Legislature in statute; they are not directly governed by the laws applicable to federally granted lands.


The initial year after the CNW v. Franz decision was decisive in setting the tone. Would the commissioner use DNR’s unprecedented new discretion to evolve management of state lands for public benefit? To date, the answer is no.

• DNR spent five months pursuing BNR approval of a problematic Settlement Agreement (SA) with a timber industry association and two counties.xi The SA would have ceded DNR’s new discretion, setting a harmful first precedent after CNW v. Franz. The SA addressed two industry lawsuits charging that DNR should have logged more in the 2019 SHC decision. The SA would allow the industry—DNR’s customer—to exert greater influence and set the terms of a new forest inventory that would be prescriptive, outdated, and expensive. Although the SA was introduced before issuance of the CNW v. Franz decision changed the legal framework, the commissioner did not reconsider the SA. In December, the SA failed at the opposition of key BNR members and conservation organizations.

• In December, a board resolution was passed due to the leadership of a BNR member. The resolution was aligned with managing state lands for multiple benefits.xii It included directives related to evolution of DNR inventory and modeling to optimize for multiple objectives, including carbon sequestration. DNR has made no visible progress on the resolution nor provided an update.

• In the 2023 legislative session, DNR-request legislation regarding the sale of ecosystem services on state lands (SB 5688) again threatened to undermine CNW v. Franz. WCA and conservation partners supported the bill as introduced. The agency then agreed to amendments requiring that ecosystem services projects—like carbon projects—produce more revenue than logging, creating a statutory requirement to maximize revenue without consideration for other benefits. This would have set the agency up for failure and undermined the CNW v. Franz decision. The bill did not pass due to opposition from conservation organizations and institutions represented on the BNR.

• Public engagement regarding state trust lands remains ineffective, despite DNR’s mandate to manage for public benefit. Public participation and frustration with BNR meetings have grown this year, particularly related to harvest of older, carbon-dense forests. DNR has not explored alternative strategies to effectively engage the public or to address public concerns.


• Update the 2006 Policy for Sustainable Forests to reflect the agency’s dual mandate to manage for revenue and for public benefit.

• Implement the authority from CNW v. Franz by developing SHCs for eastern and western Washington that quantify and pursue outputs beyond timber volume as goals, such as carbon sequestration and storage, forest health, and biodiversity. The SHC is a once-in-a-decade opportunity to act on DNR’s dual mandate to beneficiaries and to the public.

• Develop a community and public engagement process. DNR needs a channel to receive and address community input. A new approach should go beyond the current one-sided public comment at the BNR and establish public engagement on policies and timber sales. The agency should consider developing a neighborhood forestlands policy, providing an avenue for meaningful local community input about local timber sale planning.

• Consult with Tribal governments regarding values and desired benefits from state lands. Tribal priorities should be a central consideration in pursuing public benefit in the context of the CNW v. Franz decision. State trust lands are the traditional homelands of numerous Tribes and include culturally significant areas, which provide a range of cultural and ecological benefits to Tribes.


Mature, structurally complex forests on state trust lands are an invaluable public asset that must be protected. For the last several years, the public has consistently repeated this message, only amplifying it throughout 2023. Regenerated naturally, these older forests feature trees of different species, sizes, ages, and heights. Unlike the single-species, even-aged rows of trees grown using agronomic practices, these older forests have significant ecological and social values not easily replaced. They provide multiple benefits including significant carbon storage and sequestration, high quality wildlife habitat, clean air and water, stream temperature regulation, and the creation of woody debris critical for salmon habitat. Geospatial analysis suggests that approximately 77,000 acres of these mature forests remain available for harvest on state lands—less than 4% of the land DNR manages.

Although many of these stands have the potential to become old growth forests in the future, most are not protected under DNR’s Old Growth Policy. The Habitat Conservation Plan (HCP) that guides management of state lands and the Policy for Sustainable Forests both include an objective of 10-15% of forestland under the HCP as structurally complex forests 150-200+ years old. This objective gives DNR a clear mandate to protect older forests. However, the agency interprets the 10-15% as an aspiration rather than a requirement, and they are not on track to achieve it. Older forests also provide a clear opportunity to utilize DNR’s discretion to manage for public benefit, as affirmed by CNW v. Franz.

DNR has continued to conduct timber sales of these ecologically valuable older forests without addressing the consequences associated with clearcutting them. Once harvested, these unique ecosystems are not replaceable within a human lifespan.

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• No progress has been made to protect structurally complex forests or to change the agency’s approach, despite past commitments from Commissioner Franz. With public outcry growing the past few years, conservation and grassroots organizations have asked DNR to develop a new approach to older forests. Commissioner Franz committed to an evaluation of older forests, stating she saw an opportunity “to balance two admirable objectives to protect working forest lands and ensuring older growth trees are conserved for their ecological values.”xiii In May 2022, Commissioner Franz stated the agency would not consider a change to older forest policy and announced DNR would instead conserve 10,000 acres of older forests in a carbon offset project. Selection of the 10,000 acres for the carbon project has not been completed, and harvest of older forests has continued.

• DNR continues to bring forward timber sales that result in clearcutting the remaining structurally complex older forests—despite the flexibility in existing policies and new funding sources. In 2023 the state legislature dedicated $83 million from the Natural Climate Solutions Account, directing DNR to identify and conserve up to 2,000 acres of structurally complex older forest. Despite this directive from the legislature, DNR has neither paused nor reviewed planned sales containing older forests.

• In response to direct requests from counties, the CPL has offered dialogue with Jefferson, King, Thurston, and Whatcom counties about county priorities in management of county trust lands. The letters offer to “collaborate with DNR on a forest-management strategy for your county trust lands that best serves the needs of the beneficiaries, your constituents, and our state.” In two instances, DNR has pulled tracts from scheduled auction when county commissioners have expressed formal concerns with specific timber sales. These pauses have not resulted in a resolution with the counties about the tracts in question, and other contentious sales have moved forward. We hope to see DNR use the various tools at the agency’s disposal to provide the public benefit counties are seeking.

• DNR has not updated practices to reflect the state Supreme Court’s decision in CNW v. Franz. As referenced in the prior section of this report, the department has broad discretion in how it manages forests, affirmed by the State Supreme Court. In the year since the court’s decision, DNR has not pursued new management strategies for these older forests, despite affirmation that the agency is not required to maximize timber harvest revenue. DNR is actively choosing to harvest older forests at a high rate.


• Implement existing BNR and DNR policy of achieving “older forest structures across 10-15% of each Western Washington HCP Planning Unit,” and not harvesting structurally complex stands until targets are met. As the Policy for Sustainable Forests (PSF) states: “Once older forest targets are met, structurally complex forest stands that are not needed to meet the target may be considered for harvest activities.”

• In addition to conserving remaining older forests, grow the future older, structurally complex forests across the landscape. DNR can do this by implementing biodiversity pathways, as specified in the PSF, increasing thinning, and extending rotation length.

• In the short-term, protect a total of 12,000 acres of structurally complex, mature forest utilizing both the 10,000-acre carbon offset project and the 2,000 acres of older forest that can be protected with Natural Climate Solutions Account funding as complementary.

• Develop new strategies to conserve older, structurally complex forests. This is a stated goal of the Carbon and Forest Management Work Group mandated by the legislature. DNR will lead meetings of this group over the next two years to collaborate on forest management strategies for carbon storage.

• As part of the upcoming Sustainable Harvest Calculation modeling, consider preserving older forests for the diverse public benefits they provide. Beyond other criteria outlined in the PSF, older forests offer significant public benefit that is not easily replaced once lost.


DNR manages 2.1 million acres of state forestlands on behalf of trust beneficiaries and the public. The agency’s Strategic Plan 2022-2025 includes this goal: “Seize opportunities to generate benefits for trust beneficiaries and communities by incentivizing carbon sequestration on public and private lands.”

The agency does not have policies or processes to manage for carbon sequestration and storage on state lands. In 2019, WCA petitioned DNR and BNR to create a carbon and climate policy for state lands, which the agency declined to pursue.

In 2021, local communities and conservation organizations began protesting timber sales containing older, structurally complex, forests for their non-timber value—including carbon. As an alternative to an older forest or carbon policy proposed by constituents, DNR announced a 10,000-acre carbon offset project in April 2022. This project would conserve carbon-dense forests in perpetuity.

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• DNR has neither developed a policy nor a strategy to guide management for carbon on state lands, nor has it signaled an intent to include such a policy in the Policy for Sustainable Forests. The agency has chosen not to pursue a carbon policy despite the July 2022 CNW v. Franz decision– which removed the previous perceived barrier that the agency was required to maximize revenue, and could not manage for carbon.

• Progress has stalled on DNR’s carbon offset project. After holding outreach leading to the identification of approximately 14,000 candidate acres, the project appears to have been abandoned, or put on hold with an indefinite timeline. The agency indicates this is due to timber industry lawsuits seeking to stop the program. Although detractors filed a legal complaint against the project, DNR is legally able to proceed. WCA and partners have formally intervened in the litigation in support of DNR. Harvest on candidate parcels has not been paused in the interim, and no public information has been provided since November.

• The legislature granted DNR $83 million to protect 2,000 acres of carbon-dense structurally complex forests on state trust lands. The agency did not support this proposal. It is not yet clear how DNR will use these funds to maximize carbon outcomes. DNR will also soon convene the Forest and Carbon Management Work Group required by the same proviso.

• DNR requested legislation in 2022, seeking authority to sell ecosystem services on state lands. The bill, as introduced, promoted the full range carbon sequestration projects. It quickly devolved to impede carbon projects on state lands. DNR continued to promote the bill despite amendments that prohibited the only forest carbon projects proven effective to date: improved forest management projects like the agency’s own proposed carbon project.

• In October 2023, a Superior Court Judge ruled that DNR violated the State Environmental Policy Act (SEPA) by failing to consider the climate impacts of two timber sales in Jefferson County. DNR responded by including the same SEPA addendum for subsequent timber sales, asserting that carbon impacts are already addressed at a programmatic level across all state lands. A legal appeal is challenging this approach in King County.


• Adopt a policy for managing carbon on state lands, to guide management decisions both at the level of timber sale and across state lands as a whole.

• For the upcoming SHC, quantify carbon sequestration and storage outcomes, and include carbon storage as a goal.

• Provide meaningful carbon and climate impact assessment at the timber sale level, considering different harvesting and silvicultural practices as alternatives.

• Affirm the agency’s commitment to implementing the 10,000-acre carbon offset project and finalize selection of acres for the project.

• Explore pathways to sell carbon credits and other ecosystem services on state lands, including Improved Forest Management Projects within the compliance carbon market. DNR and DOE have been directed by the legislature to create a “state lands ecosystem services asset plan,” which can support this work.

• Explore shifting to extended harvest rotations across state lands, which would store more carbon and produce more timber volume.

• Ensure the work of the forthcoming Carbon and Forest Management Work Group is science based. The group should explore the potential of improved forest management and extended rotations in addition to the conservation of carbon-dense, structurally complex forests.

DNR has neither developed a policy nor a strategy to guide management for carbon on state lands

The Sustainable Harvest Calculation (SHC) sets the timber harvest targets on DNR-managed forested trust lands for the next decade. There are two SHCs in the state, for trust lands on either side of the Cascade Crest. Both SHCs must be approved by the Board of Natural Resources (BNR). DNR is currently working towards proposals for the 2025-2034 SHC for Eastern Washington. These dry forests are significantly different than westside forests, especially in terms of timber production, wildfire risk, drought, and vulnerability to climate change.

DNR has the responsibility to manage trust lands sustainably so that benefits are ensured in perpetuity. The Policy for Sustainable Forests (PSF) directs DNR to consider a wide variety of criteria in formulating the SHC such as: ecosystem health, prevention of catastrophic loss, protecting wildlife habitat, and generating revenue. DNR has wide discretion in how it chooses to emphasize these different criteria in modeling and developing the SHC.


• DNR staff have devoted significant capacity to public education about the SHC. In online and in-person forums, DNR has explained methods to evaluate criteria of interest to the public, such as resilience. This is an important step in a transparent SHC process.

• DNR is considering new aspects of SHC modeling, though it is not yet clear how they will be reflected in SHC alternatives. Information shared by DNR about resilience and disturbance demonstrates the agency is considering ways to reflect climate change and disturbance in SHC modeling. However, it is not yet clear how criteria and new elements will be incorporated, whether the model will optimize for outcomes beyond timber volume, or what numbers will be used. For example, the agency hasn’t discussed specific discount rate options or what discount rate they intend to use.


• DNR has not met with the Technical Advisory Committee this year. DNR has appointed outside experts to a Sustainable Harvest Technical Advisory Committee (TAC) to advise DNR staff on the SHC. DNR has not convened the TAC since November 2022, and there has been no interaction between the BNR (the decisionmakers) and the TAC (the technical experts) to inform the SHC development process.

• DNR has not addressed Resolution 1591, approved by the BNR in December 2022.xii The resolution directs DNR to explore new approaches to the SHC. This includes: 1) Conducting a comprehensive review of discount rates, and 2) Carrying out a multi-objective


• Address all PSF policies and criteria in SHC development. For example, the PSF outlines DNR’s obligations to ensure sustainable forests in perpetuity, to prevent catastrophic loss, to protect and enhance a diverse gene pool of native trees, and to collaborate with Tribes to address culturally significant areas. The PSF also allows DNR to use a variety of tools to consider financial return, including cost-benefit ratios. DNR should demonstrate how they are addressing each of these elements in the SHC process.

• Center resilience, restoration, and climate impacts in the Eastside SHC. Dry eastside forests are less productive than westside forests in terms of timber volume—which is the historic focus of the SHC. They also face significant threats due to climate change, which increases risk of catastrophic loss. Ensuring stewardship of these forests in perpetuity requires evolving the SHC to prioritize supporting adaptation of eastside forests to a changing climate and to increased threats such as wildfire and pests. The agency should exercise its authority to leave mature stands of trees intact, which are more fire resilient and provide multiple benefits.

• Model for severe climate impacts. Since the last SHC, there have been significant advances in our understanding of climate change, and in models predicting climate impacts. To understand the range of possible outcomes in different scenarios, DNR’s modeling should

optimization to explore additional objectives into the SHC, “including but not limited to stored carbon, watershed protection, fish and wildlife habitat attributes, ecological functions and values, associated carbon sequestration, forest health, landscape structural diversity, and local community economies.”

• The timeline for the Eastern Washington SHC is unclear. During 2023, DNR has not provided an updated timeline for the delivery of eastern Washington SHC proposals to BNR. The last available project timeline, shared in July 2022, indicated projected approval of the SHC in the second half of 2024. The process is proceeding more slowly than projected.

include climate-related constraints, including the worst-case scenarios for accelerated climate change. This includes loss of forest ecosystems due to increased drought, wildfire, pests, and landscape conversion.

• Incorporate input from the TAC in the methods, alternatives, and final 2025-2034 sustainable harvest level. As DNR seeks to develop an innovative eastside SHC, the TAC’s input will bring new scientific information and methods to the process. Direct engagement between BNR and the TAC can promote dialogue and new ideas.

• Begin work now to develop a multi-objective, spatially explicit model for future SHCs: DNR’s current modeling optimizes for net present value and is limited by the functionality of Woodstock, the modeling program used by the agency. Woodstock is not well suited to model spatial processes that unfold over time—such as disturbances due to wildfire or insects, which are exacerbated by climate disturbance. A different approach, such as multi-optimization modeling, could be beneficial to actualize DNR’s mandate of balancing monetary benefit for trust beneficiaries with non-monetary public benefit. This transition to a more comprehensive modeling program and methodology for future SHCs will require significant research and development. DNR should begin the process now. This may include partnerships with a research institution to identify and develop new models, and expanding DNR technical staff capacity. Moving forward, the BNR should also consider updates to the 17-yearold Policy for Sustainable Forest to address carbon and climate.


The Trust Land Transfer (TLT) program identifies landscapes of significant ecological and social value on state trust lands and allows DNR to move those lands into conservation status. The program provides funding to purchase replacement lands as compensation for the trusts. TLT has been highly successful in protecting numerous ecologically important areas in the last four decades.

Although the TLT program was not funded during the 2021-2022 biennium, significant collaborative work was completed by DNR and its stakeholder partners as a working group to make the program transparent, accessible, and repeatable leading to new successes and renewed funding.


• This year, the state legislature passed legislation to formalize and improve the Trust Land Transfer program. Established in the 1980’s, TLT has historically only been able to protect common school trust lands through capital budget provisos. In 2023 the legislature passed House Bill 1460 giving DNR the authority to acquire replacement real estate for “economically underperforming” trust land of all types (including county land and state forestlands) with high ecological value. The former trust land can be conserved as a natural resource conservation


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area, natural area preserve, community forest, state park, or other form of public land. The reforms within this bill were derived from recommendations provided by DNR’s TLT working group. This collaborative effort included significant input from the conservation community.

• The state legislature funded TLT projects in the 2023-2025 budget. At DNR’s request, the state legislature allocated $17.33 million to fully fund 5 new TLT projects and complete the Dabob Bay project. This will conserve about 4,425 acres of land. This will protect older forests and salmon habitat, and promote outdoor recreation for the public.


• Secure sustained funding for future TLT projects. The TLT program is still dependent on regular funding from the state legislature to purchase replacement lands and to conserve high value land. There is substantial interest from communities throughout Washington to conserve valued trust lands. DNR will need to continually seek funding on a biannual basis to ensure a range of communities benefit from TLT.

• Ensure appropriate consultation with Tribes throughout the TLT process. Tribes throughout Washington have been disproportionately impacted by unilateral land and water use decisions in the past. Many Tribes have explicitly reserved rights on all public land to hunt, fish, and gather in their usual and accustomed areas. DNR should ensure appropriate engagement with any Tribe(s) that could be impacted by a potential trust land transfer to ensure continued access for tribal citizens. As eligible receiving agencies, Tribes should always be considered for any transfer proposed within their usual and accustomed areas.

• Expand the TLT program’s scope by removing the directive to include only economically underperforming lands. DNR should seek to expand the scope of the TLT program to conserve high value landscapes regardless of their economic performance or revenue potential.

• Apply the collaborative approach the agency used in TLT to work with partners on other issues.


The 270,000-acre Olympic Experimental State Forest (OESF) on the Olympic Peninsula provides habitat for several threatened and endangered species including the marbled murrelet, the northern spotted owl, the bull trout, and the Lake Ozette sockeye salmon. DNR’s 1997 Habitat Conservation Plan (HCP) set aside the OESF as a research zone to test forest management strategies, monitoring, and adaptation.

DNR is implementing the Type-3 (T3) Watershed Experiment in collaboration with the University of Washington’s Olympic Natural Resources Center. T3 is a 20,000-acre study in 16 watersheds in Jefferson County which is examining new approaches to managing forests in the OESF.

Co-written by Olympic Forest Coalition (OFCO) and WCA EVALUATION

• Progress on lawsuit to protect Endangered Species Act-listed species in the OESF: OFCO filed a legal complaint against the US Fish and Wildlife Service to make sure that the service and the state comply with their commitments to protect threatened species and their habitat, and to respond to risks created by invasive species and climate change. OFCO wants to ensure that DNR’s logging will not jeopardize the existence of protected species, and that the service imposes reasonable adjustments to protect the complex forest habitat and clean cold water in the OESF on which owls and bull trout rely. After filing, the service agreed to pause the case and prepare a new biological opinion, which was the relief OFCO sought. This process is ongoing.

‘22 ‘21

• Commissioner Franz invited Jefferson County to collaborate on a new forest management approach for the county trust lands. The majority of the OESF lies within Jefferson County. It remains to be seen what this collaborative management in Jefferson County will look like, or if it will be a notable change from current management.

• New updates to monitoring. Ongoing independent monitoring of timber sales in the OESF by OFCO shows:

• DNR’s significant expansion of road networks, as opposed to minimal efficient road development,

• Inadequate mapping of, and protections for, critical hydrological features, such as streams,

• Inadequate identification, and protection of, unstable slopes and surfaces,

• Continued spread of noxious weeds and other invasive species, particularly scotch broom, which harms ecosystem function and carbon storage.


• Ecologically-based thinning designed to restore forest health should be used on OESF stands. Combined with longer rotations, this approach can provide more timber volume and revenue to local communities and mills while maximizing ecological benefits, including carbon sequestration. CNW v. Franz allows DNR to pursue such strategies.

• Enable public engagement on timber sales. The public is more involved and engaged than ever, with citizens reviewing timber sales and participating in BNR meetings. One easy improvement to current practices would be to establish a consistent process in which the 2-week comment period for the Forest Practices Application always precedes the 2-week comment period under SEPA. This would be an improvement from the current practice of comment periods occurring at unpredictable times.

• An analysis of the data from 2004-2022 shows that the average buffer size on Type 3 streams, which provide important fish habitat, has decreased significantly over this time period. This decrease in protection could further amplify the negative effects of warming temperatures. Riparian buffers protect aquatic ecosystems from the deleterious effects of adjacent upslope forest harvests. Buffers maintain habitat quality by keeping streams cool through shade, and provide a source of wood debris to create pools and filter sediment. Since 2004, OFCO has tracked the average buffer size on timber harvests in the OESF.

• Significant variables are not accounted for in the recently launched T3 study. The study does not include upstream waters or nearby stands of old growth habitat, nor does it have an effective mechanism for measuring the impacts of climate change over the life of the study.

• Allocate funds for more robust research in the T3 study. Additional funding could document and address the full scope of impacts associated with experimental harvesting practices in a changing climate. For example, the T3 study does not include upstream waters that drain into (and ultimately impact) fish-bearing streams. The impact of T3 treatments on habitat for salmonids and char is incomplete without this information, particularly since upstream water temperature and volume are likely to be impacted by climate change. Old growth habitat—critical for Northern spotted owls and marbled murrelets—in close proximity to T3 is still available for harvest by DNR. It is unclear how T3 will account for this external variable over the life of the study. Lastly, increasing temperatures and changing hydrologic cycles associated with climate change may negatively impact survivability of species in the T3 experiment like western redcedar and Douglas fir.


This section addresses topics related to the 9.3 million acres of private forestlands (nonfederal, non-Tribal) that are subject to the DNR-administered Forest Practices Habitat Conservation Plan.xiv These forests are governed by Forest Practices regulations which are developed and adopted via a governmental program called the Adaptive Management Program (AMP).




The basis of the AMP was established in 1987 when the forest policy community achieved a significant milestone with the creation of the landmark Timber Fish and Wildlife (TFW) Agreement.xv The TFW Agreement fostered cooperative working relationships among parties that had been at odds for decades. It brought together a diverse group of participants, including landowners, Tribal representatives, conservation organizations, and state agencies.

In 1999, the Washington State Legislature authorized the development of forest practice rulesxvi based on the findings of the Forests and Fish Report. This resulted in the AMP, which is intended to “make adjustments as quickly as possible to forest practices that are not achieving the resource objectives . . . (and) shall incorporate the best available science and information, include protocols and standards, regular monitoring, a scientific and peer review process, and provide recommendations to the FPB on proposed changes to forest practices rules to meet timber industry viability and salmon recovery…”

These provisions are designed to meet the four goals of the Forest and Fish Report (FFR):

“1. To provide compliance with the Endangered Species Act for aquatic and riparian dependent species on nonfederal forest lands;

2. To restore and maintain riparian habitat on non-federal forest lands to support a harvestable supply of fish;

3. To meet the requirements of the Clean Water Act for water quality on non-federal forest lands; and

4. To keep the timber industry economically viable in the State of Washington.”xviii

The AMP is comprised of a science committee that conducts research and evaluates the best available science to achieve the FFR goals, and a policy committee that crafts recommendations for forest practice regulations based on the science. Recommendations are advanced to the Forest Practices Board (FPB) for final approval and implementation. The AMP consists of caucuses representing westside Tribes, eastside Tribes, the conservation community, industrial landowners, small forest landowners, state agencies, and counties. These caucuses have committed to the challenging task of collaborative decision-making in the regulation of forestry across the state.

DNR has a unique role in the forest practices program: The CPL, or their designee, chairs the FPB, and DNR staff serves as FPB staff. DNR regulates forest practices activities, and DNR is a participant within the AMP. Therefore, DNR is positioned to provide the leadership needed for the AMP process to function effectively.

DNR has a unique role in the forest practices program: The CPL, or their designee, chairs the FPB, and DNR staff serves as FPB staff. DNR regulates forest practices activities, and DNR is a participant within the AMP. Therefore, DNR is best positioned to provide the leadership needed for the AMP process to function effectively.

The Adaptive Management Program (AMP) evaluates the effectiveness of the state's forest practices rules in achieving its objectives and facilitates necessary adjustments. Compliance with the Clean Water Act (CWA) is one of the AMP's core goals, recognizing the importance of cool water temperature for water quality, and downstream fish habitat that fish depend on for survival.

To address industry concerns over regulatory certainty, the Department of Ecology (DOE) issued the CWA Assurances. The assurances operate under the premise that if the AMP is functioning effectively, then forest practice rules developed through the AMP process serve as a substitute for general CWA procedures. However, logging activities often diminish tree cover in riparian areas, causing water temperatures to rise to the detriment of fish such as salmon. As a result, landowners may be in regulatory compliance by adhering to forest practice rules while still technically exceeding CWA water quality standards.

The original 10-year CWA Assurances were put in place under the assumption that the AMP would study and promulgate rules over the 10-year period that would sufficiently protect water quality. By the end of 2021, DOE had extended the Assurances three times, allowing 14 additional years for AMP to create a rule.

Comprehensive studies began in 2005, with the goal of determining the impact of logging on streams. The primary studies concluded in 2017 and were given to the policy committee to evaluate. A technical workgroup was created in 2019 and presented its report concerning water temperature to the policy committee in 2021. The conversation quickly focused on the width of tree buffers needed around streams to meet water temperature standards and to protect aquatic habitat. The policy committee was unable to reach a consensus. After two rounds of dispute resolution, it submitted majority and minority proposals to the FPB.


• DNR abruptly withdrew support from the majority proposal, diverging from DOE. In November, DOE demonstrated leadership by co-developing the majority proposal, together with eastside and westside Tribes, the conservation community, and DNR. DNR withdrew support from the majority proposal one week before proposals were brought before the FPB. This was an unexpected development after 17 months of TFW Policy discussion of Type N alternatives, including DNR’s direct participation in crafting the majority proposal. This shift occurred after the CPL decided to review the majority and minority proposals and “take a hard look at the science”—even though technical experts have spent nearly two decades planning, carrying out, and analyzing the science. As a result, DNR determined neither majority nor majority proposals “strike the right balance of water quality protection and minimizing impact to landowners.” This action diverged from all other state agencies, including DOE, which has the authority to administer the CWA.



1999 Department of Ecology (DOE) grants the Clean Water Act (CWA) Assurances for an initial 10-year period. 2004 Stream temperature study scoping begins. 2009 DOE extends the CWA Assurances for 10 more years, until 2019. 2017 Initial results of stream temperature studies are presented to the policy committee, demonstrating temperature increases due to existing rules. 2018 Based on temperature studies, the policy committee submits a recommendation to the FPB that “action was warranted” and “rulemaking will be needed.” 2019 A stream temperature forms. CWA Assurances two years to allow studies and a rule proposal 40
‘22 ‘21

• At the November FPB meeting, DNR joined the landowner caucuses to vote to advance both the majority and minority proposals to rulemaking. This legitimized the minority proposal, which does not adequately protect stream temperatures crucial to fish like salmon. AMP science clearly shows that this minority proposal exceeds CWA temperature standards, allowing streams to warm. This resolution—necessary for the minority proposal to proceed to rulemaking—did not pass due to insufficient votes.

• DNR then voted against the resolution to advance only the majority proposal to rulemaking—which AMP science shows will achieve the majority of CWA temperature standards. This resolution passed with the support of eastside and westside Tribes, the conservation community, and all other state agencies: DOE, Washington Fish & Wildlife, Agriculture, and Commerce.xix

• In March, the industrial landowner caucus threatened litigation, seeking a FPB revote to advance both the minority and majority proposals to rulemaking. These litigation threats asserted: 1) the FPB violated the Open Public Meetings Act (OPMA) prior to the November meeting through routine conversations between FPB members, and 2) DOE is misinterpreting the agency’s own water quality standards. Had DNR not unexpectedly taken a position against its sister agencies, the FPB vote would have been more decisive, buffering against the timber industry’s subsequent outside-the-process tactics. Rather than demonstrating leadership in support of AMP science and process, DNR's passive approach invited process interference. As program administrator, DNR did not


send a clear message that litigation was an inappropriate response, the very thing that the AMP was developed to avoid.

• In August, at DNR’s urging, the FPB rescinded their prior vote to advance only the majority proposal. The DNR FPB Chair suggested the FPB consider if a recission of the prior decision and a revote was needed to put to rest allegations of OPMA violations. DNR waited until the August FPB meeting to vote on a recission—5 months after litigation threats. This further delayed an already longdelayed rulemaking process.

• The FPB again voted to advance only the majority proposal—without DNR’s support. Throughout the meeting, the DNR FPB chair was vocal in the agency’s position of advancing both the majority and minority reports. A revote again resulted in a 7-6 decision advancing only the majority report—the same decision made 9 months earlier in November. The August revote was another missed opportunity for DNR to join the majority proposal, supporting the best available science, as well as the leadership of fellow state agencies.

• DNR put the CWA Assurances at risk by hindering progress on rulemaking for the majority proposal. In November 2022, DOE Director Watson extended the assurances for one additional year—the fourth extension— based on the FPB’s approval of the majority proposal. The letter states: “If progress stalls or the parties abandon a continued commitment to the AMP, Ecology will consider withdrawing the Assurances and pursuing alternatives to achieve water quality protection under the CWA.”

• Now that the majority proposal is again moving forward, DNR should advance the rulemaking in an expedited fashion. Ideally, the agency will recoup some of the nine months lost amid litigation threats and a revote.

• As program administrator, DNR can lead the AMP towards maintaining the CWA Assurances by taking a strong position against future litigation threats, and by setting a firm tone that the AMP process should be followed. The agency must reject post-hoc assertions that insufficient information exists to support a new Type N rule, reminding participants that all caucuses agreed to the design of the scientific studies and subsequently agreed that the results warranted a response in the form of rulemaking.

• The rulemaking analysis ahead must consider public interest. DNR should include climate change, impacts to fish populations, and other ecosystem benefits and impacts.

temperature technical workgroup Assurances are extended for studies to be completed proposal developed. May 2021


Ecology extends CWA Assurances by one year to allow time for rulemaking.

Technical workgroup completes its report and presents it to the policy committee.

Nov. 2021Oct. 2022

FPB votes to advance only the majority proposal. Mar. 2023

Dec. 2021

TFW Policy discusses proposals, moves through stage I and II of the dispute resolution process, and develops majority and minority proposals.

Nov. 2022

FPB revotes to address violations and advances the majority proposal once more.

Washington Forest Protection Association sends a letter to the FPB threatening litigation, which halts rulemaking.

Aug. 2023


Water typing is the fundamental classification system employed by DNR to assess streams and other bodies of water for fish habitat. Accurate water typing classification is important because it determines the levels of protection the waters receive, such as the extent of required forested buffers along streams. Buffers play a crucial role in providing shade and filtration that are essential for maintaining cool and clean water conditions vital for the survival of species such as salmon.

As an illustration, in the case of a fish habitat stream, logging may be prohibited within 75 feet from the stream bank so that the tree cover will keep the waters cool. Conversely, if the stream does not qualify as fish habitat, a smaller buffer of 0 to 50 feet from the bank might be permitted for logging.

For the past 25 years, forest practices regulations have been governed by an antiquated interim water typing rule that does not provide adequate protection. Despite numerous efforts, the AMP has failed to establish a permanent rule to date.

Water typing rulemaking has gone through a lengthy process. The FPB paused rulemaking and directed caucuses to continue to refine elements of their water typing proposals, particularly related to an aspect called the “anadromous fish floor” (AFF). The AFF is intended to eliminate the need to do electrofishing surveys for anadromous fish in areas of presumed fish habitat. This would lessen the likelihood of error and harm to fish. It would also reduce the number of waterways that would need to be actively classified.

In 2019, the FPB determined that the AFF had not gone through proper AMP process. In response, there was significant dialogue among policy caucuses, two years of work from a FPB subcommittee, and a policy committee workgroup.

When the process was finally ready to proceed in 2022, the FPB chair—the CPL’s designee—unilaterally canceled water typing meetings. The cancellation was explained by the hope that, contrary to the experience of the past six years, a consensus proposal could be brought forward. This resulted in another 6-month delay before the FPB directed rulemaking to move forward with multiple AFF alternatives.


The FPB adopts an emergency water typing system.

1996 Recommendations from Forests & Fish negotiations propose a new water typing system.


DNR finds the model too inaccurate and retains the interim water typing rule.

The conservation caucus drafts a petition for rulemaking which prompts the policy committee to begin addressing a permanent water typing rule.



• DNR was directed to begin rulemaking analysis on the AFF in November 2022, three months after the FPB vote to accept two AFF alternatives for analysis in August. This timeline was consistent with the FPB resolution, based on the premise that DNR could prepare for analysis during the threemonth waiting period. No visible progress was made between the August FPB resolution and November. In the winter, DNR began soliciting a new spatial analyst for rulemaking analysis.

• In March, a water typing rule work group was convened to work on rule language after a 4-year hiatus while awaiting a decision from the FPB. DNR intends to finalize draft language to send to the FPB in time for the November 2023 FPB meeting and complete rulemaking in 2024.

• After 25 years of delay on a permanent water typing rule, and impacts to fish habitat during this time, DNR should seek all opportunities to expedite rulemaking analysis, rule drafting, and FPB approval to advance the process as rapidly as possible. As AMP administrator, DNR must guide the rule through the approval process without further delay. This requires not giving credence to assertions that the AMP process has not been followed, or that consensus among all caucuses must be reached to proceed.

• Expedite the process of the water typing workgroup drafting the rule language by releasing revised rule drafts and scheduling meetings on an ambitious timeline so that DNR can forward the rule to the FPB.

• DNR should use its discretion to draft a rule that is consistent with the best available science and will lead to the protection and restoration of fish habitat. While DNR actively seeks input from caucuses, the agency retains full authority over the content of the final draft rule. DNR has discretion over which stakeholder comments to include or exclude as well as when to submit the draft rule language to the FPB.

• DNR should not allow any additional delays in incorporating the AFF into the final rule. The department must move forward with rulemaking analysis and begin implementation.

The policy committee recommends creation of a new water typing system. 2016 FPB assumes rule development responsibility. 2017 FPB formalizes part of the water typing rule proposed by Tribes, known as the Anadromous fish floor (AFF), and the policy committee forms an AFF workgroup. 2019 The AFF workgroup completes its work. 2021 FPB directs DNR to proceed with rulemaking for water typing. 2022 43

The AMP was founded in the spirit of cooperation. Over time, confidence in this collaborative approach has diminished, leading to strained relationships. Various attempts have been made to address these challenges within the AMP.

Most recently, conflict resolution processes, principals convenings, and a State Auditor’s Office (SAO) report have been the channels for improving AMP functioning. In the past several years, DNR leadership has been neither consistent nor clear. This has created uncertainty and, as a result, minimal progress. This section also considers how DNR’s actions have guided the process forward in the face of litigation threats from the industrial landowner caucus—particularly considering the agency’s role as AMP administrator.

In January 2021, the Washington State Auditor’s Office (SAO) completed a performance audit of the AMP. The SAO recommended made 11 recommendations to remedy the dysfunction it documented. It noted that, without improvement, “the state risks penalties for failing to meet federal requirements.”xx DNR created the SAO Response Plan (SAO Plan) to address the recommendations, which was approved by the FPB in May 2021.

In June 2021, Center for Conservation and Peacebuilding (CPeace) resigned from a conflict resolution process intended to address conflict and tension within the AMP. After working on the AMP 2019-2021. CPeace’s resignation cited the absence of conditions needed for successful engagement. This was the first time, in 25 years of work as an organization, that CPeace had taken such an action.

In response, Commissioner Franz convened a series of meetings of TFW Principals (leadership of the AMP caucuses) in 2021 and 2022. Although principals were designated as leads on certain items in the SAO Response Plan, these items were not the focus of the meetings. The objective of principals’ meetings and the role of principals remained unclear. Principal meetings ended without explanation in July 2022, resulting in participant frustration.



• The most recent SAO Plan update was published in June 2023, with half the items completed or on track. Out of the eleven recommendations, three have been completed, three are “on track” for completion, four are delayed, and one is “on hold”. The SAO Plan update includes inaccurate information, for instance, that two rounds of principals meetings have occurred in the prior six months. They have not.

• The former principals process was ineffective and ultimately abandoned. Principals meetings have not occurred in more than a year, and it is unclear how aspects of the SAO Plan assigned to caucus principals will be completed. Prior principals engagement generated confusion regarding the role of the principles in the AMP, given that principles are not part of the formalized process of the AMP, which consists of the Cooperative Monitoring, Evaluation, and Research Committee, TFW Policy, and the FPB.

• DNR has indicated plans to contact the TFW Principals in late 2023 to assess the level of interest and investment in meetings and, potentially, to engage with a subset for further dialogue. The content and context of potential principal reengagement is not yet clear.

• Enabling delay and obstruction of Type N process: As described in the Stream Temperature and Clean Water Act Assurances section, DNR’s lack of leadership in Type N has slowed down the process by 9 months and signaled that litigation is an appropriate strategy for influencing the AMP process. In the August FPB meeting, DNR acquiesced to timber industry litigation threats by encouraging a rescission of the November FPB vote on Type N proposals, citing the risk posed by alleged OMPA violations. The vote’s recission sets a troubling precedent that litigation may influence and become a part of AMP rulemaking. Litigation threats have strained relationships within the AMP and had a chilling effect on participant communication and cooperation.


• Assertive DNR leadership as AMP administrator can reinforce procedural norms and reestablish trust that has been weakened by litigation threats regarding Type N. DNR should encourage AMP stakeholders to follow the established process, and not give credence to messaging that the AMP is not working when some caucuses are dissatisfied with an outcome.

• Set firm deadlines to protect against rulemaking delay. Expediting the process could renew the faith of various stakeholders as well as force participants to engage on substantive grounds.

• If principals’ meetings are reconvened, DNR should be clear about the objectives and the role of principals in the AMP process: as leaders who guide and support their representatives in TFW Policy and the FPB; not as an additional step in the formal process.

‘22 ‘21

‘22 ‘21

DNR appropriately denied requested extensions of aquatic tideland leases for nonnative finfish aquaculture followed by an executive order prohibiting future commercial finfish net pen aquaculture on state-owned aquatic lands.


DNR manages 2.6 million acres of state-owned aquatic lands, which include tidelands, shorelands, harbor areas, and the beds of navigable waters. Threats to those lands include derelict vessels and structures, creosote timbers, sewage and stormwater pollution, loss of kelp and eelgrass, and ocean acidification.

DNR serves as steward of these lands and has the authority to take action directly through programs such as the Derelict Vessel Removal Program and kelp and eelgrass restoration. In addition, DNR must engage with other state government, Tribal government, and non-governmental organizations to prevent further harm and to restore habitat that supports salmon and other wildlife.


• DNR worked to pass a new law that expands its authority to remove derelict structures and that expedites the judicial process related to derelict vessel recovery. This will help the agency streamline programs that reduce these risks. DNR’s Derelict Vessel Removal Program expanded its operations and staffing allowing for significant progress in removing derelict vessels from our state’s waterways.

• DNR secured funding to pursue kelp restoration and to maintain critical monitoring networks to track aquatic conditions over time. This will inform future management needs.

• DNR appropriately denied requested extensions of aquatic tideland leases for nonnative finfish aquaculture followed by an executive order prohibiting future commercial finfish net pen aquaculture on state-owned aquatic lands. This will protect native salmon from adverse impacts from aquaculture, including organic waste, chemical and drug contaminants, transmission of disease and competition from nonnative fish.


• Coordination with agencies, Tribes, and other organizations is key to managing state-owned aquatic lands successfully. We would like to see increased cooperation with external groups. This would ensure that habitat priorities address critical needs such as restoring nearshore habitat for salmon and forage fish and continuing to implement the recommendations of the Orca Recovery Task Force.

• DNR owns the aquatic lands beneath Capitol Lake, an artificial impoundment of the Deschutes Estuary. Future estuary restoration will require DNR to be a partner in recovery as the Department of Enterprise Services, which secured funding in the 2023 legislative session to begin engineering design work for the restoration. DNR must use its role on the State Capitol campus committee to expedite next steps toward recovery of this southernmost region of the Salish Sea. We recommend DNR engage directly with Squaxin Island Tribe on solutions and prioritize this important project.





Build-out of low carbon, clean energy generating projects remains an important part of our state’s work to achieve our greenhouse gas emission reduction targets. Ensuring the best, most equitable use of state-managed land remains a key component of this larger energy development effort.

DNR’s ability to identify and site clean energy projects on public lands continues to evolve. As the agency works to meet its goal of 1000 megawatt generation, it is crucial that DNR uphold its responsibility for Tribal consultation, along with community engagement and overall impact review.

One tool designed to support this work is a clean energy mapping tool. Mapping tools can be useful in identifying general themes of available land and in generating interest from developers. However, it is incumbent upon the department to ensure that information is not used to enable developers to harm communities or to make it harder for Tribal Nations to protect their Tribal treaty rights. This is an issue actively in play and one that should be monitored carefully.


• DNR’s approach to the development of land leases for wind, solar and geothermal projects continues to develop.

• Opportunities exist to explicitly include protections for the rights of Tribal Nations, habitat or conservation requirements, or land use access requirements.

• DNR has an estimated 215 megawatts of wind power capacity in production or under lease, representing 21.5% of the agency’s clean energy production goal.

• Three solar, one wind, and one geothermal project are in the pre-development stage, and negotiations are underway with an additional wind project developer. The agency estimates 543 MW capacity under lease or pending lease.


• DNR launched a public Clean Energy Site Mapping tool in 2023,xxi targeted toward generating interest among clean energy project developers. The nature of the map of including, “candidate parcels” creates concern for how to protect cultural resources and lands of cultural significance. This is important for the agency to pay particular attention to in order to ensure their goals for clean energy development do not harm Tribes.

• To select “candidate parcels” identified within the map, the agency considers the economically highest and best use for the trust. However, DNR staff acknowledge the agency’s discretion to manage trust lands for environmental, social, and economic good as affirmed by CNW v. Franz. The Clean Energy program evaluates the public benefit of a project, though the details of this process are not publicly transparent.

• Proactive consultation with impacted Tribal Nations and then subsequent changes based on that consultation to the mapping tool, any lease requirements, and policies, as needed, as clean energy siting proceeds.

• As a land manager responsible for managing public lands on behalf of communities for the greatest environmental, social, and economic good, DNR is uniquely positioned to ensure that any clean energy development occurs in ways that uphold Tribal sovereignty, ensure public engagement, and maintain the integrity of the environment. This may include lease agreements that incorporate tools like community agreements, preservation of access, and design adaptations for habitat protection.


During the 2023 legislative session, the commissioner and DNR were supportive of the following important environmental priorities.

Trust Land Transfer Funding and Revitalization (HB 1460): This DNR request bill to modernize and update the Trust Land Transfer Program was the result of a multi-stakeholder process. The legislature also granted $17.33 million to support TLT projects. This item is covered in the State Lands Section.

Establishing a programmatic safe harbor agreement on forestlands (SB 5390): The Northern Spotted Owl Implementation Team commissioned by the FPB recommended DNR enter into a statewide Safe Harbor Agreement (SHA) with US Fish and Wildlife Service (USFWS) as a strategy for spotted owl recovery. After several attempts, the bill was passed this year, authorizing DNR to enter into the SHA with USFWS. The SHA will encourage private landowners to maintain and restore spotted owl habitat.

DNR Webster Nursery Expansion ($7.4 millionState Building Construction Account): This budget allocation to expand the capacity of Webster Nursery is covered in a dedicated item in the Statewide Forestry Issues section.

Removal of Derelict Aquatic Structures and Restoration of Aquatic Lands (SB 5433): Establishes a program to remove and dispose of and restore derelict aquatic structures, such as old piers, to protect waterways and fish habitat, and provides $10.8 million in funding. It also allocates $1 million for removal of toxic, leaching tires from Puget Sound.

Cascading Impacts of Wildfire (HB 1578): This DNR-requested legislation focuses on secondary health and safety effects of wildfire, including smoke and debris. It requires DNR to coordinate with other state and federal agencies as well as Tribal governments. The agency’s continued prioritization of wildfire progress before the legislature is positive. It is important that the legislature ensure transparency so that DNR implements a community-centered approach to wildfire resilience and response work.

Urban Forestry Funding ($5.99 million - Natural Climate Solutions account): DNR secured funds from the CCA’s Natural Climate Solutions Account to support community grants with the goal of increasing urban tree canopy statewide, a tree equity map, tree canopy analysis, and model tree ordinances. An equity and health disparity lens should be central to this work.


DNR has made progress in the following areas which are not covered as full sections in this report but deserve acknowledgment.

Aquatic Invasive Species Program: DNR has made progress in eradicating invasive noxious weeds on the Coast, Puget Sound, and in eastern Washington. The Aquatic Invasive Species Program also created a European Green Crab management program in 2022, and to date has captured and removed more than 300 European Green Crab from Willapa Bay and Grays Harbor Natural Resources Conservation Areas.

Aquatic Lands Environmental Management and Stewardship: DNR reports that more than 90% of new and reauthorized uses of state-owned aquatic lands—such as leases, easements and right of entries—include considerations to protect and to improve aquatic lands. For example: requirements to replace creosote piling and treated wood with more environmentally friendly materials, to reduce shading from overwater structures using grated floats, to limit ground-disturbing activities that may harm habitat like eelgrass beds, and avoidance measures for sensitive habitats like kelp beds.

Aquatic Restoration: DNR is advancing aquatic restoration projects to remove toxic pilings, remove shoreline armoring, restore marine shoreline vegetation, and improve nearshore habitat. Projects include Whiteman Cove, Dickman Mill Sediment Sampling and McNeil Island Still Harbor, and Nooksack River Salmon Restoration.

Orca Task Force Recommendations: DNR continues to advance actions that support the Governor’s Orca Task Force Recommendations: reducing exposure of contaminants through removal of derelict vessels and structures, including creosote-lined structures, protecting and restoring habitat important to orca food sources, zooplankton sampling, ocean acidification monitoring, and programs monitoring impacts of climate change.

Plan for Climate Resilience 3-Year Update: In April, DNR released an update on the agency’s 2020 Plan for Climate Resilience. The report provides an update on climate resilience work, including many topics included in this report. The update also sets 40 metrics across 14 program areas, which will be useful guideposts moving forward.

Statewide Kelp and Eelgrass Plan: DNR has been working with partners to fulfill the requirements of SB 5619: 2022 legislation focused on conserving and restoring kelp forests and eelgrass meadows. Actions have included hosting public workshops and Tribal and state agency webinars. DNR intends to produce a report identifying priority areas for conservation in recovery efforts at the end of 2023.

Urban and Community Forests: In the past year, DNR added eight new employees to offer technical assistance and outreach to cities on urban forestry. The agency also awarded $350,000 in community grants, which will provide resources for cities to do tree planning and inventory, community outreach, and policy development. Of the 13 projects, 10 will benefit highly impacted communities. The additional $5.99 million allocated from the CCA’s Natural Climate Solutions account in 2023 will support expansion of this work.

Wildfire Response and Suppression: In DNR’s role as the state wildfire fighting force, the agency is responsible for wildfire response across 13 million acres of private- and state-owned forestland. According to the DNR’s Wildfire Intel Dashboardxxii, as of September 6th, DNR had responded to 1,508 fires affecting 121,133 acres. Of these fires, 989 fires and 103,082 acres were on DNR-protected lands.


In the coming year, we will be following the developing topics below, in addition to topics and opportunities described elsewhere in the report.

Climate Resilience Strategy: With state agencies, DNR will participate in the Ecology-led process to update the Integrated Climate Change Response Strategy, as required by HB 1170. DNR’s collaboration with other agencies can bring natural and working lands to the forefront of this discussion.

Access and Responsible Recreation (OARR)


statewide strategic planning project: DNR is in the early stages of engaging with stakeholders and Tribes to identify management priorities related to recreation on DNR-managed state lands. In the first meeting, participation leaned heavily towards the offroad recreational vehicle community. DNR should ensure balanced representation from all stakeholders impacted by recreation including diverse recreation interests, industry, and environmental groups. Many participants in the first meeting were confused by DNR’s separate engagement process with Tribes, and would benefit from an explanation of why Tribal comanagers work with DNR in a different capacity.

Sustainable Harvest Calculation

Western Washington

(SHC): In addition to the eastern Washington SHC covered in the State Lands section of this report, DNR also has pending to complete an SHC for the 1.4 million acres of state trust lands west of the Cascade Crest. This calculation will guide logging from 2025 to 2034. The next year will be critical to completing the calculation on time, and with innovation and credibility. Given DNR’s discretion to manage for multiple benefits rather than maximizing revenue, we hope to see a sustainable harvest calculation that models and considers climate change and other goals beyond timber revenue.

Workforce Development: DNR plans to launch a Youth Education and Outreach Program to support K-12 educator professional development on natural resources. The program intends to build the skills and interests necessary for students to pursue future work in the natural resources sector. In addition, DNR is advancing adult workforce development efforts, consistent with direction from the legislature in HB 1168. This includes the expansion of the Conservation Corps crew and pathways to permanent employment for formerly incarcerated individuals who served on state fire response crews.


The Commissioner of Public Lands holds an important and challenging position with unmatched responsibility for stewarding our natural resources. The path set by the CPL has tangible impacts on the health of ecosystems that sustain every single person in our state. That is why we hold the CPL to a high standard.

Washington is at a historic crossroads in managing our forests and public lands for the benefit of communities. The intensifying climate crisis, new funding via the Climate Commitment Act, and the rationale in the CNW v. Franz decision make this moment the right time for a visionary leader to advance a new paradigm for managing Washington’s remarkable forest ecosystems. If the person in this position wants to make profound changes to make progress in this time of both climate and economic challenges, the potential is unparalleled.

Here are some actions a visionary CPL could take:

• Protect our waters and fish with science-based forest practices, such as adequate riparian buffers.

• Harness the power of carbon sequestration and storage on our natural lands to achieve the state’s climate goals.

• Showcase our public state lands as a model for balancing the monetary and non-monetary benefits of forests.

• Reorient wildfire response not only toward suppression and commercial thinning but toward community-led resilience and the return of ‘good fire’ to the landscape.

• Help our most vulnerable frontline communities adapt to wildfire, with solutions originating from local communities.

• Support small forest landowners to access resources and incentives to grow carbon sequestration.

• Promote Tribal treaty rights and the co-manager role of Tribal governments in the agency’s resource management actions.

• Support climate-smart wood supply chains for responsibly sourced wood from Washington.

As this report shows, significant work remains in all the areas above. Given the pace of climate change, time is short to pursue a different path.

Commissioner Franz has made progress in some key areas: securing funds for a critical expansion of Webster Nursery, improving new work on community resilience to wildfire, growing the agency’s recently resuscitated prescribed fire program, and ongoing good work in aquatics. After a several-year process, DNR secured much-needed updates to the Trust Land Transfer program and funding to protect specific parcels. DNR has also continued to advance acres treated under the 20 Year Forest Health Plan. Additional agency accomplishments fall outside of the scope of this report.

For these successes, quantitative goals and metrics are needed to allow us—and all Washingtonians—to understand how well the agency is achieving intended goals and whether investments are delivering real change on the ground.

Unfortunately, this year’s report also documents an ongoing pattern: a lack of collaboration and partnership to confront contentious problems and make progress for the health of our ecosystems and people.

The Adaptive Management Program continues to be entrenched in conflict and delay, exacerbated by the industrial landowner caucus resorting to tactics outside of this multi-stakeholder process, such as litigation, and DNR enabling this behavior.

Forest carbon sequestration continues to be a missed leadership opportunity and a gap in our state’s climate response. We also see a pattern of the agency operating as a lone entity, rather than collaborating with other agencies, community organizations, or civil society.


On state lands, DNR has not seized the discretion of CNW v. Franz, addressed the pleas of the public to protect unique older forests, delivered its promised carbon offset project, or otherwise managed state lands for carbon. Absent the CPL’s leadership, WCA and partners acted by securing $83 million for the protection of carbon-dense forests on state lands.

The CPL has allowed timber revenue to remain a wedge that worsens outcomes for everyone, and is missing the chance to fulfill the potential of the office. Imagine what might be achieved if the CPL actively brokered creative solutions that brought ecological, social, and economic benefits to the state’s communities.

After years of slow progress in key areas, our wish list for the coming year is long:

• Incorporation of environmental justice across the agency’s divisions and land management actions, including on wildfire and on state trust lands.

• A statewide natural and working lands carbon sequestration strategy tied to state greenhouse gas limits and developed in partnership with other state agencies.

• Centering community needs to adapt to wildfire, and directly funding community organizations at higher levels.

• Significant expansion of prescribed fire across the landscape.

• Effectiveness monitoring to understand the impact of investment in forest health treatments on wildfire behavior.

• Update to state lands policies and practices to manage for public benefit, consistent with CNW v. Franz—including prioritizing carbon storage and conservation of mature forests.

• Reinitiating implementation of the 10,000-acre carbon offset project, and protecting an additional

2,000 acres of carbon-dense forests funded by the legislature.

• An eastside harvest calculation oriented toward restoration and non-timber benefits.

• Finalized science-based rules for water typing and riparian buffers on perennial streams.

• Restoration of the Deschutes Estuary impounded by Capitol Lake.

• Leadership on reviewing and siting clean energy projects with protections for tribal treaty rights, habitat protections, and community benefits.

We would welcome collaboration with the agency to advance any of these goals.

We are left wondering: Will the agency have the courage to move beyond the status quo and to innovate? Will the state have the wisdom to embrace new ideas and scientific data even when timber interests may not welcome change? Can the state broaden its view so that forest management promotes the many benefits our complex forest ecosystems provide, beyond wood? In short: will DNR represent the interests of all its constituents?

We don’t have much time to find new paths, new ways of seeing, new ways of operating.

As the 2023 IPCC report stated: “Climate change is a threat to human well-being and planetary health. There is a rapidly closing window of opportunity to secure a livable and sustainable future for all. . . the choices and actions implemented in this decade will have impacts now and for thousands of years.”xxiii

For Washington to seize this closing window of opportunity, the Department of Natural Resources must be a leader in the solutions. We believe in the ability of our state to make this transition, and will be here to applaud, support, and push for innovation every step of the way.

Washington Conservation Action is a statewide environmental advocacy organization that fights for clean air, clean water, healthy forests, democracy and voting rights, and environmental justice. We work to lift up voices too long ignored: those of Native Nations and of communities that bear the brunt of toxic pollution and climate chaos. Our nonpartisan teams collaborate with local groups across Washington to promote civic engagement and to ensure that everyone has access to the ballot. We seek out and support solutions that nurture healthy communities, healthy economies, and healthy ecosystems.



Aida Amirul, Digital Communications Associate

Rein Attemann, Puget Sound Campaign Manager

Rachel Baker, Forest Program Director

Lennon Bronsema, Vice President of Campaigns

Katie Fields, Forests and Communities Program Manager


Heather Millar, Content Manager

Darcy Nonemacher, Government Affairs Director

Jody Olney, Tribal Nations Program Director

Bryan Pelach, State Forestlands Program Manager

Miguel Pérez-Gibson, State Forest Policy Advisor

Rebecca Ponzio, Climate & Fossil Fuel Program Director

Mallori Pryse, Visual Communications Manager

Zachary Pullin, Communications Director

Mindy Roberts, Puget Sound Program Director

Rico Vinh, Forests and Fish Project Manager

i Report on Long-Term Forest Health & Reduction of Wildfire Danger (HB 1168)

ii 20-Year Forest Health Strategic Plan for Eastern Washington

iii DNR Strategic Plan 2022-2025

iv 20-Year Forest Health Strategic Plan: Eastern Washington Treatment Tracking Progress Memo – June 2023

v Washington 2021 State Energy Strategy

vi Leveraging the potential of nature to meet net zero greenhouse gas emissions in Washington State

vii Engrossed Substitute House Bill 1109, April 28, 2019, Sec. 308

viii Washington Forest Ecosystem Carbon Inventory: 2002-2016

ix Small Forest Landowner Carbon Work Group Interim Legislative Report

x Conservation Northwest et al v Franz et al.

xi Settlement Agreement, Skagit County and Thurston County Superior Court Cases

xii Board of Natural Resources Resolution No. 1591

xiii Amid climate crisis, a proposal to save Washington state forests for carbon storage, not logging

xiv Adaptive Management

xv Timber/Fish/Wildlife Agreement

xvi Section 22 Guidelines for Adaptive Management Program

xvii RCW 76.09.370(7)

xviii Section 22 Guidelines for Adaptive Management Program

xix Forest Practices Board 2 Regular Board Meeting – November 9 & 10, 2022

xx Performance Audit, Adaptive Management Program: Improving Decision-making and Accountability

xxi DNR Clean Energy Program Parcel Reviewer

xxii DNR Wildfire Intel Dashboard

xxiii IPCC 2023. AR6 Synthesis Report, Headline Statements


Under the creative commons 2.0 attribution or Standard Adobe License.

Cord Pryse (cover, 3, 6, 12); Underwaterstas (4); Kat Holmes (8); ©Scott F McGee/forest2sea.com (10, 26); Mallori Pryse (13, 46); BLM/Photo by Lisa McNee (16); Rachel Baker (18, 20, 24, 52); Helivideo (22); U.S. Fish and Wildlife Service/

Photo by David Patte (28); Bureau of Land Management (30); Michael Treleaven (32); Jim Freeburg (34); unknown (38); Wild Fish Conservancy (40, 42, 44); Alex Williams (48); Jim Bowen (50)


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