2024 State of our Forests & Public Lands Report

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9TH EDITION | SEPTEMBER 2024

Introduction

Grades at a Glance

Environmental Justice

Tribal Relations

Statewide Forestry Issues

Community Wildfire Resilience

Beneficial Fire

20-Year Forest Health Strategic Plan

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 and Western Washington Sustainable Harvest Calculations

Update: Olympic Experimental State Forest Litigation

Issues on Private Forest Lands

Overview of Forests & Fish and the Adaptive Management Program

Adaptive Management Program Governance and Administration

Water Typing Rulemaking

Protecting Stream Temperature in Headwater Streams and Clean Water Act Assurances

on Aquatic Lands

Washington state faces a momentous juncture in how it manages our natural resources. Do we maintain the status quo, in which logging revenue is often prioritized at the expense of ecological and social values, rural livelihoods are pitted against conservation, and insufficient urgency and resources are devoted to harnessing the full potential of the natural climate solution potential of our state’s forests and aquatic lands? Or do we innovate and implement new, science-based and community-informed strategies to reflect present day needs?

Washington Conservation Action (WCA) is a statewide non-profit organization. We work to mobilize the public, to elect champions for the environment, and to hold our leaders accountable. Since the 1960s, we have monitored the work of the DNR and of the CPL, the elected official who leads and sets the direction of DNR. The current CPL, Hilary Franz, was elected to her second term in 2020.

WCA envisions a future for natural resources management in Washington state that promotes both resilient rural communities and healthy ecosystems. We hope to see forest ecosystems that fight the climate and biodiversity crises, with society and markets rewarding this value creation. We aim to help build a forest sector that supports environmental justice and Tribal sovereignty, and that is accountable to sound science, legal commitments, and local communities.

In November, Washington voters will make key decisions that determine our future, including:

• Voting on an initiative that would repeal the Climate Commitment Act, our state’s historic cap-and-invest program, which tackles climate change and invests in natural climate solutions.

• Choosing a new governor, who will have the opportunity to build on the legacy of the most environmental governor in the history of our state.

• Electing a new Commissioner of Public Lands (CPL) who will lead stewardship of our state’s natural resources at a moment of evolving expectations and new opportunities.

Today, the Department of Natural Resources (DNR) is at a crossroads. DNR has newly affirmed legal authority to manage state lands not just for timber revenue but also for public value. It has yet to integrate this authority into its policy or its practice. DNR will soon establish timber harvest levels that will determine logging on state lands for the next ten years. The agency has started long-awaited rulemaking in forest practices which will have significant, much-needed impact on aquatic resources but has been mired in delay and unexpected setbacks. Unprecedented funding is available to address climate change and wildfires, thanks in large part to the Climate Commitment Act, Washington's innovative, statewide cap-and-invest program. DNR has only just begun environmental justice work. Environmental justice work is critical for communities vulnerable to wildfire, rural timber towns across the state, Tribal governments, and urban communities that rely on the water and climate mitigation forests provide.

Amid all these transformational changes, DNR must also manage increased public and community scrutiny and greater pressure from timber industry associations- powerful business interests that are both DNR customers and entities regulated by DNR.

In January, a new CPL will assume leadership of DNR. One path continues the status quo, while the other path transforms management of our state’s natural resources for the triple bottom line: social, ecological, and economic value. The new CPL will have the opportunity to recommit to management for all the people of Washington, centering conservation, science, climate response, environmental justice, and Tribal sovereignty.

​​Since 2015, WCA has produced ​​the​State of our Forests and Public Lands Report. This is our ninth report and it has two goals: First, to provide our fellow Washingtonians with credible information and analysis on DNR and on the CPL’s work on behalf of our state. Second, to make clear recommendations to DNR and to the CPL to achieve 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:

• Regulation of 12 million acres of state (public) and private forests.

• Management of 2.1 million acres of forested state trust lands.

• Management of 2.6 million acres of state aquatic lands (tidelands, shorelands and harbors).

• Management of 1 million acres of state grazing lands.

• Serving on the Board of Natural Resources (BNR) which sets policies to guide how DNR manages our state-owned forests, aquatic lands, and rangelands.

• Chairing (or naming a designee to chair) the Forest Practices Board (FPB) which adopts rules for private and state forestland that DNR implements and enforces.

• Our state’s wildfire protection.

This report evaluates the work of DNR and the CPL during the past 12 months. Rather than comprehensively evaluating all areas of the agency’s extensive work, we select topics that are core to DNR’s mandate

and where DNR plays a significant role. We only cover areas in which WCA and our partners engage and therefore, are areas that we can evaluate credibly.

As we reflect on the past year, we also think ahead: What could a new CPL, with new ideas, energy, and partnerships accomplish? How could they innovate and explore new strategies? You will see these ideas reflected as “Opportunities for the Next CPL” in each section of this report, alongside smaller scale “Opportunities for the Year Ahead.”

During this election cycle, we’ve frequently been asked: why are there so many candidates for CPL? What does the CPL do? Is it important? After reading this report, we hope it’s clear that the CPL’s role in managing our state’s natural resources is unparalleled. The future CPL’s approach will have significant consequences for the future of both people and nature in our state.

This report continues a nearly decade-long thread of accountability and feedback on the work of the CPL and the agency they lead. It highlights opportunities and expectations for the CPL and the agency they oversee on behalf of the public. Accountability and transparency are as important as ever amid a backdrop of impending change in leadership, new legal decisions, and evolving societal demands.

Lastly, we write this report with gratitude to those who are on the ground advancing this difficult and important work every day. This includes DNR staff, as well as the organizations and communities putting forward their own vision of how our state’s resources might be managed.

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. Our report applies the following grades to DNR’s work during the past 12 months: SUCCESS, WORK IN PROGRESS, or NEEDS IMPROVEMENT. These three grades 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.

ASSESSMENT OF PROGRESS:

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

We select topics based on WCA’s assessment of their importance and timeliness, our organizational priorities, relevance to DNR’s core mandate, and DNR’s level of involvement. We strive to maintain continuity of core topics year-on-year.

Each topic includes an introduction providing context on the topic, 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 future reports. This year, we highlight both near-term and longer-term priorities the next CPL could pursue.

As overarching topics that must be integrated 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.

STATEWIDE FORESTRY ISSUES

COMMUNITY WILDFIRE RESILIENCE

DNR made notable improvements to contracting processes for community organization grantees, enabling more effective project implementation. Equity and Inclusion Grants for organizations serving Latinx communities are positive, though a very modest portion of DNR’s wildfire spending. To address community needs, DNR and other state agencies must prioritize better collaboration. Wildfire Ready Neighbors continues to overlap with other wildfire home assessments, creating excess work for local partners. Notable progress has been made in post-fire recovery and in expanding resilience work in Western Washington.

BENEFICIAL FIRE

DNR addressed some of the barriers to expanding prescribed fire and continued to train burn bosses through their Certified Burn Manager program. However, staff capacity and total acres burned remains low. An April 2024 Leader’s Intent establishes an ambitious objective of 100,000 acres of prescribed burning annually. An actionable plan and significant additional investment will be needed to reach this magnitude of burning. This is more than five times the average annual acres of prescribed fire since the Forest Health Strategic Plan’s inception in 2017.

20-YEAR FOREST HEALTH STRATEGIC PLAN

Forest health treatments in Eastern Washington continue to progress ahead of pace, reaching a total of 790,790 acres. More emphasis is needed on treatment types with the greatest ecological impact: non-commercial thinning and broadcast burns. On state lands, “regeneration harvests” (clearcuts) continue to comprise a large portion of treatments, suggesting more scrutiny is needed over forest health objectives of treatments. Substantially more broadcast burning is needed to restore forest health. On state lands, less than 1% of treatments were broadcast burns. The first 20-Year Forest Health Strategic Plan Monitoring Report, published this year, reflects an ongoing commitment to scientific rigor, building on the landscape analysis used to identify priority treatment areas.

CARBON SEQUESTRATION AND STORAGE IN FORESTS ACROSS WASHINGTON

DNR has not taken steps to develop a statewide plan for enhancing carbon sequestration and storage on natural and working lands. This leaves a void in the state’s climate strategy. The agency has secured funding and initiated mapping to guide future reforestation, but has not advanced other forest-based natural climate solutions. This year, the DNR-convened Small Forest Landowner (SFLO) Carbon Workgroup delivered a report, fulfilling a legislative mandate to provide recommendations on carbon market opportunities for SFLOs. The report contained recommendations that merit further exploration. However, the path forward to prioritize these recommendations and make them actionable is not yet clear.

ISSUES ON STATE TRUST FOREST LANDS

GOVERNANCE AND MANAGEMENT OF STATE LANDS FOR MULTIPLE BENEFITS

DNR has not changed its approach to managing state trust lands following the Washington State Supreme Court’s unanimous CNW v. Franz decision in 2022. The ruling affirmed DNR’s duty to manage for public benefit alongside a duty to provide benefit to trust beneficiaries. The Court also affirmed that DNR is not obligated to maximize revenue. DNR has continued to prioritize maximizing revenue through timber harvest, as demonstrated by ongoing logging of mature forests, as well as a landslide following logging of known unstable slopes in Cowlitz County. DNR has initiated legislatively mandated efforts to create an ecosystem services asset inventory on state lands.

OLDER FORESTS AND CRITICAL HABITATS ON STATE LANDS

DNR’s Habitat Conservation Plan includes an objective to achieve 10% to 15% older forests across DNR managed lands by 2067. DNR has asserted they are on track to meet this objective in the future. However, DNR continues to log existing older, structurally complex forests, even though agency policy commits to harvesting structurally complex stands only once older forest targets are met. These remaining mature forests represent less than 4% of all DNR managed lands. Initiatives led by the conservation community and counties have secured Climate Commitment Act funds to conserve mature forests and buy replacement forestland to add to the trust for timber harvest.

MANAGING FOR CARBON AND CLIMATE ON STATE LANDS

DNR has not changed management practices to enhance carbon storage and sequestration on forested trust lands nor has it explored creation of a carbon policy or a climate policy. DNR continues to log carbon-rich mature forests. The agency also voluntarily halted its sole proposed carbon offset project in response to timber industry litigation. In April, a Superior Court judge ruled in this litigation, affirming DNR’s legal authority to lease lands for carbon storage and sequestration projects. In March, King County Superior Court also found that DNR failed to conduct adequate review of the climate impact of individual timber sales, affirming a similar ruling from Jefferson County Superior Court in 2022 that DNR did not implement broadly.

EASTERN AND WESTERN WASHINGTON SUSTAINABLE HARVEST CALCULATIONS

The Sustainable Harvest Calculations (SHC) for Eastern and Western Washington were delayed due to timber industry litigation that was withdrawn in September 2023. DNR now anticipates completing the SHCs at least one year into the 2025-2034 decadal sustainable harvest period. DNR has not demonstrated how SHC modeling will change to quantify and to promote social and ecological outcomes, beyond the status quo of optimizing for timber revenue. Board of Natural Resources Resolution 1591 requires DNR to consider objectives such as carbon sequestration and storage. The resolution was passed in December 2022, though DNR has neither demonstrated progress nor shared plans to fulfill the Resolution’s requirements. DNR has also not engaged the Sustainable Harvest Technical Advisory Committee this year or last year.

ISSUES ON PRIVATE FOREST LANDS

ADAPTIVE MANAGEMENT PROGRAM GOVERNANCE AND ADMINISTRATION

The Department of Natural Resources (DNR) has made significant progress on the Washington State Auditor’s Office recommendations. However, in its role as program administrator, DNR has taken a passive stance on industrial landowner litigation threats, missing opportunities to reinforce AMP norms. Recently, a Structured Decision Making workshop was held. Facilitators have been brought on board to pilot this decision-making process within AMP, though its long-term trajectory remains uncertain. Lastly, a Timber, Fish, and Wildlife Policy Manual has been approved to enhance program consistency. Despite these efforts, the AMP is facing a substantial $3.8 million budget shortfall, which threatens the continuation of planned projects and stakeholder participation.

WATER TYPING RULEMAKING

Water Typing rulemaking took a problematic turn in August, when core, longstanding elements of the proposed rule were moved to non-binding Board Manual guidance. Earlier this year, DNR hired a contractor to develop spatial analysis to guide the economic analysis for rulemaking. The spatial analysis methodology contains significant issues. It also does not integrate prior, more robust Adaptive Management Program (AMP) analysis produced by a lengthy multistakeholder process. This past modeling studied how well rule alternatives achieve program objectives. The options, materials, and framing DNR provided the Forest Practices Board (FPB) to guide decision making between water typing rule alternatives generated confusion and misperceptions. As a result, the FPB voted to remove these elements from the water typing rule. This path sidelines 8+ years of AMP work, and risks violating both the Habitat Conservation Plan and Tribal treaty rights.

PROTECTING STREAM TEMPERATURE IN HEADWATER STREAMS AND CLEAN WATER ACT ASSURANCES

A stakeholder workgroup was formed to draft new rules for riparian buffers on Type Np streams. DNR struggled to maintain process clarity and inconsistently incorporated stakeholder input. DNR finalized the draft rule language and submitted to the FPB, leading to improved transparency. The Type Np (non-fish perennial) rulemaking analysis relies on the same spatial analysis methodology used in water typing. The significant errors and resolution limitations of this analysis may result in accuracies to the economic analysis. DNR intends to move forward with Type Np rulemaking concurrently with water typing, hopefully avoiding the Type Np rulemaking timeline being negatively impacted by any delays in Water Typing rulemaking.

AQUATICS

ISSUES ON AQUATIC LANDS

DNR continues to grow the Derelict Vessel Removal Program and to make good use of the Watercraft Excise Tax and vessel registration fees. DNR is also preventing boats from becoming derelict vessels through the Vessel Turn-In Program. Reducing toxic discharges is good for salmon and for people, including upcoming work to remove tire reefs from Puget Sound that continue to leach chemicals. A pilot program to accelerate salmon recovery in the Snohomish Basin is gaining momentum and leveraging modest initial investments into millions of dollars of state and federal funding.

CLEAN ENERGY

DNR has made progress in the past year by updating its policies to promote a more robust public process for land-use decisions. The agency has also been focusing on exploratory land use licenses that do not allow infrastructure development or land disturbance. There have been some refinements of the Clean Energy Parcel Screening Tool based on Tribal consultation and public feedback. However, the agency is falling far short of its goal of 1,000 MW of new clean energy generation, with no new projects moving forward in the past year.

CLEAN ENERGY

Environmental justice is a newer DNR priority, but essential if people and communities are to thrive. The agency has been building the Office of Equity and Environmental Justice since hiring the first Director of Equity and Environmental Justice in 2021. Environmental justice appears throughout many of DNR’s planning documents. DNR’s 2022-2025 Strategic Plan features the goal “Embed Environmental Justice practices into DNR management, operations, and processes.” DNR must continue to prioritize environmental justice in agency policies, operations, and internal processes.

CURRENT EFFORTS

• A new equity and environmental justice action plan for DNR Boards and Commissions was published in August 2023. Impacts include:

- Board meeting attendance rates up from 50-60% in prior years to 88% in 2024.

- Increased appointment of women and of people under 40.

- A mandatory public comment period at all board meetings.

- A more accessible application process.

- The addition of two overburdened community member seats to each board.

• A draft Pro-Equity Anti-Racism (PEAR) Plan was published in July 2024. This plan will guide DNR’s work through 2026 to identify and break down both internal and external inequities. The plan addresses eight focus areas:

- Leadership, Hiring, Operations, and Services.

- Workforce Culture, Development, and Equity.

- Tribal Engagement.

- Community Partnerships and Engagement.

- Agency External Communications.

- Equitable Contracting and Systems Improvement.

- Policies, Planning, and Budgets.

- Building PEAR Capacity & Understanding DNR’s Impact.

• Although the Forest Resilience Division published the first division-specific environmental justice plan in 2023, no other divisions have done so.

• As required by the HEAL Act, agency environmental justice assessments began on July 1, 2023, and include agency rulemaking, loan programs, large grants or loans, and agency request legislation.

• DNR intends to classify the Sustainable Harvest Calculation on state lands as a significant agency action, which requires associated environmental justice assessment.

• DNR increased investment in Critical Incident Stress Management tactics to support mental health for high-risk jobs such as wildland firefighting. DNR plans to hire a staff member in Winter 2025 to support this work across DNR.

OPPORTUNITIES IN THE YEAR AHEAD

• Continue to adapt coordination of the HB 1168 funded equity grant program to better support local organizations and the non-English speaking communities this program is intended to serve.

• Hire an ADA Environmental Justice Coordinator to conduct accessibility evaluations and to improve access to DNR-managed recreation sites.

• Update DNR hiring processes and contracting systems to recruit more diverse contractors.

OPPORTUNITIES FOR THE

NEXT

CPL

• Adequately resource the Office of Environmental Justice to ensure that foundational work can advance with deliberate speed, guided by successful, accessible engagement of impacted communities.

• Make environmental justice a standard element of DNR job descriptions and division planning efforts. Ensure every division has a staff member who is focused on environmental justice, including the commissioner’s office. Periodically convene these staff 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. For example, in state lands management through community, engagement, timber sale planning and the Sustainable Harvest Calculation.

• Develop a comprehensive affordable housing plan in collaboration with impacted communities to ensure that any housing development projects on state lands prioritize equity and meet the needs of the communities they serve. Establish policies to avoid significant loss of ecological assets or forest cover.

• Support the Board of Natural Resources to determine how environmental justice is reflected in management of state trust lands moving forward. It is critical DNR explore this topic given the CNW v. Franz decision affirming that DNR has a duty to manage for public benefit and is not required to maximize timber revenue.

The care and protection of our forests and public lands requires close collaboration with Tribal nations. Since hiring its first Tribal liaison in 1991, DNR has taken steps toward improving its policies and processes for upholding Tribal sovereignty and for working in relationship with Washington Tribes. The Office of Tribal Relations is an essential component of DNR’s commitment to maintaining government-to-government relations with the 29 federally recognized Tribes of Washington state, as well as Tribes outside of Washington whose ancestral lands and traditional territories have been divided by state borders.

Tribal nations (treaty and non-treaty) are natural resource co-managers with the State of Washington. Tribal nations should be included in the stewardship of cultural resources. All Tribal nations have sovereign and inherent rights and should be meaningfully consulted, preferably under Free, Prior, and Informed Consent principles. Communication with, and inclusion of, Tribal leadership must be done early and often, with deference to the capacity and the priorities of Tribal nations.

RECENT EFFORTS OF THE OFFICE OF TRIBAL RELATIONS:

• DNR convened the 2024 Annual Tribal Summit, as well as regional meetings related to kelp and eelgrass, and government-to-government meetings regarding recreation, clean energy, and net pen rulemaking.

• DNR and the Squaxin Island Tribe announced a partnership to steward the health of the Tribe’s Squaxin Island Kelp Bed. DNR will create a priority habitat zone around the kelp bed, co-develop ways to improve ecosystem health, and explore restoration work.

• Development underway for a new information platform aggregating updates for Tribes regarding the Climate Commitment Act and facilitating consultation requests. This new system will allow Tribal nations to receive comprehensive information and to prioritize engagement based on issues most important to them.

• DNR is working with Tribal communities to implement the Derelict Vessel Removal Program, cleaning up waterways that impact Tribal fisheries.

• A Cultural Resources Specialist was hired to expand capacity on the Tribal Relations team.

• DNR held four regional meetings with Tribal nations to establish goals and policy objectives for the Outdoor Access and Responsible Recreation (OARR) Strategic Plan. This effort coincided with Governor Inslee’s plan to address recreation guidelines across the state. OARR planning has resulted in government-to-government meetings focused on educating the public on treaties and Indigenous rights, responsible recreation, and the need for more enforcement of recreational regulations.

OPPORTUNITIES

• Define and better integrate co-management with Tribal Governments. It remains critical that DNR explore how to integrate co-management into the agency’s natural resources management decisions. DNR faces the challenge of navigating differing state agency opinions on the definition of “co-management.” However, the CPL can lead by defining principles of co-management or co-stewardship within DNR, and setting expectations for agency partnership with Tribes that may exceed legal requirements. This will allow DNR to better steward both cultural and natural resources and nurture a deeper relationship with Washington's tribes.

• Expand staff capacity on the Tribal Relations team and increase Native staff employment at DNR. To meaningfully engage with Tribes statewide, it is essential that the Office of Tribal Relations hire more staff. DNR should set a goal of a cultural resource specialist and Tribal liaison for each region and continue to promote natural resource career opportunities for Tribal communities. Increasing Native leadership across the agency would strengthen the coordination and the capacity of the Office of Tribal Relations.

• Pursue Clean energy work in consultation and close collaboration with Tribes. Proactively provide updates to Tribal nations about clean energy project exploration and seek Tribal input about project siting. Pursue consultation with Tribal nations and implement DNR’s Tribal Government Consultation Policy for each clean energy project. Adapt the Clean Energy Parcel Screening Tool based on feedback from Tribal nations.

• Commit funding to invest in implementing the Outdoor Access and Responsible Recreation (OARR) Strategic Plan: Funding is needed in order to implement the plan. DNR should structure and centralize the plan around Tribal feedback.

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

Community wildfire resilience (CWR) is the ability to prepare for, adapt to, and recover from wildfire. Community resilience is critical in Washington, where fire is a natural part of the landscape. CWR is closely intertwined with natural resource management objectives, such as forest health and beneficial fire.

CWR is a newer but well-established DNR priority. It appears throughout DNR’s planning documents including the 2022-2025 Strategic Plan, Wildland Fire Protection 10-Year Strategic Plan, and the 20-Year Forest Health Strategic Plan.

EVALUATION

• Greater collaboration is needed with other agencies including Emergency Management Division (EMD), and Departments of Ecology, Transportation, and Health. Resilience touches on numerous areas outside of the traditional purview of a natural resource agency. It therefore requires coordinated efforts with other agencies. DNR’s post-fire recovery program has begun establishing stronger connections with EMD. New work in smoke preparedness is also strengthening relationships with the Department of Health and local clean air agencies. DNR should build on these relationships.

• Wildfire Ready Neighbors (WRN) program still in need of changes. The program continues to focus on home wildfire preparedness assessments that are not integrated with existing assessments used by fire districts. As a result, redundant work must be completed to meet the different standards. WRN still lacks dedicated financial and administrative support to implement the home hardening measures identified by home assessments.

• Improvements to contracting and funding for community organizations. Funding to community organizations is supporting a broader range of initiatives, and community organizations have benefitted from support in preparing grants. While there is still room for improvement, extending some contracts from annual to multi-year has allowed organizations to implement programming more effectively.

• Wildland Fire Protection 10-Year Strategic Plan review. The midterm review of the 10-Year plan by DNR staff and the Wildland Fire Advisory Committee is an important first step to promote effective implementation in the remaining five years. In the plan’s first five years, significant progress has been made on raising awareness about community resilience. Much work remains to define roles and responsibilities to reduce risks to lives and property.

OPPORTUNITIES IN THE YEAR AHEAD

• Update the Wildfire Ready Neighbors program, including integrating assessments with existing, nationally recognized programs where appropriate. Coordinate with other DNR programs, state agencies, and partners to develop cost share or other financial support to residents for home hardening.

• Proactively invite public input in the development and implementation of the statewide wildfire hazard mapping mandated by SB 6120 to reflect additional nuance and on-the-ground conditions. While SB 6120 allows local jurisdictions to develop their own maps, public engagement in the state-level hazard mapping process remains critical. Additionally, engagement with the Insurance Commissioner’s office will be important in development, and subsequent use, of wildfire hazard maps.

• In DNR’s upcoming December report to the legislature on HB 1168, provide transparent information about community resilience expenditures. Specify how community resilience expenditures support community resilience and provide a breakdown of spending by program, e.g. Wildfire Ready Neighbors and Equity and Inclusion grants.

• Expand the Wildland Fire Advisory Committee to include an environmental justice position.

• Expanding CWR into new areas. With funding from HB 1578, the post-fire recovery program is developing technical tools and outreach materials. This additional funding also supports growing westside community wildfire resilience efforts.

• Many DNR staff members are engaged and committed to supporting local-level CWR efforts including Community Wildfire Protection Plan (CWPP) development, expanding programming and communicating about current and future policy efforts.

• Environmental Justice: In FY 2024-2025, DNR has committed approximately $1.2 million of HB 1168 funds to Equity and Inclusion Grants for organizations serving Latinx communities. This funding supports wildfire education and community wildfire preparedness work. This is slightly less than 1% of the $125 million in total biannual funding specified by HB 1168 which requires that at least 15% of appropriated funds be spent on community resilience activities.

OPPORTUNITIES FOR THE NEXT CPL

• Fund community-based projects as investments in capacity that provide “seed funding” to create systems-level change rather than short-term, project-based funding.

• Empower regional DNR staff to leverage agency resources in innovative ways, following the lead of local champions who know best what their communities need to be resilient to wildfire.

• Support integration of CWPPs with hazard mitigation plans and comprehensive plans to create cohesion, strengthen relationships, and maximize community engagement— while recognizing the different values and objectives of each plan.

Beneficial fire is planned fire used to accomplish stewardship goals. Beneficial fire encompasses a range of practices, including cultural burning, prescribed fire, and allowing some wildfires to burn when they can achieve forest health objectives.

Cultural burning is one category of beneficial fire, and it is not limited to achieving forest health goals. Rather, cultural burning includes the use of fire for a range of social, ceremonial, and ecological purposes, and Tribes’ sovereign authority governs such uses of fire in cultural contexts.

Prescribed fire is critical to forest health in the fire-adapted forest ecosystems of Washington. A growing body of research emphasizes that thinning coupled with fire is more effective than thinning alone for forest health. Implementing prescribed fire appears in the DNR strategic plan, in the 2020 Forest Action Plan, and the 20-Year Forest Health Strategic Plan

EVALUATION

• DNR conducted a sustained, but not increased, pace of prescribed burning this year. DNR conducted three prescribed burns totaling 474 acres in Fall 2023 and three burns totaling 540 acres in Spring 2024 (a total similar to Spring 2023).

• In total (including DNR-led burns), 3,230 acres of prescribed burning have been reported to date statewide in 20241 . 41,262 acres of prescribed burning were reported for 2023. The acres burned are predominantly pile burns rather than broadcast burns.

• The CPL published a Leader’s Intent, setting an ambitious goal to reach 100,000 acres of annual prescribed fire across all land ownerships by 2027. The current annual average across all lands since the 20-Year Forest Health Plan’s inception is 19,600 acres. DNR would need to quickly and drastically scale up efforts to achieve this goal.

• Two DNR certified burner program trainings were attended by 32 individuals. Twelve trainees are now Certified Burn Managers. This will support expanding prescribed fire statewide.

• Progress on addressing some recommendations from the July 2023 barriers assessment. DNR prescribed fire staff are updating permitting and burn plan processes and sharing more information through the agency’s burn portal. Many identified barriers remain unaddressed.

• DNR not advancing beneficial fire legislation. During the past year, DNR was in dialogue with partners about a planned bill to add staff capacity and resources. However, the bill will not be part of DNR’s 2025 legislative agenda.

• Environmental Justice and Tribal Sovereignty: DNR staff have identified a need for a staff person dedicated to developing prescribed fire agreements with Tribal nations. The pathway to this role is less clear in the absence of beneficial fire legislation.

OPPORTUNITIES IN THE YEAR AHEAD

• Build staffing capacity needed to scale up prescribed fire, including burn plan writers.

• Prioritize funding for a contract specialist to assist with prescribed fire agreements with Tribes through a budget proviso or unallocated HB 1168 funds.

• Build out a public-facing dashboard to share timely and comprehensive data on prescribed burns.

• Develop an ambitious, but achievable, science-based implementation plan for increasing the number of acres burned, up to the level indicated in the Leader’s Intent.

• Establish roles and responsibilities for DNR staff and external partners to advance each action item in the barriers assessment.

1 These data represent broadcast burning conducted on lands managed by state and federal agencies, Tribes, NGOs, and private entities and are inclusive of the DNR state lands totals. Data sources: DNR October 2023 and May 2024 Treatment Tracking Memos.

OPPORTUNITIES FOR THE NEXT CPL

• Collaborate with state and federal agencies to implement stated commitments to expanding beneficial fire.

• Advance comprehensive legislation to enable expansion of beneficial fire including staff capacity, addressing liability, and removing barriers to cultural burning.

• Incorporate more local input, especially as local prescribed burn associations emerge and implement more burns throughout the state.

• Prioritize relationships and partnerships with Tribal governments to reduce barriers to cultural burning on Tribal lands and elsewhere.

Excluding fire from Washington’s forests during the 20th century overloaded much of our state’s forestlands with fuels. This dynamic contributes to poor forest health and exacerbates wildfires. Treatments like prescribed fire and thinning—while leaving older trees—moves forests closer to historical conditions and increases resilience to climate change. A 2020 study estimates that 3 million acres in Washington need restoration.

Forest health weaves throughout DNR’s strategic plan, most explicitly in the goal “Healthy forest ecosystems in priority watersheds.” The 20-Year Forest Health Strategic Plan (FHSP) is the agency’s guiding document for this work. It sets a goal of 1.25 million acres of restoration treatments in Eastern Washington 2017-2037. DNR’s role in the FHSP is twofold: managing forest health on state trust lands and supporting implementation across all land ownership types.

EVALUATION

• Forest health treatments statewide, 2017- June 2024

- Total acres treated: As of June 2024—1/3 through the plan timeframe—790,790 acres were treated (63.6% of the 1.25-million-acre goal).2

- Acres treated in priority areas: 50% of acres treated (391,465 acres) are in the 47 priority planning areas that have undergone landscape evaluations.3

2 20-Year Forest Health Strategic Plan: Eastern Washington Treatment Tracking Progress Memo – May 2024

3 Analysis has been completed on 41 planning areas, with an additional six in progress and anticipated to be completed this year.

• Forest health treatments on state trust lands managed by DNR, 2017- June 2024

- Treatment types: The majority of treatments were non-commercial thinning (58.4% of treatments).

- Predominance of regeneration harvests: Among commercial treatments (29.8% of all forest health treatments), the vast majority (73.5%) were “regeneration harvests.” A regeneration harvest is a clearcut or the harvest of the majority of trees in order to establish a new stand for commercial harvest (rather than for forest health objectives).

- Prescribed fire: 11.1% of treatments were prescribed fire. Prescribed fire is divided into broadcast burns and pile burns. Pile burns are a common forest management practice after harvest. Broadcast burns are the most critical prescribed fire to expand, given forest health benefits. Broadcast burns comprised just 0.6% of total treatments.4

• The forest health tracker would continue to benefit from minor adjustments to enhance usability. The tracker is the main public-facing source of information on forest health treatments.

• The first 20-Year Forest Health Strategic Plan monitoring report marks a significant, positive milestone. The report sets the stage for communication with legislators and local implementers.

• The CPL’s Leader’s Intent advocates for increased pace and scale of prescribed fire.

• Environmental Justice: In 2023, Forest Resilience was the first DNR division to publish an Environmental Justice Implementation Plan. The division later incorporated social vulnerability indices into their decision-making, added language interpretation to service forestry, and improved access to financial resources for small organizations.

OPPORTUNITIES IN THE YEAR AHEAD

• Expand prescribed fire and non-commercial thinning on state lands, consistent with management for public benefit.

• Publish and implement basic criteria indicating what qualifies as a forest health treatment. Be transparent about when and why regeneration harvests are considered forest health treatments.

• Integrate findings from the 20-Year Forest Health Strategic Plan monitoring report into forest practices applications.

• Improve the Forest Health Tracker by making the map and project list clearly visible on the landing page. Provide definitions of all treatment types on the glossary page. Add a “completed year” filter.

OPPORTUNITIES FOR THE NEXT CPL

• Continue to build on scientific analysis and reporting on forest health treatments. Share information with legislators and practitioners. Continue to collect, refine, and share forest health data.

• Create guidance for use of managed wildfire to achieve forest health objectives.

• Lay the groundwork to secure allocation of adequate resources for forest health beyond the wildfire funding account created by HB 1168, which will sunset in 2029.

4 Broadcast burning on state lands was re-initiated in 2022. Therefore no treatments of this type were reported for 2017-2021.

• Develop an approach to forest health work in Western Washington. The geographic scope of DNR’s FHSP is Central and Eastern Washington. No comparable plan exists for Western Washington. Wildfire is increasing on the west side of the state and requires dedicated planning to address forest health in densely populated areas with different forest ecosystems.

We cannot achieve Washington’s goal of carbon neutrality by 2050 without our state’s forests. Peer-reviewed research concludes that more than 80% of our state’s potential to draw down additional carbon in natural systems lies in forest ecosystems. The passage of the Climate Commitment Act (CCA) in 2021 created opportunities to promote forest carbon sequestration and storage. These include carbon offsets and Natural Climate Solutions Account investments.

As the lead state agency on forestry, promoting forest carbon sequestration and storage aligns with DNR’s mandate. The 2022-2025 Strategic Plan includes a goal to “Reduce net greenhouse gas emissions and strengthen local economies,” including “by incentivizing carbon sequestration on public and private lands.” This section focuses on DNR’s leadership role in forest management statewide, rather than as the manager of state trust lands.

EVALUATION

• DNR still lacks a coordinated plan for enhancing carbon sequestration and storage on natural and working lands. After DNR chose not to support a proposed proviso to create a statewide strategy in the 2023 legislative session, the issue was not addressed in the 2024 legislative session. This leaves a void in the state’s climate strategy.

• Past DNR work on forest carbon sequestration and storage has not resulted in agency action, such as the 2020 Carbon Sequestration Advisory Group report, Forest Ecosystem Carbon Inventory, and 2022 Carbon Playbook.

• DNR is advancing planning to promote reforestation. In collaboration with American Forests, DNR is mapping and prioritizing areas for reforestation and afforestation statewide. DNR is also developing a post-wildfire reforestation program to invest the $10 million allocated by the legislature in 2024. $2.5 million will fund post wildfire reforestation on DNR lands, and $7.5 million will fund post wildfire reforestation on other non-federal lands.

SHORT-TERM OPPORTUNITIES

• Seek legislative support to develop a Natural and Working Lands Carbon Sequestration Strategy in collaboration with other state agencies. A strategy should establish measurable goals and identify priority interventions and investment, including from CCA funds.

• Leverage CCA funding for projects that use verifiable and innovative approaches to enhancing carbon sequestration and storage.

• Refine the most promising SFLO Workgroup recommendations to pursue DNR-led development and support. For example: Investing in statewide remote sensing modeling of forest composition and structure to use as a “Washington’s forest census (wall-to-wall inventory),” exploring financial incentives to enhance carbon sequestration and storage, and developing an “Apprenticeship-to-Ownership” program to connect older SFLO to young people interested in forestland ownership— prioritizing historically marginalized communities.

• Through the DNR participant in the U.S. Forest Offset Protocol Technical Working Group, bring forward credible recommendations to reduce barriers to SFLOs and Tribal governments implementing Washington’s U.S. Forest Offset Protocol.

• Small Forest Landowner (SFLO) Carbon Workgroup report delivered. The 2021 CCA directed DNR to contract Washington Farm Forestry Association (WFFA) to convene a workgroup to explore carbon market opportunities for SFLOs. The workgroup’s final report, delivered in June 2024, contains numerous recommendations for DNR to explore. The report includes a recommendation for adjusting Washington’s U.S. Forest Projects offset protocol, currently the focus of the Ecology-convened Forest Offset Protocol Technical Working Group. However, this recommendation does not include specific or actionable language for inclusion in a protocol update.

• Environmental Justice and Tribal Sovereignty: The SFLO Carbon Workgroup report considered environmental justice, highlighting the need to gather more information and to engage with underserved populations. The report does not deliver actionable recommendations specific to supporting underserved communities in accessing carbon incentives, nor does it directly address barriers facing Tribal governments with smaller forested land bases.

OPPORTUNITIES FOR THE NEXT CPL

• Develop DNR programs and strategies to promote natural climate solutions in forest ecosystems. These should go beyond reforestation, with an emphasis on improved forest management. The majority of Washington’s natural climate solutions potential is in transitioning to climate-smart practices in existing managed forests. For instance, 67.8% of the state’s potential to store carbon in natural systems is in extended harvest rotations.5

• Explore financial tools and develop in-house technical capacity to help private and Tribal landowners transition to climate-smart practices and to explore actionable carbon sequestration projects.

• Demonstrate climate-smart forest management on state trust lands.

This section addresses topics relevant to the 2.1 million acres of public forests that are held in trust “for all the people” of Washington, and managed by DNR to generate revenue for trust beneficiaries such as counties and school districts and to provide public benefit. 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.

DNR has traditionally managed forested state trust lands to maximize revenue through timber harvest. In July 2022, the Washington State Supreme Court issued a unanimous ruling in CNW v. Franz. The court affirmed that DNR has three responsibilities: generate benefits for trust beneficiaries, provide benefits for all Washingtonians, and comply with all state and federal laws. The court clarified that DNR does not need to maximize revenue, nor is the agency required to harvest timber. The ruling stated that DNR can generate revenue or otherwise serve beneficiaries through a variety of means. In addition, the Court held that DNR has a constitutional duty to manage lands to benefit all the people of Washington—not solely trust beneficiaries.

EVALUATION

• DNR has made no changes to management practices or policies to reflect DNR’s duty to manage for broad public benefit. More than two years after the CNW v. Franz decision, DNR has not signaled any intent to update policies guiding management of state trust lands to reflect the duties affirmed by the State Supreme Court.

• Thurston County Superior Court affirmed DNR’s authority to proceed with carbon leasing, after DNR voluntarily paused the agency’s carbon project for over a year. The April 2024 ruling gave DNR the greenlight to pursue carbon projects on 10,000 acres of state trust lands, rather than logging. The ruling further confirms DNR’s wide latitude to manage forests for non-monetary value, and to pursue alternative ways to generate revenue.

• A landslide in the Double Haul timber sale demonstrated how pressure to maximize timber revenue puts public resources at risk. This timber sale adjacent to the Merrill Lake Natural Resources Conservation Area in Cowlitz County included unstable slopes. WCA and several organizations flagged significant landslide risk prior to the sale’s approval. DNR chose to log the unstable areas regardless. Landslides in November and December 2023, shortly after logging, damaged a forest road, a fish-bearing stream, culverts, and a lakeside campground. The cost of repair will exceed the value of timber sold from the unstable areas.

OPPORTUNITIES

IN THE YEAR AHEAD

• Issue clear guidance to act on the authority affirmed by CNW v. Franz. This guidance should come directly from the CPL to DNR staff and the BNR.

• Implement BNR resolution 1591, requiring DNR to explore incorporation of non-monetary benefits in Sustainable Harvest Calculation (SHC) modeling.

• Enhance proactive outreach and consultation with Tribal governments on all aspects of state lands management.

OPPORTUNITIES FOR THE NEXT CPL

• Continued harvest of mature forests. Despite legal confirmation of DNR’s broad discretion in managing trust lands, the agency has continued nearly monthly auctions of timber sales with significant stands of mature forests. Communities and some counties continue to actively oppose these sales.

• In April, DNR convened the Ecosystem Services Workgroup. As directed by the state Legislature, this group will advise DNR in the creation of the Ecosystem Services Asset Inventory and Asset Plan for DNR-managed lands.

• No changes made to public engagement. Despite growing public concern, robust public comments, letter campaigns, and even in-person protests, DNR has not developed new communication or public engagement strategies.

• Environmental Justice and Tribal Sovereignty. DNR has several agency-wide environmental justice and Tribal engagement goals in the Strategic Plan 2022-2025. This has not resulted in changes in the agency’s state lands work.

• Update DNR’s foundational Policy for Sustainable Forests to reflect DNR’s discretion to provide benefit to beneficiaries in “myriad ways,” as well as their mandate to manage for non-monetary public benefit.

• Set decadal timber harvest levels in Eastern and Western Washington SHCs that optimize for non-monetary benefits alongside net present value. This evolution would align with the CNW v. Franz decision and support balanced ecological, social, and economic outcomes.

• Establish new outreach and consultation strategies to improve engagement with the general public and Tribal nations, including a formalized process to gather input about desired public benefit and cultural protections to guide management strategies.

• Quantify ecosystem services impacts of state lands management actions to understand public benefit, e.g. carbon sequestration and storage, water provisioning, and water quality. Create incentives for staff to generate these benefits in their management planning.

Mature, structurally complex, carbon-dense forests on state trust lands are an invaluable public asset. These older forests feature trees of different species, sizes, ages, and heights. Such ecosystems provide many benefits including significant carbon storage and sequestration, critical habitat for wildlife, and healthy streams.

The Habitat Conservation Plan (HCP) and the Policy for Sustainable Forests (PSF) guide management of state lands, including an objective for 10% to 15% of forestland to be older, structurally complex forests. This objective has not been achieved. The PSF calls for only considering harvest of older, structurally complex forests once the 10% to 15% target is met. Past analysis suggests that approximately 77,000 acres of mature forests on state lands remain available for logging. That’s less than 4% of DNR managed forestlands. This number is likely lower now since DNR continues to conduct timber sales of these forests.

Concern for the conservation of DNR’s older forests has continued to grow, with more state and local representatives echoing the sustained public calls to stop logging these lands. Although DNR has clear authority to act in response to these concerns, the agency and CPL have chosen not to do so. Instead, actions to conserve older forests have originated from the Legislature, the BNR, county governments, the conservation community, and local communities.

EVALUATION

• DNR has not changed management of older forests. DNR has the discretion to choose which stands it harvests on state lands. In addition, the Carbon and Forest Management Work Group (CFMWG)—which the legislature directed DNR to convene—is developing recommendations for management of older forests on state lands. While this work is underway, DNR has continued to present timber sales containing older forests for approval.

• DNR’s current strategy for achieving 10% to 15% older, structurally complex forests would create few additional ecological benefits. In July, DNR staff reported to the BNR that the HCP requirement for 10% to 15% structurally complex older forests will be met through existing practices. This approach concentrates older forests in riparian zones where harvest is already restricted. This would worsen edge effects rather than establishing large stands of mature forest with additional value for habitat and for carbon.

• 2,000 acres selected to be conserved in perpetuity. The Legislature appropriated $83 million in 2023 to conserve mature forests on state trust lands and to purchase replacement forestland for ongoing harvest. DNR did not support this effort, which was led by WCA and partner conservation NGOs. In 2024, DNR advanced implementation by identifying 2,000 acres of mature forests to be conserved across five counties in Western Washington, and 9,115 acres of replacement land in Wahkiakum to add to the trust.

• Second budget allocation by the Legislature to conserve mature forests and buy replacement timberland. In 2024, the legislature appropriated $15 million to conserve additional mature forest in four Western Washington counties, as well as to purchase replacement land for encumbered lands. This effort was again led by conservation organizations and counties.

• DNR was directed to pause a mature forest sale in Thurston County in response to county commissioner requests. The BNR delayed voting on the Juneau timber sale in March 2024, prompted by objections from Thurston County commissioners. Thurston County is responsible for developing an alternative management plan by October 2024.

• Conserving older forests is not a stated priority in the forthcoming Sustainable Harvest Calculation.

• Environmental Justice and Tribal sovereignty: Tribal governments have unique concerns regarding expanded conservation of mature forests. Currently, it is unclear how DNR management reflects Tribal management priorities.

OPPORTUNITIES IN THE YEAR AHEAD

• Pause all timber sales containing mature forests until the CFMWG delivers final recommendations to the state Legislature, expected in December 2025. DNR must maintain the work group’s focus on delivering recommendations for mature forests on trust lands. This is consistent with longstanding recommendations to pause harvest of mature forest until a comprehensive plan and appropriate policy is created.

• Complete the 9,115-acre Deep River Woods acquisition using funds appropriated by the legislature in 2023 and transfer the selected 2,000 acres of mature forest into conservation status.

• Complete acquisition of additional Deep River Woods forestland with the $15 million from 2024 legislative funding. Finalize selection of the highest ecological value mature forest to conserve in Pierce, Thurston, Snohomish, and Kitsap counties.

• Reinitiate DNR’s proposed carbon offset project to conserve additional acres of mature forests.

• Collaborate with stakeholders and conservation advocates on climate funding to support win/win projects that store and sequester carbon, support rural communities, and improve habitat.

OPPORTUNITIES FOR THE NEXT CPL

• Develop a Mature Forest Policy to guide management of mature, structurally complex forests. This must include achieving the 10% to 15% older, structurally complex forest goal and implementing conservation strategies where appropriate.

• Direct DNR to plan timber sales with consideration of the multiple benefits mature forests provide, as well as potential alternative revenue sources such as carbon credits and non-monetary cultural and ecological benefits.

• Grow the mature, structurally complex forests of the future. Increase prevalence of mature forests across the landscape by using uneven aged management, extended harvest rotations, and thinning.

DNR’s Strategic Plan 2022-2025 includes the goal: “Seize opportunities to generate benefits for trust beneficiaries and communities by incentivizing carbon sequestration on public and private lands.”

DNR 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. DNR did not take up this issue in 2019 nor in subsequent years, citing legal uncertainty about the agency’s discretion while awaiting a decision on CNW v. Franz The CNW v. Franz decision issued in July 2022 affirmed DNR’s discretion to manage for values like carbon storage.

In 2020, 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. DNR voluntarily halted this project when a legal challenge was filed by American Forest Resource Council (AFRC), Lewis County, and Skagit County.

EVALUATION

• DNR has not taken steps to create a policy guiding forest management for carbon or climate, nor has it pursued management strategies that have the greatest impact on carbon sequestration and storage.

• In March, King County Superior Court ruled that DNR “failed to conduct an adequate review of the climate change impacts of the Wishbone Timber Sale,” in response to successful litigation from conservation organizations. DNR is now required to account for climate impacts of individual timber sales in SEPA analysis. A 2022 Jefferson Superior Court ruling reached the same conclusion, though DNR did not subsequently integrate timber sale-level carbon impacts into SEPA analysis across its timber sales.

• In April, Thurston County Court affirmed DNR’s authority to pursue carbon leasing, resolving the legal challenge on the agency’s proposed 10,000-acre carbon project. DNR defended against this litigation alongside conservation intervenors, though unfortunately elected to pause the project during the 12+ months that the litigation was active. The ruling affirmed that DNR has the constitutional and statutory authority to implement carbon projects, and that the SEPA process for the project to date was adequate. DNR can now confidently move forward with the carbon project.

• To date, DNR has not included carbon storage in Sustainable Harvest Calculation (SHC) modeling nor goals. The agency is exploring how to better incorporate impacts and increased disturbance due to climate change in modeling for the 2025-2034 SHC, but has not indicated plans to incorporate carbon storage and sequestration as an SHC outcome.

• DNR identified 2,000 acres of carbon-dense forest to conserve, as required by the legislature, though continues to harvest other carbon-dense forests. DNR is using the $83 million appropriated by the legislature in 2023 to conserve carbon-dense forests in Western Washington. Beyond these 2,000 acres, timber sales containing mature, carbon-dense forests continue to be nominated at nearly every BNR meeting.

• The DNR-led Carbon and Forest Management Work Group is exploring approaches to forest management and carbon on state trust lands as directed by the Legislature in 2023. Reaching consensus has been challenging, but in May 2024 the work group achieved the initial step of agreeing on modeling 16 management scenarios. Six scenarios include lengthened rotations and deferred harvest of mature forests.

• Environmental Justice: DNR requested legislation in 2023 proposed creation of a new trust obligation on state lands to generate revenue for childcare. Though it did not pass, HB 2243 called for purchase of forestland to manage for timber revenue. The initial version of the bill required management “for the dual purposes of enhancing carbon sequestration and revenue production,” though this language was removed in a substitute bill. The amount of revenue to be generated under this proposal was unknown and likely minimal compared to the need for childcare funding. It would have expanded an antiquated reliance on timber harvest to fund critical community needs, creating conflict between community wellbeing and conservation goals and obligations.

OPPORTUNITIES IN THE YEAR AHEAD

• Vigorously defend against the AFRC and county appeal of Thurston Superior Court’s ruling on the carbon offset project, and do not wait for final resolution to pursue carbon projects.

• Reinitiate the 10,000-acre carbon offset project, and explore additional carbon projects focused on improved forest management, e.g. extended rotations.

• Include carbon storage and sequestration on forested trust lands as an objective and output in SHC modeling. This should include modeling the economic benefits of carbon offsets and the non-monetary benefits of carbon storage and sequestration.

• Collaborate on CCA funding for projects in the 2025-27 budget cycle.

OPPORTUNITIES

FOR THE NEXT CPL

• Adopt a carbon and climate policy to guide management decisions for both individual timber sales and across state lands as a whole.

• Incorporate carbon accounting in timber sales. Rather than appealing the court decisions in Jefferson and King County, DNR should invest in credible methodologies to include carbon storage and emissions as part of the SEPA process for timber sales.

• Center climate change in the next SHC, including both the impacts of climate change and promoting carbon storage and sequestration as a natural climate solution.

• Adopt climate-smart forest management strategies that enhance carbon storage and sequestration on state lands.

The Sustainable Harvest Calculation (SHC), required by statute, sets timber harvest volume targets on DNR-managed trust lands for the next decade. The SHC sets the foundation of state trust land management. In setting the SHC, policies direct DNR to consider many criteria, including environmental, economic, and social considerations.

DNR is currently scoping both the 2025-2034 Eastern and Western Washington SHCs (the first formal step in preparing environmental impact statements and asking for public comment). Historically, SHC calculations have optimized revenue from timber harvest. This is the first pair of SHCs since CNW v. Franz affirmed DNR’s duty to manage for multiple benefits, and that DNR does not need to optimize revenue without regard for other benefits and impacts. The SHCs are a one-time opportunity to set management priorities for the next decade, including timber harvest goals and climate change mitigation priorities.

EVALUATION

• The SHC was delayed by nearly 1 ½ years due to timber industry litigation. American Forest Resource Council, Lewis County and Skagit County filed litigation in January 2020, challenging DNR’s SHC inventory and modeling. DNR indicated that this litigation required reallocating DNR staff capacity away from the SHC, delaying the process significantly from the original planned completion date in late 2024. The timber industry withdrew the litigation in September 2023. DNR can now re-focus on completing the SHC quickly.

• DNR’s new timeline for the Eastern Washington SHC culminates in final approval from the Board of Natural Resources (BNR) in February 2026. DNR’s original goal was to complete the Final Environmental Impact Statement (FEIS) by spring 2024, with final SHC approval in late 2024. After delays due to timber industry litigation, DNR recently shared a new timeline: FEIS completion by late 2025 and BNR approval by February 2026.

OPPORTUNITIES IN THE YEAR AHEAD

• Provide updates on timeline and anticipated deliverables for the Western Washington SHC.

• Communicate how provisions in the PSF will be addressed in the upcoming SHCs, including watershed protection, fish and wildlife habitat attributes, and social benefits, and carbon sequestration.

• Engage the TAC on SHC model development and communicate with the BNR and the public about the TAC’s recommendations

This is more than a year into the planning decade covered by the SHC, which begins in 2025.

• DNR’s modeling priorities are unclear, and the agency has not demonstrated how it will model for benefits beyond timber volume and net present value. BNR Resolution 1591, approved in December 2022, directed DNR to consider multiple non-timber benefits in the forthcoming SHCs, and to use a multi-objective model to incorporate those benefits, rather than prioritizing net present value. It remains unclear how DNR will reflect those factors in the SHC model. Forest resilience to climate change is a critical goal but has not been addressed by DNR staff publicly nor by BNR since June 2023.

• DNR has not met with the SHC Technical Advisory Committee in 2023 or 2024. The TAC is a multi-stakeholder expert group providing advice to DNR on the SHC. DNR last engaged the TAC in November 2022. DNR intends to convene the TAC in late 2024 to gather input for the draft EIS for the Eastern Washington SHC. The next planned engagement for the Western WA SHC is unclear.

OPPORTUNITIES

FOR THE NEXT CPL

• Complete both SHCs expeditiously and thoroughly, incorporating provisions in the PSF, BNR Resolution 1591, and the mandate affirmed in CNW v. Franz to manage for public benefit.

• Evolve the SHC. Rather than solely prioritizing revenue generation from timber harvest, create a model that emphasizes a range of monetary and non-monetary benefits, including carbon sequestration, extended rotations for ecological and economic benefits, conservation of mature forest to meet HCP goals, biodiversity, watershed benefits, and new economic opportunities such as carbon markets. This will require exploring improved, multi-objective modeling techniques.

In 2024, The Olympic Forest Coalition (OFCO) settled its litigation on the Olympic Experimental State Forest (OESF) 2016 Land Plan (2018-2024), regarding the lack of consistency with the State Lands Habitat Conservation Plan (HCP). The US Fish and Wildlife Service (USFWS) made several findings as a result of this litigation, including a new Biological Opinion and a clarification that DNR must follow the HCP.

The bases for the litigation were DNR timber sales in the OESF that were inconsistent with the HCP and with the 1997-1998 biological opinions, DNR’s failure to provide protections or plans required by the HCP, and new information regarding climate change and barred owls.

USFWS completed and signed a new biological opinion on March 21, 2024. The biological opinion reviews the entire HCP, with a focus on bull trout and northern spotted owls. Settlement correspondence between USFWS and DNR, as well as “Conservation Recommendations,” substantiated concerns raised by OFCO.

USFWS “clarifications” to DNR included the following, many of which are reflected in the “Conservation Recommendations” portion of the new biological opinion:

• The HCP always governs, and the OESF Land Plan cannot reduce its protections. The clarification specified numerous inconsistencies in which HCP protections are controlling:

- HCP requirements for Type 5 stream channel evaluation and protections continue to apply.

- The OESF Land Plan’s “allotted acres” plan cannot reduce HCP protections.

- The OESF Land Plan lists management activities within interior-core buffers, which appear to be inconsistent with the HCP. The HCP indicates that timber harvest within the original function-based interior-core buffers is generally limited to restoration, thinning, and research.

• The HCP allows for flexibility for exterior buffers in the OESF, but also requires monitoring and adaptive management.

• The HCP requires DNR to both maintain and aid restoration of riparian functions. This includes functions associated with wood, shade, peak flows, windthrow, channel and floodplain integrity, sediment regimes, and water quality and quantity.

The USFWS set forth deadlines for DNR to complete planning required by the HCP. DNR committed to the following:

• Finalize a Headwaters Conservation Strategy by March 1, 2026.

• Complete a Comprehensive Road Network Management Plan by March 1, 2026.

• Address salvage harvest procedures with USFWS.

• Develop and submit a formal wind-risk model monitoring and adaptive management program by March 1, 2025.

OFCO requested that the Board of Natural Resources (BNR) direct DNR staff to provide public, regular reports to the BNR regarding DNR’s progress on these commitments. OFCO also requested that draft plans be provided to the public for comment prior to submission to USFWS.

OPPORTUNITIES

Among the above agreements and milestones established by the litigation, critical opportunities for DNR to act on in the short term include:

• DNR must adjust the OESF Land Plan to fulfill HCP requirements. This is consistent with USFWS’s clarification that the conditions in the HCP are controlling.

• USFWS and DNR agreed that DNR will finalize the headwaters conservation plan within two years. DNR can expedite this process and prioritize the conservation plan immediately.

• USFWS and DNR agreed that DNR would complete and submit a final windthrow probability model to USFWS by March 1, 2025. In the interim, DNR must stop using its current model which was found to reduce riparian, exterior and interior conservation buffers to, in some cases, less than 1% of what is required by the HCP.

• DNR should work with USFWS to study and integrate barred owl control to allow for recovery of northern spotted owls.

This section addresses topics related to the 9.3 million acres of private forestlands (non-federal, nonTribal) and 2 million acres of state lands that are subject to the DNR-administered Forest Practices Habitat Conservation Plan. These forests are governed by Forest Practices regulations which are developed and adopted via a governmental program called the Adaptive Management Program (AMP).

OVERVIEW OF FOREST PRACTICES

ADAPTIVE MANAGEMENT

PROGRAM

The basis of the Adaptive Management Program (AMP) was established in 1987 when the forest community achieved a significant milestone with the creation of the landmark Timber Fish and Wildlife (TFW) Agreement. 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 rules 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 non-federal 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.”

The AMP consists 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 leadership is essential for the AMP process to function effectively.

DNR is responsible for administering the Adaptive Management Program (AMP), which was created to cooperatively develop and update state forest practices. DNR plays a crucial facilitation and program management role among diverse stakeholders and managers. In recent years, relationships have become strained, past agreements have become points of disagreement, and progress is slow.

Recent efforts to address these challenges include a 2021 State Auditor's Office (SAO) report with 11 recommendations for program reform, and a conflict transformation process by an external facilitator. The conflict transformation effort ended after two years when the facilitator, for the first time in their career, resigned citing inadequate conditions to achieve success. The January 2021 SAO audit highlighted dysfunction and the risk of not meeting federal requirements. DNR responded with an SAO Response Plan, approved by the FPB in May 2021. In addition, the CPL held a series of TFW Principals meetings in 2021 and 2022. This process stalled due to unclear objectives, with the last meeting occurring in July 2022.

In DNR’s role as a participant caucus within AMP, the agency has taken actions which have further strained relationships. For example, DNR voted against sister agencies on Type Np (non-fish bearing, perennial) stream alternatives, hindering cooperation and long-delayed rulemaking, and enabling litigation threats from landowners.

EVALUATION

• Significant strides have been made towards completion of SAO recommendations. All but three of the recommendations have been completed, with two of those remaining in progress and one delayed. DNR has prioritized moving SAO recommendations through the AMP.

• DNR has continued to take a passive approach to industrial landowner litigation threats. DNR had opportunities to rebuke industry attempts to derail rulemaking processes, but has chosen not to reaffirm AMP norms and commitments.

• Structured Decision Making (SDM) workshop: Participants from all levels of the AMP attended a 2-day workshop to learn the SDM process. SDM is a standardized way to make decisions by combining science, values, and input from participants.

• With the approval of the TFW Policy Committee, AMP has hired facilitators to support piloting SDM in the decision-making process. The success of this pilot and the extent of future changes to the AMP decision-making process is uncertain.

• Creation of a TFW Policy Manual: TFW Policy has approved a handbook outlining current practices and program functioning. It aims to improve consistency across the program, promoting alignment with AMP goals and operations.

• DNR did not provide the FPB with comprehensive information, history, or framing for the August 2024 decision about Water Typing rulemaking, resulting in a problematic outcome.

• Budget Shortfall: The AMP faces a $3.8 million shortfall for the next biennium, which is by far the largest in the history of the program. This budget shortfall threatens the AMP’s ability to proceed with planned programming, and to support stakeholder participation.

• Environmental Justice and Tribal Sovereignty: DNR has generally chosen to take a mediator role in the program, rather than taking opportunities to affirm and elevate Tribal rights or public interests.

OPPORTUNITIES IN THE YEAR AHEAD

• Address the AMP funding shortfall. DNR has an opportunity to bring together AMP parties and interests to unify behind securing $3.8 million to address the current funding shortfall.

• Implement clear priorities and oversight to prevent future budget overruns. As the administrator, DNR can orient the FPB towards reevaluating AMP priorities to ensure that all studies fall within the general AMP budget and objectives.

• Help the FPB understand the implications of recent decisions on Water Typing, and identify a credible path forward.

• Ensure that incorporating SDM into the AMP does not undo or undermine previous substantive agreements. Programmatic changes can either improve or harm decision-making. DNR should carefully consider the long-term impacts and support changes that enhance transparent and efficient, science-based decision-making.

OPPORTUNITIES FOR THE NEXT CPL

• Assert DNR leadership by emphasizing and modeling expectations for the AMP, including collaboration, adherence to past agreements, following scientific guidelines, and complying with legal requirements like the antidegradation standard. DNR must reaffirm the importance of updating forest practices through the AMP process rather than pursuing litigation. If DNR cannot lead the program effectively, it will be necessary to reconsider the value of dedicating time and resources to it.

• If DNR reengages Principals to reaffirm program purpose, it will be critical to provide clarity on the purpose and role of meetings.

DNR oversees a water typing system to classify streams and water bodies as fish habitat or non-fish habitat. Accurate classification is crucial, because it determines logging requirements for forested buffers along streams. Buffers provide shade and filtration, maintaining cool, clean water for species like salmon. For example, logging may be prohibited within 75 feet of the banks of a fish-bearing stream.

Despite extensive efforts, the Adaptive Management Program (AMP) has not established a permanent water typing rule. Instead, for over 25 years, the state has been operating under an outdated “interim rule.”

The rulemaking effort has experienced numerous substantial delays. These have included delays in 2022, when the CPL’s designee on the FPB unilaterally canceled critical water typing meetings leading to a decision on a new water typing system. The cancellation was explained by the hope that a consensus proposal among all stakeholders was possible— contrary to the experience of the prior six years. This resulted in another 6-month delay before the FPB directed rulemaking to move forward again with the same proposals.

EVALUATION

• DNR convened an informal water typing workgroup to gather AMP stakeholder feedback on incorporating the FPB-approved language and rule alternatives into an existing rule. After numerous iterations, DNR concluded they had received adequate input and closed the workgroup pending the FPB’s final decision on which alternative to move forward.

• DNR contracted Four Peaks to develop spatial analysis as a foundation for the economic analysis that is part of rulemaking. The initial draft analyses contained numerous, significant substantive errors. In March, DNR and Four Peaks presented the spatial analysis methodology to stakeholders. The presentation highlighted model and technological limitations, as well as errors in the methodology.

• DNR worked with Four Peaks and oversaw development of the final spatial analysis report. While the final report corrected some of the identified errors and acknowledged the limitations highlighted by stakeholders, unresolved issues introduced confusion in the rulemaking process.

• DNR staff provided insufficient information for the FPB to make an informed decision about which water typing alternative to incorporate into the final rule. DNR presented the FPB with a number of options derived from the Four Peaks report, which was developed for economic analysis. However, this report was not shared alongside the more in-depth geospatial model created by Terrainworks earlier in the process. Substantial AMP resources, time, and stakeholder input were devoted to development of the Terrainworks model. Its purpose was to approximate how well water typing options perform in identifying fish habitat and minimizing electrofishing. The lack of reliability of the Four Peaks model and the lack of clarity over the purpose of each model generated misperceptions.

• Lack of DNR leadership resulted in removal of core water typing components from the water typing rule. The FPB met on August 28, 2024 to

decide which water typing alternatives should be included in the final draft rule. In a surprising turn of events, the FPB voted to remove all alternatives from the draft rule. The FPB directed DNR to instead incorporate these provisions into non-binding Board Manual guidance. This undermines eight years of discussion, research, and negotiations towards a permanent rule that protects fish habitat. DNR contributed to this outcome by failing to promote a shared FPB understanding of the purpose and history of this process, the performance of the two alternatives, and the consequences of this action.

• Environmental Justice and Tribal Sovereignty: To date, DNR has failed to meaningfully incorporate tribal concerns regarding salmon recovery. The Westside Tribes caucus identified a significant error in how their water typing proposal was analyzed in the cost-benefit analysis for water typing. It remains unclear why substantive elements of the proposal were removed. DNR did not correct the error once it was discovered. As a result, the Westside Tribes' alternative was likely misrepresented to the FPB, significantly influencing the water typing discussions.

TIMELINE FOR WATER TYPING

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

1999

1996

The FPB adopts an emergency water typing system.

2005

DNR attempted to develop a water typing model, but finds the model too inaccurate and as a result, retains the interim water typing rule.

OPPORTUNITIES IN THE YEAR AHEAD

• Guide the FPB down a new path to adoption of a final water typing rule that complies with the state’s HCP commitments to the federal government and respects Tribal treaty rights. The current path established in the August 2024 FPB meeting risks violating both the HCP and Tribal treaty rights. DNR must proactively help the FPB understand these shortcomings and take action to resolve them.

• Reorient the FPB with additional, comprehensive information to better inform rulemaking decisions, including:

- A comprehensive summary of analysis to date on water typing work within the AMP.

- The requirement to establish a permanent water typing rule that reduces electrofishing.

- The implications of substantially weakening the water typing rule by moving rule elements into Board Manual as guidance.

- The intended purpose and limitations of the Four Peaks analysis.

• Fix the Four Peaks models to provide an accurate basis of analysis for rulemaking. DNR removed a crucial element of the Westside Tribes' proposal. The analysis will need to be redone for any accurate future analyses.

Conservation Caucus drafts a petition for rulemaking which prompts the Policy Committee to begin addressing a permanent water typing rule.

2011

FPB assumes water typing rule development responsibility.

2017

2016

October

Policy Committee recommends to the FPB creation of a new water typing system.

The AFF workgroup completes its work and recommendations were accepted for additional analysis.

2021

FPB votes to remove the AFF and associated elements from the draft rule language, placing it into Board Manual guidance, and directs DNR to continue rulemaking.

2024

2022

FPB directs DNR to proceed with rulemaking for water typing.

2019 June

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.

OPPORTUNITIES FOR THE NEXT CPL

• Direct staff to provide accurate and complete information to inform FPB decision making. DNR staff did not serve as active administrators of the AMP in recent FPB meetings. This allowed the protracted rulemaking process to proceed without a shared basis of knowledge among newer FPB members, with highly problematic results. Moving forward, DNR must be a steward of institutional memory and HCP commitments.

• Bring the long water typing process to a close, establishing a much-needed permanent water typing rule that adequately protects fish habitat and minimizes electrofishing. This is necessary to achieve the AMP goal “restore and maintain riparian habitat on non-federal forestlands to support a harvestable supply of fish.” The current path of the water typing component remaining in rule will not achieve this.

• Once the new water typing rule is adopted, DNR must facilitate a smooth rollout with landowners. DNR will play a critical role in providing training and support to all parties utilizing the new rule to ensure its accurate and effective implementation. This will require providing guidance materials, training, and staff technical support for small forest landowners.

The Adaptive Management Program (AMP) evaluates the state's forest practices rules and ensures state compliance with the federal Clean Water Act (CWA). CWA requirements include maintaining the cool water temperatures vital for water quality and fish habitats. A continuous effort over 20 years has involved testing and developing rules to ensure logging maintains cool water in non-fish, perennial (Type Np) streams.

In 1999, the Department of Ecology (DOE) granted CWA Assurances, which state that effective forest practice rules are an alternate method to achieve CWA requirements. In practice, landowners may meet forest practice rules while still exceeding CWA standards. DOE granted the Assurances with the expectation that the AMP would study the impacts of logging on stream temperature to determine if CWA standards are achieved, and adjust forest practices rules accordingly.

The original CWA Assurances assumed AMP would test and develop protective rules within 10 years. By November 2021, DOE had extended the Assurances three times, providing 14 additional years for AMP to develop a rule. Studies on the impact of logging on stream temperature began in 2005 and concluded in 2017.

In 2022, the Policy committee submitted recommendations to the Forest Practices Board (FPB) for new Type Np riparian buffers to meet CWA standards. Due to lack of consensus, recommendations were delivered as majority and minority proposals. The majority proposal was co-developed by DOE with Tribes, conservation groups, and state agencies. DOE stated that only the majority proposal would meet CWA standards.

However, a week before the November 2022 FPB vote, DNR unexpectedly withdrew support from the majority proposal. DNR joined landowners and counties and voted to advance both the DOE-led and landowner-led proposals to rulemaking. That vote failed. Only the majority proposal advanced—without DNR support. After the industrial timber caucus threatened litigation, DNR called for a revote in August 2023. The revote yielded the same outcome: advancing only the majority proposal to rulemaking.

TIMELINE FOR CLEAN WATER ACT ASSURANCES AND STREAM TEMPERATURE STUDIES

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.

EVALUATION

• Np Workgroup convened to develop new rule. A stakeholder workgroup was created to draft rule language for riparian buffers on Type Np streams. DNR struggled to keep the process clear. Stakeholder input was incorporated inconsistently.

• Draft rule language submitted to the FPB. After concluding the Np Workgroup, DNR finalized draft language internally with regular updates to the FPB. This has improved transparency and accountability.

• DNR's Type Np rulemaking analysis relies on the same unrefined spatial analysis methodology the agency is using for water typing rulemaking. The remote sensing technology used to create the spatial analysis has inherent resolution limitations. Significant methodology errors also persist. This will impact the economic analysis and subsequent rulemaking.

• DNR planned to move Type Np rulemaking forward sequentially with water typing. DNR has committed to advancing as much of Np rulemaking as possible concurrently with water typing rulemaking. Since the water typing rule making has taken a dramatic turn from the trajectory of the past eight years, it is unclear if DNR will be able to maintain the projected Np rulemaking schedule.

• Environmental Justice and Tribal Sovereignty: Clean water is essential to fish health and to the general public, particularly populations that are disproportionately impacted by lower water quality, and Tribes for which salmon and other fish are a cultural resource. In rulemaking analysis, there has not yet been an indication that DNR is considering values beyond narrow legal requirements.

OPPORTUNITIES IN THE YEAR AHEAD

• Ensure accurate information and modeling to guide FPB decision making on Type Np. DNR’s intention to also use the Four Peaks model for Type Np rulemaking analysis raises concerns about the impact of model inaccuracies on Type Np.

• Assume a leadership role in guiding the FPB through the rulemaking process to ensure that timelines are maintained. DNR’s current timeline anticipates the conclusion of Type Np rulemaking in November 2026. DNR should look for opportunities to streamline the process and commit additional resources as needed.

• Adopt a final Type Np rule consistent with the majority proposal currently under analysis.

Initial results of stream temperature studies are presented to the policy committee, demonstrating temperature increases due to existing rules.

2017

A stream temperature technical workgroup forms. CWA Assurances are extended for two years to allow studies to be completed and a rule proposal developed.

2019

2018

Based on temperature studies, the policy committee submits a recommendation to the FPB that “action was warranted” and “rulemaking will be needed.”

OPPORTUNITIES FOR THE NEXT CPL

• Be prepared to defend the final Type Np rule and the underlying science in court. The landowner litigation threats challenging the validity of the CWA standards have not formally concluded.

• Mend relationships with Ecology and WDFW to ensure the AMP functions smoothly, while also setting clear expectations around agency expertise and collaboration.

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

Nov. 2021-Oct. 2022

May 2021

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

Dec. 2021

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

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

Aug. 2023

FPB votes to advance only the majority proposal.

Nov. 2022

Mar. 2023

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

This section addresses management of the 2.6 million acres of stateowned aquatic lands: the navigable lakes, rivers, streams, and marine waters DNR manages for public use and access, environmental protection, and income generation.

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 habitat restoration and through efforts such as the Derelict Vessel Removal Program. In addition, DNR must engage with other state agencies, Tribal governments, and non-governmental organizations to prevent further harm and to restore habitat that supports salmon, other wildlife, and our cultural identity

EVALUATION

• Derelict vessels making progress: DNR continues to grow the Derelict Vessel Removal Program, which has removed more than 2,600 vessels. The program is making good use of the Watercraft Excise Tax and vessel registration fees to fund the $10.3 million work in this budget biennium. The Vessel Turn-In Program prevents boats from becoming derelict vessels in the first place by giving owners options at no cost to the owner. Strong demand at partner events indicates that more funding means more prevention.

• Snohomish Watershed Resilience Action Plan increases capacity: DNR launched the Snohomish Watershed Resilience Action Plan (WRAP) in 2022 to accelerate salmon recovery and to promote watershed resilience. Five employees are now working with Tribes, agencies, and local salmon recovery organizations. The added capacity has designed more recovery projects, partnered on debris and piling cleanup on tidelands, leveraged a modest initial investment of $250,000 into millions of dollars in state and federal grant funding, and piloted new programs such as sourcing large woody debris from DNR lands for recovery projects. The work has gained momentum and is picking up the pace of recovery in the Snohomish basin.

OPPORTUNITIES IN THE YEAR AHEAD

• Reducing impacts from discarded tires: In 2023, DNR completed mapping of tire reefs –thousands of automobile tires that were placed in Puget Sound in the 1970s and the 1980s. Originally intended to increase fishing habitat, these bundles of tires are breaking apart, releasing polypropylene line, and the tires themselves are breaking down and releasing toxic chemicals into sensitive marine habitats. Now that the mapping is completed, DNR needs to work with WDFW and other agencies to get them out of places like Saltwater State Park, Solo Point, Burfoot County Park, and Frye Cove County Park in Puget Sound.

OPPORTUNITIES FOR THE NEXT CPL

• Deschutes Estuary restoration gains momentum: DNR owns the aquatic lands beneath Capitol Lake, an artificial impoundment of the Deschutes Estuary. Recently the Squaxin Island Tribe secured $6.4 million in federal funding to remove the dam and help recover salmon habitat. Estuary restoration will require DNR to be a partner in recovery and to use its role on the State Capitol Campus Committee to expedite next steps toward recovery of the southernmost region of the Salish Sea. We recommend that DNR continue engaging directly with the Squaxin Island Tribe. Throughout state-owned aquatic lands, DNR should explore carbon sequestration in estuaries and tidelands.

CLEAN ENERGY

The section addresses DNR's Clean Energy Program, which explores clean energy project development on state trust lands.

Washington’s public lands have the potential to play a role in achieving our state’s ambitious clean energy goals, if balanced with protections for the environment, community needs, and respect for Tribal sovereignty. However, this potential remains largely untapped.

DNR’s Strategic Plan includes the strategy “generate new sources of trust revenue by increasing opportunities for renewable energy production on state lands,” and highlights collaboration and consultation with Tribes in advancing renewable energy.

EVALUATION

• Progress is uncertain on DNR’s goal of 1,000 MW clean energy generation. Statewide, approximately 20 leases on DNR lands support wind plants that can generate up to 215 MW of electricity and one 70 MW solar photovoltaic plant. In addition to solar and wind, DNR has invited developer proposals for geothermal, biomass, energy storage, and electric vehicle charging infrastructure. However, no new clean energy projects have been completed nor approved during the past year. An existing wind plant in Central WA is exploring a renovation, and several potential solar and wind projects in Central and Eastern WA are on hold or under consideration.

• Rollout of a new mapping tool highlights challenges to clean energy development on state lands. The agency launched a public Clean Energy Parcel Screening Tool in 2023. This map was created to aid developers in considering whether specific DNR land parcels may be good candidates for clean energy projects. Generally, only a small portion of a given clean energy project’s footprint would be on DNR land, making the agency’s engagement in these projects more complicated. There have been some refinements of the map based on Tribal consultation and public feedback. However, this process has largely been reactive, rather than proactive. So far, no projects have moved forward as a result of the screening tool.

• Environmental Justice and Tribal Sovereignty: DNR made progress in the past year in making clean energy leasing more responsive to community concerns. The agency has updated its policies to prioritize a more robust public process for land-use decisions. This is part of an effort to adopt a more deliberate approach to clean energy development that protects the environment, benefits local communities, and respects Tribal sovereignty. One significant change in the last year is the decision to consider and sign new leases only after the lead agencies that conduct State Environmental Policy Act and National Environmental Policy Act reviews issue their determinations for a proposed project. This allows DNR to learn more from the public participation and input during each permitting process. The agency has also been focusing on exploratory land use licenses that do not allow infrastructure development or land disturbance.

OPPORTUNITIES IN THE YEAR AHEAD

• DNR staff currently participate in the Clean Energy Siting Council and are actively involved in considering recommendations for improved siting processes. There may be opportunities for DNR staff to engage with the development of a statewide Build Ready Clean Energy program or clean energy preferred zone designation and incentives.

OPPORTUNITIES FOR THE

NEXT CPL

• In addition to helping meet our climate targets, clean energy leases have the potential to diversify revenue generation for state beneficiaries. Currently, leases generate about $1 million each year. Responsible increases to clean energy production could lead to increased and reliable revenue. It is critical that DNR decision-making about leasing considers analysis of potential benefits to trust beneficiaries alongside careful analysis of benefits and impacts to the general public.

• Community Benefits Agreements (CBAs): CBAs are tools used in energy project development to ensure that benefits promised to communities, such as environmental protections and jobs, are delivered. DNR encourages project developers to complete CBAs but does not require them to do so. The agency could pursue a directive to require CBAs, similar to Commissioner Franz’s directive requiring project labor agreements for clean energy projects on department-managed lands.

• Tribal Sovereignty: The 29 federally recognized Tribes of Washington are sovereign Tribal nations. DNR has a responsibility to conduct government-to-government consultation with Tribes on clean energy project development and potential impacts to Treaty Rights, traditional cultural properties, usual and accustomed areas, Tribal lands, and priorities identified by Tribes. This foundational responsibility must be upheld as DNR continues to develop its approach to clean energy development on public lands. This includes how the agency articulates the impacts of clean energy projects and prioritizes lands for leasing opportunities. One strategy to minimize risk of impact to cultural resources is to preferentially explore energy development opportunities on land that has previously been developed.

2024 was a short legislative session, typically a quieter legislative year. During this session, the commissioner and DNR supported the following important environmental priorities.

Trust Land Transfer (TLT) ($10.8 million, Natural Climate Solutions Account): Funds will support conservation of ecologically important forested trust lands and acquisition of replacement properties for the trust. The nine funded projects encompass 2,200 acres of forestland across nine different counties. This funding builds on the passage of HB 1460 in 2023, which updated the TLT program.

Wildfire Funding (HB 1168): DNR secured full funding for HB 1168 for the remainder of the 202325 biennium at the $125 million/biennium level specified in the bill. This funding supports wildfire response, forest restoration, and community resilience.

Wildfire Reforestation and Grants ($10 million, Natural Climate Solutions Account): DNR received $7.5 million for post-wildfire reforestation on DNR lands and $2.5 million to create a grant program for post-wildfire reforestation on lands owned by Tribes, nonprofits, private landowners, local governments, and other state agencies.

Prescribed Fire Funding ($10 million, Natural Climate Solutions Account): DNR secured $10 million “solely for forest treatments in areas where they have the greatest potential to prevent wildfires and protect air quality.” This funding supports prescribed fire treatments that have ecological and community health benefits.

Kelp, Eelgrass, and Blue Carbon: DNR continues to make progress stewarding kelp and eelgrass which help absorb marine (blue) carbon. This includes monitoring through programs such as the Acidification Nearshore Monitoring Network, collaborating on eelgrass health with Puget Sound Vital Sign, and co-developing strategies to conserve and restore at least 10,000 acres of kelp and eelgrass extending from Grays Harbor to South Puget Sound to the Strait of Juan de Fuca.

Statewide Climate Resilience Strategy: In 2023, the state Legislature passed HB 1170, directing state agencies to collaborate in updating the state’s integrated climate change response strategy. This is intended to enable the state to prepare for, address, and adapt to the impacts of climate change. DNR is participating in this process, which is led by Department of Ecology. A draft strategy was released for public comment in June 2024. Post-fire recovery and forest health are the proposed DNR-led actions in the plan.

Urban Forestry: DNR distributed more than $8 million to 55 cities, counties, Tribes, nonprofits, and other organizations through the 2024 Urban and Community Forestry Grant Program. More than 120 entities applied for funding, requesting a total of $20 million for projects. DNR also continued growing the Tree Equity Collaborative, a joint partnership with American Forests, which was launched in 2023. The collaborative includes more than 65 members, working towards expanding tree canopy cover in urban areas across the state. DNR held an in-person Learning Lab in Tacoma this spring and will host another in Spokane this fall.

Wildfire Response: In DNR’s role as the state’s wildfire fighting force, the agency responds to wildfires across 12 million acres of private and state-owned forestlands. According to DNR’s Wildfire Intel Dashboard, DNR had responded to 1,295 fires affecting 106,483 acres as of September 6, 2024.

Affordable Housing on State Lands:

Commissioner Franz’s Commissioner’s Order 202407, issued in March 2024, directs DNR to identify appropriate affordable housing sites and partnerships to leverage transition lands: “areas that DNR currently manages for natural resource production that could yield a higher return from conversion to a different land use.” Housing lies outside DNR’s historic scope and competency, and such an initiative requires strong policy sideboards to ensure that lands with ecological and cultural value are not lost to development. To be effective, DNR would need to conduct clear and transparent evaluation of ecological, social, and economic value of land use alternatives. DNR must also ensure any proposed housing matches local comprehensive plans and the needs of community members.

Bioeconomy Playbook: This year, DNR is developing a “strategic playbook” describing DNR’s bioeconomy efforts, setting a shared vision for DNR’s role, and identifying challenges and opportunities for advancing the state's bioeconomy. Although DNR does not currently have a public definition, bioeconomy is generally defined as a sustainable and renewable circular economy utilizing biological resources.

Carbon and Forest Management and Work Group:

In 2023, the state Legislature appropriated $2.5 million of Natural Climate Solutions funds and directed DNR to establish a stakeholder work group to address “conservation and management of older, carbon dense, structurally complex forest stands located on lands managed by the department.” The work group has convened seven times during 2024. It has made progress on forest management and wood supply scenarios that will be used to model sequestration and storage of carbon in forests and wood products from forested state trust lands. The work group will deliver recommendations to the Legislature in December 2025.

Ecosystem Services Asset Plan and Work Group: In 2023, the state Legislature appropriated $1.5 million of Natural Climate Solutions funds for DNR to conduct an ecosystem services asset inventory and to develop an ecosystem services asset plan for DNR-managed lands. The proviso also established a work group to explore “how state lands under the department's jurisdiction can be monetized, including ecosystem services credits . . . to reduce the overall greenhouse emissions, or increase greenhouse gas sequestration and storage.” The work group convened in April 2024. Resulting recommendations are an opportunity to enhance ecosystem services and to diversify revenue sources on state trust lands.

Outdoor Access and Responsible Recreation

(OARR) Strategic Plan: DNR is developing a statewide road map to guide future landscape-level planning for recreation while ensuring natural, cultural, and Tribal resources are respected and protected. DNR plans to release a final OARR Strategic Plan by the end of 2024. Tribes and the public will have an opportunity to comment on a draft plan before a final version is released.

Trust Land Transfer (TLT) Program: DNR has screened applications for the next round of TLT, which will transfer ecologically significant parcels to permanent conservation status. The prioritized list of applicants includes eight projects. Six of these applications were advanced by Tribal governments, enabling return of ecologically and culturally important land to Tribes. The agency is expected to submit a funding request to the legislature after BNR approval in September 2024. We intend to monitor which parcels are nominated for conservation, and how the DNR balances ecological, social, and economic considerations as it decides which parcels to prioritize.

In anticipation of a new Commissioner of Public Lands taking office in January 2025, we have developed a vision for how an ambitious new leader can transform and scale up the agency’s work Evolving DNR’s work is necessary to address the urgent challenges that our state faces. This vision is grounded in where DNR’s work stands today, following the eight years Hilary Franz has led the agency. This progress of the agency’s work during this time is reflected in the seven annual reports we have published since Commissioner Franz took office in 2017.

Statewide Forestry Issues: Build on the new path forged on wildfire and harness forests and natural lands as a climate solution

The next CPL is well-positioned to expand and refine the wildfire work that has been a core focus during Commissioner Franz’s time in office. Commissioner Franz’s first term began with the publication of the 20-Year Forest Health Strategic Plan. DNR has advanced hundreds of thousands of acres of forest health treatments. More work is needed by the next CPL to prioritize the most effective forest health treatments, particularly on state lands: broadcast burning and pre-commercial thinning. DNR restarted its prescribed fire program after a 20-year hiatus, though significant additional agency support is needed for this program to reach its full potential.

The landmark passage of the wildfire funding bill in 2021 provided resources that, to date, have been dedicated predominantly to suppression. Greater funding is needed for other important aspects of wildfire response. The next CPL will also need to secure continued funding beyond the eight years committed by the wildfire funding bill, ending in 2029.

Lastly, a new program focused on resilience to wildfire is beginning to demonstrate progress, after a bumpy start. Serving the needs of Washington’s communities will require learning from DNR’s experience in this nascent program and expanding funding dedicated to community-identified priorities.

Moving forward, the next CPL has the opportunity to build on DNR’s wildfire progress:

• Continue to build on scientific analysis and reporting on forest health treatments, including ensuring that DNR is implementing ecologically informed treatments in the right locations.

• Develop an approach to forest health work in Western Washington.

• Invest more in community-based solutions for wildfire resilience, and approach funding community-based projects as investments in capacity that provide “seed funding” that will lead to systems-level change.

• Collaborate with state and federal agencies to implement stated commitments to expanding beneficial fire.

• Advance comprehensive legislation to enable expansion of beneficial fire, including staff capacity, addressing liability, and removing barriers to cultural burning.

A statewide approach to carbon sequestration and storage in natural and working lands is an open arena for the next CPL to shape. The new commissioner must define a targeted role for DNR in promoting natural climate solutions in Washington. This next step can draw from the series of isolated

DNR efforts and analysis over the last eight years (e.g. participating in the Climate Alliance Working Lands Group, the Carbon Sequestration Advisory Group, and the Carbon Playbook). DNR’s approach to carbon sequestration and forestry must include clear messaging about distinguishing climate-smart wood products, following the innovation and leadership in our region by the architecture, engineering, and construction community as well as environmental NGOs. Developing a comprehensive DNR approach is critical to achieve the state’s greenhouse gas emission goals. Given DNR’s core competency in forestry, this role is a natural fit for DNR.

The next CPL can initiate a strong program of work in this area, simultaneously supporting our state’s climate goals and forest landowners:

• Create a Natural and Working Lands Carbon Sequestration Strategy in collaboration with other state agencies.

• Develop DNR programs and strategies to promote natural climate solutions in forest ecosystems, including conservation and improved forest management strategies, such as extended rotations.

• Explore financial tools and develop in-house technical capacity to help private and Tribal landowners transition to climate-smart practices and to explore carbon sequestration projects.

• Leverage Climate Commitment Act funding for projects that use verifiable and innovative approaches to enhance carbon sequestration and storage.

State Trust Forest Lands: Evolve management of our state forests to integrate management for “all the people” alongside trust beneficiaries

The last several years have brought a sea change in public dialogue about our public state lands. Following a groundswell of grassroots engagement and several important court decisions, the next CPL will be charged with evolving management of our state trust lands to explicitly integrate public benefit alongside revenue generation for beneficiaries. The state is ready for conversations about reflecting the public in DNR and BNR decisions, decoupling variable and insufficient logging revenue from critical school funding, and enhancing ecosystem services on state lands. Doing so is essential to maintaining the social license of DNR’s logging operations.

In 2018, we first included an item in the report about DNR’s constitutional obligations on state trust lands. We urged a “more holistic approach that uses less

environmentally impactful forestry would create more jobs, provide new opportunities for sustainable revenue, and better meet the constitutional requirement to manage these lands for the public.” In the intervening six years, DNR’s management practices have not evolved. What has changed is that in 2022, the State Supreme Court provided clarity that DNR has a legal duty to manage for public benefit. On state lands, all other outcomes flow from this central issue: how DNR internalizes this mandate and acts on its obligation to the people of Washington.

The next CPL has a wide-open opportunity—and duty—to balance the multiple legal obligations woven into state lands management. Clear direction from the CPL will be critical to evolving long-established policies and management actions, from the top of the agency down to individual timber sales. Progress on climate, mature forests, endangered species, public safety, and rural livelihoods relies on setting goals for ecological and social outcomes, in addition to timber harvest volume goals. By doing so, state lands can become a model of ecological forest management in Washington. Fortunately, the next CPL will have new tools available to support this transition, including carbon offset projects, CCA revenue, and updated forest stewardship certification standards.

DNR must be an innovator in managing state trust lands, demonstrating how forest managers can achieve triple bottom line outcomes through climate-smart forestry:

• Update DNR’s foundational Policy for Sustainable Forests to reflect DNR’s mandate to manage for non-monetary public benefit, including adding a carbon and climate policy.

• Pause timber sales containing mature forests until a mature forest strategy is developed, and work to grow the mature, structurally complex forests of the future.

• Set decadal timber harvest levels in Eastern and Western Washington Sustainable Harvest Calculations that center climate change, and optimize for non-monetary benefits alongside net present value.

• Establish new outreach and consultation strategies to improve engagement with the general public and Tribal nations, including a formalized process to gather input about desired public benefit and cultural protections to guide management strategies.

• Quantify carbon and ecosystem service impacts of state lands management actions to understand public benefit.

• Adopt climate-smart forest management strategies that enhance carbon storage and sequestration, including extended harvest rotations.

• Reinitiate DNR’s proposed carbon offset project and explore additional carbon offset projects.

Private Lands: Finalize strong rules to protect water quality and fish habitat, and demonstrate the viability of the Adaptive Management Program

Since before Commissioner Franz took office, the Adaptive Management Program (AMP) and Forest Practices Board (FPB) have been focused on two potential changes to forest practices: a permanent water typing rule and adjusting Type Np buffers to regulate stream temperature. Although the rulemaking process is underway for both, neither will reach completion before a new CPL takes office. Further, the water typing rule is now on a problematic path that will not meet the State’s commitments. The next CPL will be responsible for expeditiously guiding the Forest Practices board to adopt final rules that protect water quality and fish habitat.

In 2018, the AMP delivered a decade-long study, finding that riparian buffers on Type Np streams are not adequately maintaining cool stream temperatures. A series of delays pushed the original 2022 timeline for rule completion to a current projected completion date of late 2026.

Water typing rulemaking was reinitiated early in Commissioner Franz's first term after languishing for 10 years. At this point, a new rule was expected in 2019. DNR currently projects a completion date of 2025, with a strong likelihood of further delay. Meanwhile, the state is using an interim rule that does not provide adequate protection.

Timelines for both rules have been grossly misaligned with the urgency of these issues, and significant risk remains that final rules will neither adequately protect fish habitat nor water quality. Delay has largely been due timber industry tactics and threats of litigation, as well as DNR’s actions as program administrator.

We hope to see the next CPL approach the AMP with a firm commitment to science and partnership. DNR must align with Tribes and sister agencies on rule alternatives that AMP science demonstrates would come closest to achieving program objectives. Partnership with, and deference to, these caucuses is critical to achieving good outcomes. DNR must also commit to strong leadership of AMP and embrace its role as a regulator, even when doing so may be unpopular.

Successfully concluding Type Np and water typing rulemaking in the near term would demonstrate that the AMP can function as intended. Since 2006, the AMP has only produced two science-based rule revisions. Following years of dysfunction and slow progress, confidence is low that the AMP can fulfill its purpose. After Type N and water typing rulemaking, the next CPL will be tasked with guiding the AMP through future challenging projects. This includes exploring new rules for logging on steep and unstable slopes, to prevent catastrophic landslides like the 2014 Oso landslide.

To fulfill the promise of AMP as a process for establishing science-based forest practices, the next CPL must:

• Assert DNR leadership by emphasizing and modeling expectations for the AMP, including collaboration, adherence to past agreements, following scientific guidelines, and complying with legal requirements.

• Reorient the water typing rulemaking process and bring it to conclusion, establishing a much-needed permanent water typing rule that adequately protects fish habitat and minimizes electrofishing.

• Facilitate a smooth rollout of the future water typing rule by providing guidance materials, training, and staff technical support for small forest landowners.

• Complete Type Np rulemaking and be prepared to defend the final Type Np rule and the underlying science in court.

• Mend relationships with Ecology and WDFW to ensure the AMP functions smoothly.

Aquatics: Maintain progress on protecting and restoring aquatic habitat

Commissioner Franz inherited an Aquatics Division with a strong sense of direction and work plan. As the Commissioner focused on other areas of DNR early in her tenure, attention to Aquatics languished. The next CPL can make sure staff and managers are supported and stewarding aquatic resources for future generations. Both seasoned work such as monitoring programs and new directions like the Snohomish Basin approach will need support and attention from the next commissioner. Salmon and people depend on the aquatic natural resources that DNR stewards to survive and thrive.

Clean Energy: Promote projects that protect the environment, benefit local communities, and respect Tribal sovereignty

Clean energy development is a newer area of focus for DNR. If done thoughtfully, it can diversify

revenue for trust beneficiaries and contribute to state clean energy goals. This work is in an early stage, and DNR continues to refine its approach to clean energy development— particularly with regards to consultation with Tribal governments and engagement with local communities. Across the state, ecologically and culturally appropriate clean energy siting remains a challenge. The next CPL has an opportunity to shape DNR’s approach to clean energy on public lands, demonstrating best practices for the state. This should include only exploring projects that respect Tribal sovereignty and cultural resources, are in ecologically appropriate locations, are responsive to community concerns, and provide local community benefit.

Environmental Justice: Incorporate justice across agency actions and divisions

Commissioner Franz created an Office of Environmental Justice, a needed and critical step. This marked the first time dedicated staff capacity was hired to advance equity and environmental justice in the agency. The start of this work is encouraging, and expansive opportunities lie ahead for the next CPL to grow the office and to integrate environmental justice throughout DNR programs and decisions. The next CPL has the opportunity to support integration of environmental justice across DNR job descriptions and the priorities of agency divisions. To support this expansion, the next CPL must champion expansion of staff capacity and resources dedicated to the Office of Environmental Justice and within divisions.

Tribal Relations: Building internal capacity to partner with Tribal nations

With each passing year, it becomes more urgent that state agencies prioritize working with Tribes. To do so effectively, agencies must expand internal capacity for Tribal engagement. DNR's Office of Tribal Relations has built momentum in recent years. However, the scope of the office’s work is limited by the small number of staff working on a broad range of issues and holding relationships with a large number of sovereign Tribal nations. The next CPL can position DNR to respond to Tribal concerns and build partnerships with Tribal governments by growing and empowering this office. Actions that should be at the forefront of the next CPL’s priorities include: expanding Tribal Relations staff capacity, increasing Native staff agency-wide, improving the consultation process and access to information for Tribes, and strengthening co-management with Tribal governments.

This year’s grades are nearly identical to our 2023 report, illustrating a continuation of past trends. Like last year, we document significant DNR focus and steady progress on wildfire, disappointing outcomes on state trust lands, delay and unexpected setbacks on private lands, success on aquatics, and incremental progress on clean energy development and siting.

DNR should not maintain this holding pattern. The agency is well positioned to take decisive steps forward under bold new leadership. A new leader will have good momentum for innovation as a result of resolved litigation, forest practices rulemaking processes on the cusp of completion, a new Sustainable Harvest Calculation, availability of CCA funds, and results of DNR-led studies and workgroups.

Innovation and faster progress are needed throughout DNR.

Starting in 2025, we hope to work with a new commissioner who can embrace the challenges and tough decisions inherent to the forest sector, and proactively collaborates with other state agencies, Tribal governments, and the conservation community. We hope the next commissioner will recognize that we urgently need a new direction on state trust lands and forest practices on private lands. And we look to the next CPL to innovate and find new solutions to address the new challenges presented by climate change. While we may not always agree, we are committed to supporting the search for solutions and progress that Washingtonians are counting on.

A bright future awaits us, in which thriving forests support community needs, rural livelihoods, and diverse species. We hope to see Washington coalesce around a ‘new forestry’ centering and rewarding restoration, ecological management, local employment, clean water, habitat, environmental justice, and Tribal sovereignty. DNR has a pivotal role to play in leading us there. But we don’t have time to wait. The pressures of economics, changing climate and ecological damage are too great. With optimism, we look forward to partnering on innovating forest and natural resource management in our state, to usher in this future for the Washingtonians of today and tomorrow.

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 non-partisan 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.

WCA STAFF CONTRIBUTORS

Aida Amirul, Digital Communications Coordinator

Rachel Baker, Forest Program Director

Lennon Bronsema, Vice President of Campaigns

Katie Fields, Forests, Fire and Communities Senior Manager

Caitlin Krenn, Climate and Clean Energy Director

Stephanie Masterman, Tribal Nations Senior Manager

Heather Millar, Content Senior Manager

Darcy Nonemacher, Government Affairs Director

PHOTO CREDITS

Bryan Pelach, State Forestlands Program Manager

Miguel Pérez-Gibson, State Forest Policy Advisor

Mallori Pryse, Visual Communications Manager

Zachary Pullin, Communications Director

Mindy Roberts, Puget Sound Program Director

Ava Stone, Climate Smart Wood Senior Manager

Rico Vinh, Forests and Fish Program Senior Manager

Christina Wong, Vice President of Programs

Under the creative commons 2.0 attribution or Standard Adobe License.

Cord Pryse (cover, 6, 12, 47, 50, 52); Mallori Pryse (2, 4, 8, 14, 18, 20, 24, 30, 32, 40, 42, 46, 48, 56); Washington State Office of the Governor (10); DOI/Photo by Neal Herbert (16); unknown (22, 28, 34); Alexander Harris and RE Sources (26); Jim Choate (36); Pixabay (38); Martin Barraud/Caia Image (44).

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