Read Our SEPA Comments on the Turnover Timber Sale
July 8th, 2025
Scott Sargent, Pacific Cascade Region Manager
Via: SEPA Center
P.O. Box 47015
Olympia, Washington 98504-7015
sepacenter@dnr.wa.gov
Re: Turnover Timber Sale – SEPA comments (File No. 25-042301)
Dear Mr. Sargent,
Friends of Clark County (FOCC) is a local non-profit advocacy organization representing its thousands of supporters who are residents of Clark County, Washington.
FOCC opposes the proposed “Turnover” timber sale (SEPA File No. File No. 25-042301) located in Clark County, and we strongly support all comments from Stephen Kropp of the Legacy Forest Defense Coalition (LFDC) regarding this sale.
We agree with LFDC that units 2 and 4 of the Turnover timber sale would clear cut approximately 60 acres of mature, structurally complex forests greater than 75 years old and that DNR’s SEPA checklist for this project incorrectly states that these stands originated in 1950 and 1953 respectively, as aerial images taken in 1952 show that the area contained a young stand—meaning that it likely originated in the 20s or 30s.
The decision to specifically target this rare forest for commercial logging continues to undermine DNR’s own older forest targets in the State Trust Lands Habitat Conservation Plan (with the DNR only having set aside 2% of structurally complex forest in the Columbia HCP planning unit), and the continued, business-as-usual destruction of nearly all remaining natural, lowland forests in Southwest Washington is, as LFDC put it, “scientifically, financially, and economically indefensible”.
Furthermore, we agree that and stress Mr. Kropp’s statements regarding the generation of revenue: “A new carbon market is rapidly emerging, and it may soon be more profitable to leave these older trees in the ground than cut them down. New laws and policies intended to combat climate change are likely to create many more jobs in restorative forestry, fire risk reduction, and ecologically-based forest management 20 years from now on state forest lands than there are in timber sale contracts today.”
Moreover, the Clark County Council, the elected representation of the trust beneficiaries, told you that these older growth forests “provide public recreation and economic opportunities beyond the dollars generated through harvest alone” when they asked you to stop the previous Dabbler timber sale and work with them on a management plan that prioritizes conservation of what is left of our older forests.
Finally, we are deeply concerned with the disregard DNR has displayed for the legal process, demonstrated by its actions involving administrative appeals of timber sales all over the state, and the disregard for the wishes of the trust beneficiaries in the case of the Dabbler timber sale, the Turnover sale, and potentially two more timber sales that remain in the queue. Our Clark County Council has made it clear to your agency that they do not want to see more timber sales of structurally complex older legacy forests going forward, as the people of this county value the ecological benefits of these forests over the short-term, unsustainable economic benefits of cutting them down during a climate emergency.
The DNR’s own website states, “As a trust land manager, DNR is obligated to follow the common law duties of a trustee, which include generating revenue, managing trust assets prudently and acting with undivided loyalty to trust beneficiaries (Washington Supreme Court: Skamania vs. State of Washington, 1984).” FOCC implores you to uphold your duty to Clark County as the trust beneficiary by removing the structurally complex legacy forest units from the Turnover timber sale and other future timber sales in Clark County, and we echo LFDC”s recommendation that “DNR focus on developing a management strategy to generate revenue for trust beneficiaries that conserves older forests, accelerates the development of fully functional forests, and is consistent with the requirements of DNR’s Habitat Conservation Plan, the Intra-Service Biological Opinion for the HCP, PR 14-004-046, the Policy for Sustainable Forests, and the state’s commitment to combat climate change”.
Thank you,
Mary Goody, Friends of Clark County Board Member
Ann Foster, President, Friends of Clark County Board