Turnover Timber Sale Comments to the Board of Natural Resources
Friends of Clark County is a non-profit organization representing its thousands of supporters who are residents of Clark County, Washington. We reiterate our opposition to the Turnover timber sale and urge the Department of Natural Resources to respect the wishes of the people of Clark County and its elected representatives by rescinding the Determination of Non-Significance on this sale and for it to be removed from the auction list for the following reasons:
- The people have spoken. Clark County residents collectively sent hundreds of letters in opposition to the Dabbler timber sale, making it clear we do not want the DNR to destroy what is left of our legacy forests. The Clark County Council also requested that the DNR halt the destructive Dabbler timber sale and timber sales in similar legacy forests.The Council also went on record as explicitly opposing the Turnover and Dendrophobia timber sales. The benefit of these legacy forests to Clark County as naturally regenerated, structurally complex forest has been communicated over and over. The DNR’s repeated determination of “no significance” ignores the political sovereignty of our county, undermining the Council’s ability to be stewards of county citizen interests. The days of the DNR ignoring the will of the people must come to an end.
- The Turnover timber sale includes some of the last structurally complex, Maturation II designated, naturally regenerated forest habitat that Clark County has left. These facts have been verified multiple times, including most recently by Brian Poehlein at the Clark County Trust Lands Visit. Maturation II forest, as designated by the Van Pelt method (2007) and used by the DNR, includes some of the rarest and most biodiverse types of forest stands outside of old growth. These legacy forests provide some of the best current and future wildlife habitat in Clark County. Currently, the DNR has only reached 2% of its goal of 10-15% structurally complex forest in the Pacific Cascade region. It defies logic, then, to remove this forest before that minimum is met. Furthermore, the Turnover SEPA Environmental Checklist (2024) lists several categories of wildlife in addition to the endangered spotted owl that will be affected by this habitat loss. This includes “songbirds”, many of which are in decline in the PNW due to mature forest loss, and specifically the Swainson’s thrush which was highlighted in the Seattle Times in August 2025 (Mapes 2025). The harvest of this structurally complex, mature forest will have cumulative effects on wildlife that is not touched on by the policies used.
- Outside of the importance to wildlife in this region, there is no consideration in the DNS or alternatives for the cultural or recreational importance of this contiguous area. Additionally, as part of the Trust Lands Visit recently, there was no mention of management that addresses cultural or recreational importance to the county and citizens of Washington state, of which our forest lands as according to the Washington State Constitution must be managed for the benefit of all.
- Carbon mapping obtained by Legacy Forest Defense Coalition confirms that Turnover includes some of Clark County’s most carbon dense forested areas. These forests are critical to meeting state mandated greenhouse gas emissions reductions goals and improving Clark County’s climate resiliency. Current climate change models’ output effects on forest stock have not been considered within the DNR’s policies used to determine “non-significance” of timber sales. Timber sale SEPA checklists refer to “the global warming mitigating role of wood products from Washington’s private forests…that currently operates as a significant net sequesterer of carbon.” This conflicts with the USDA data reported by Center for Sustainable Economy which contradicts this statement for this harvest area (Talberth 2024). In the Turnover SEPA EC, the DNR states: “The timber harvested from DNR-managed lands is used to produce climate-smart forest products” and that the climate impacts of DNR’s management have been included in multiple policies informing this harvest plan. Using phrases like “climate-smart” without objective metrics is empty and blatant greenwashing. Recent DNR policy analysis by Brandi Cole asserted that in the FEIS for the Sustainable Harvest Calculation for Western Washington—which is now outdated—the DNR did not sufficiently consider the climate impact of individual timber harvest units (Cole 2025). Additionally, Cole found that the DNR’s assertion that regionally Western WA forests “sequester more carbon than is emitted is based on dated materials. Further, the Turnover SEPA EC unfairly prioritises the benefits of carbon sequestration within timber products over the sequestration and habitat value of leaving the structurally complex, mature forest standing. The EC also does not investigate the adverse impacts that this harvest proposal would bear on Clark County’s environment. According to the SEPA Handbook (2025), “all elements of the natural and built environment must be considered, not just those within the lead agency’s jurisdiction. The beneficial aspects of a proposal should not be balanced against the adverse impacts. Instead, determine if any probable adverse environmental impacts, particularly significant ones, are likely to occur” highlighting the importance of considering the adverse effects of these timber sales.
- There are no cumulative climate impacts considered in the SEPA checklist, therefore the DNS cannot be accepted as sound and valid justification for the harvest of this site. Policy analysis by Brandi Cole of WSU asserted that “mitigation across timber sale ECs does not conduct or provide project-level analysis regarding site-specific cumulative effects of or mitigation for individual timber sales including carbon and climate change or alternate methods of generating revenue from these forested lands” (Cole 2025). The Turnover SEPA EC intentionally highlights the benefits of timber production over the benefits of leaving our oldest forests standing and their potential to mitigate the worst climate change risks. The DNR supports this claim by citing an IPCC report which credits timber products from “sustainable forest management” as a climate change solution. However, the DNR does not provide any objective metrics to describe what “sustainable forest management” means in this context which amounts to greenwashing. Secondly, in their reference to Washington law HB2528 as that older forests actually sequester and store more carbon than timber products regardless of their capacity to store carbon. Using the mentioned statements from the IPCC report as well as HB2528 ignores the carbon storage capacity of mature and older forests compared to harvested for timber products. The statements within the Turnover EC also neglects other points made within the 2019 IPCC report including that “Climate change is projected to alter land conditions with feedbacks on regional climate” and “changes in forest cover, [such as] deforestation, directly affect regional surface temperature through exchanges of water and energy”(IPCC 2019). Further, none of the DNR’s referenced policies within timber sale ECs address current climate model estimates of 1.5 degrees warming in the near future or the effects on forests and regional climate of Clark County, Washington.
- The policies informing the planning of Turnover do not take into account the role that the most recent climate trends will have on the state of our forests in the state, and how this harvest will impact these trends. The source policies used in timber sale SEPA ECs do not consider the most recent forecast of hotter, drier climates in the next 10 years and their effect on our forests. This is reflected in a recent statement by a DNR representative that “The main climate takeaway for Washington in 2024 was the continuation of long-term warming trends…For the third time in four years, the annual average temperature in Washington was among the 10 warmest on record” (Fitzgerald 2025). Further, in the most recent IPCC report it is stated that “Continued greenhouse gas emissions will lead to increasing global warming, with the best estimate of reaching 1.5°C in the near term in considered scenarios and modelled pathways. Every increment of global warming will intensify multiple and concurrent hazards” (IPCC 2019). This is not mentioned or considered in the source policies, nor the project level cumulative effects.
- There has been no recent outreach with Clark County trust beneficiaries regarding timber sales within the county including the Turnover sale. This lack of outreach was verbally confirmed by Sarah Ogden, Trust Lands Outreach Coordinator, on September 12th at the Trust Lands Visit in Clark County. One of the main talking points of the DNR to both Clark County officials and members of the public has been that they are planning the Turnover sale with their obligation to trust beneficiaries in mind. It is not only disingenuous, but deceptive to weaponize the trust beneficiaries’ interests in regards to this sale, when the trust beneficiary interests were never once consulted in planning this sale. According to the SEPA Handbook (2025), “In evaluating a proposal…Lead agencies should also consider any comments received from the public, Tribes or other agencies (through consultations, a notice of application, permit applications, etc.).” However, the comments provided regarding the determination of nonsignificance of the Turnover timber sale, and letters from Clark County councilors were not considered.
In conclusion, there can be no determination of “non-significance” if the “non-significance” has not been diligently and accurately investigated . There has not been adequate justification that this harvest as planned is fully in the interests of Washington state citizens, including Clark County leadership, residents, and trust beneficiaries. Rescind the Determination of Non-significance of the Turnover and take it off consideration for auction.
References
Cole, Brandi. 2025. “Evaluating Public Involvement in Environmental Assessment: A Case Study of Washington Department of Natural Resources Dabbler Timber Sale.” doi:10.7273/000007526.
Fitzgerald, Emily. 2025. “WA Forest Health Survey Finds 545,000 Acres of Stressed or Dead Trees.” The Columbian, July 11. https://www.columbian.com/news/2025/jul/04/wa-forest-health-survey-finds-545000-acres-of-stressed-or-dead-trees-2/
Intergovernmental Panel On Climate Change (IPCC). 2022. “IPCC, 2019: Summary for Policymakers.” in Climate Change and Land: IPCC Special Report on Climate Change, Desertification, Land Degradation, Sustainable Land Management, Food Security, and Greenhouse Gas Fluxes in Terrestrial Ecosystems. Cambridge University Press. https://www.ipcc.ch/site/assets/uploads/sites/4/2019/12/02_Summary-for-Policymakers_SPM.pdf
Jones, Keith. 2024. Turnover Timber Sale SEPA Environmental Checklist. State Forest Land SEPA Environmental Checklist. Clark County, Washington: Washington Department of Natural Resources (WADNR). https://apps.ecology.wa.gov/separ/Main/SEPA/Record.aspx?SEPANumber=202501659.
Mapes, Lynda V. 2025. “A Familiar Bird of Northwest Summer Takes a Perilous Journey to Costa Rica.” The Seattle Times, August 9. https://www.seattletimes.com/seattle-news/climate-lab/inside-the-perilous-journey-of-a-familiar-northwest-summer-bird/
Pelt, Robert Van. 2007. Identifying Mature and Old Forests. Washington Department of Natural Resources (WADNR). https://dnr.wa.gov/sites/default/files/2025-03/lm_hcp_west_oldgrowth_guide_full_lowres.pdf.
Talberth, John. 2024. “Court Halts Logging Over Climate Impacts.” https://www.sustainable-economy.org/court-slaps-dnr-again-for-climate-impacts-of-mature-forest-logging.
Washington State Department of Ecology (WSDOE). 2025. State Environmental Policy Act Handbook. https://apps.ecology.wa.gov/publications/SummaryPages/2506009.html?utm_medium=email&utm_source=govdelivery.
Washington State Legislature. 2020. Engrossed Second Substitute House Bill 2528, Chapter 120, Laws of 2020, 66th Legislature, 2020 Regular Session. https://lawfilesext.leg.wa.gov/biennium/2019-20/Pdf/Bills/Session%20Laws/House/2528-S2.SL.pdf