168 Lost Mountain Lane
Sequim, WA 98382
November 12, 2025
To: Kelly D. Lawrence, Forest Supervisor
Olympic National Forest
1835 Black Lake Blvd. SW
Olympia, WA 98512
Re: Canyon Forest Restoration Project, Preliminary Environmental Assessment
Olympic National Forest, PALS Project Number 62260
Olympic Park Advocates (OPA) wishes to share some concerns regarding the environmental assessment (EA) for the Canyon Forest Restoration Project. This is a major action covering more than 2,000 acres, the largest we know of in Olympic National Forest since the 1994 Northwest Forest Plan (NWFP). Yet the Forest is proceeding with this controversial action with a brief and inadequate EA. We submit that this project is of a size, scope and complexity to require a full environmental impact statement (EIS) under the National Environmental Policy Act (NEPA). It will affect an area that contains habitats for several listed threatened and endangered species, including Northern Spotted Owl, Marbled Murrelet, and several fish stocks in the Dungeness and Gray Wolf rivers and their tributaries. The Dungeness is a Tier 1 Key Watershed and a municipal water source; it and the Gray Wolf River are recommended for Wild and Scenic River designations in a the Wild Olympics Wilderness and Wild and Scenic Rivers legislation currently before Congress. The area is significant traditional cultural territory for treaty tribes, and an extremely popular recreation area. If these factors fail to merit consideration under a full EIS, we question what does.
Your Current Conditions statement describes the previously logged managed stands in the area, less so the naturally regenerated stands following fire disturbance included in the project. We agree with your stated Need for Action, “The purpose and need for the project is to increase forest structural and wildlife habitat diversity and accelerate the development of late-successional forest characteristics, while contributing to the economic viability of local communities,” but disagree that all lands described in the EA are in need of treatment. We submit that nearly half (922 acres of unmanaged, fire regenerated stands) are not.
The EA acknowledges naturally regenerated fire stands as having “a higher frequency and variability [of larger trees] in clumps or single legacy trees or snags in the stands that developed after wildfire” and “more amounts of coarse woody debris (large logs) and snags in the fire-regenerated areas.” Yet the treatments proposed for these stands, heavy-equipment and cable yarding commercial thinning (with 8% hand falling), are applied without distinction to both managed and naturally regenerated landscapes. Previously unmanaged lands would be degraded by commercial thinning activities, which will place threatened and endangered species, protected under the ESA, further at risk. Further, for the majority of species in the EA’s list of sensitive wildlife and botanical species in project areas, proposed actions “may impact” species or habitat. Describing these actions as “restoration” while noting they will “degrade 1,988 acres of habitat” strikes us as and others as arbitrary and capricious decision making.
OPA supports forest restoration thinning when it addresses dense, single species-dominated, even-aged managed stands that are over-stocked and lacking in species and habitat diversity. There is certainly no shortage of these stands on the Forest. We are concerned that the project includes many areas (close to half the acreage) of older, naturally regenerated, fire-originated stands. As the EA confirms, these stands contain larger trees, snags and a greater diversity of species, age, and habitat structure. “The project wildlife biologist also expressed that these stands provide greater structural and habitat diversity including foraging habitat for spotted owls.” These stands are evolving at their own pace toward more structurally diverse, late successional and eventually old-growth forests. They do not need active management; the risks to natural resources are clearly too high. Protecting legacy structures through skips and no equipment zones is inadequate.
Additionally, these stands are far less accessible than previously harvested stands, mostly lacking road systems and landings. The 11.4 miles of temporary road construction required to access these stands will have serious and lasting impacts on fish-bearing streams. All roads, even temporary roads, can deposit sediments into salmon streams and tributaries, provide vectors for non-native and invasive species, open habitat stands to avian predators, and invite illicit quad and dirt bike incursions, all of which degrade fish and wildlife habitat. The forest is rife with temporary or ghost roads that have been reopened by illegal quad and four-wheelers. Enforcement has been lax. In an area hosting a high density of deeply incised salmon streams and tributaries, including habitat for federally listed stocks, this level of road construction is a serious concern. Further, the EA states, “There would be 718.02 acres of harvest units planned within and adjacent to potentially unstable landforms, and 7.36 miles of temporary roads/specified roads planned within and adjacent to potentially unstable landforms [emphasis ours].”
OPA believes the quantity of road construction and associated harvest actions to be in violation of the Endangered Species Act and the Clean Water Act.
The proposed actions: variable density thinning, with sideboards for canopy closure, gap openings, and protected skips to hasten development of mature and old-growth conditions, are appropriate for managed stands, much less so for naturally regenerated fire stands. Since nearly half the proposed project, 922 acres, is made up of these latter stands, we suggest you re-scale the project and focus primary on the densely planted managed stands where road systems and (some) landings already exist. We request the Forest monitor treatments using your recently developed monitoring protocols and document results before entering naturally regenerated stands.
We appreciate the attention given to climate change in the EA. We note the relatively small amounts carbon being removed from the forest, but we believe the climate discussion would benefit from a more through investigation of the capacities of older trees and undisturbed soils to sequester carbon.
Previous rock-source quarries have become de-facto and illegal shotting ranges. What measures will the forest take to prevent this illegal use?
Thank you for this opportunity to comment on the project EA. We look forward to reviewing and commenting on a more detailed EIS for a significantly scaled-down project in the future.
Sincerely,
Tim McNulty
Vice president
Olympic Park Advocates
Olympic Forest Pushes Ahead
with Major Timber Sale in Dungeness Watershed
By Tim McNulty
After a three-year hiatus, and a green light from President Trump to ramp up logging on federal lands, Olympic National Forest is pushing ahead with a major timber sale in the Hood Canal Ranger District. The “Canyon Forest Restoration Project” proposes to commercially thin more than 2,000 acres in the Dungeness watershed. The action requires construction of 11 miles of “temporary” roads including several stream crossings. Forest Service officials are justifying this “restoration project” in a limited and inadequate environmental assessment (EA) rather than a full environmental impact statement (EIS), as required by the National Environmental Protection Act (NEPA). The abbreviated period for public comment ends November 13, 2025.
This is a massive, unprecedented action for the recovering Olympic forest. Areas targeted for thinning are classified as Late Successional Reserves and Adaptive Management Areas under the 1994 Northwest Forest Plan. Nearly half the areas (922 acres) are made up of naturally regenerated stands that seeded in after a fire. These older forests (80-160 years old) generally exhibit a greater diversity of species, age and habitat structure. They contain down logs, dead snags, and increasingly larger trees as stands naturally develop. Progressing at their own pace toward more structurally diverse, late successional, and eventually old-growth conditions, these legacy forests are also important carbon sinks that help curb the acceleration of global warming.
The 11.4 miles of new roads required to access these stands can deposit sediments into salmon streams and tributaries, provide vectors for non-native and invasive species, and open stands to avian predators, all of which degrade fish and wildlife habitat, including habitat for federally listed and sensitive species. We know from bitter experience even “temporary” roads, once cut, invite illicit quad and dirt bike incursions and illegal tree cutting, which remains rampant in this district of the forest.
Several federally listed threatened or endangered species occur in or near these forests, including northern spotted owls and marbled murrelets. Four threatened fish species use the Dungeness River and its tributaries: Puget Sound Chinook salmon, Puget Sound steelhead, Hood Canal summer chum salmon, and bull trout. The Dungeness River is classified as a Tier 1 key watershed in the NW Forest Plan.
In our 2022 scoping letter, OPA stated that a project of this scope requires a full environmental impact statement under NEPA. Further we asked the Forest Service to consider thinning only previously logged and planted second-growth stands and monitor treatments for desired habitat results before committing nearly 1,000 additional acres of older, naturally regenerated forest to restoration thinning. With staffing cuts and all-out slashing of agency budgets, follow-up studies and monitoring are unlikely.
Our concerns were dismissed out-of-hand. Not a problem, the EA assures us: such “short-term” habitat degradations are “expected to benefit habitat in the long term.” With the Trump administration behind it, the agency is plunging ahead.
Deadline for comments on the EA has passed, but this will be an ongoing 10-year project. In the meantime, the Forest Service needs to hear from you.
You can view the project here.
ACTION ALERT:
Tell Congress to Reject Federal Land Sales
in the Budget Reconciliation Bill
click image to enlarge
Analysis of the draft budget shows up to 5.4 million acres in Washington state overall is deemed eligible. Donate to fuel the fight & tell Congress the Wild Olympics are NOT for sale.
(This comment period ended.)
Republicans in Congress are working to pass a budget reconciliation bill that includes the mandatory sale of at least 2 million acres and up to 3.25 million acres of our public lands to private interests over the next five years. The proposal identifies Washington as one of 11 states where the required sales would occur.
Specifically, the Senate’s bill includes a proposal that makes 250 million acres of public land across 11 Western states, including more than 5 million acres in Washington, eligible for sale to private interests (with the exclusion of designated national parks, wilderness areas and the Mount St. Helens National Volcanic Monument).
The rest of the Senate budget bill is just as egregious for public lands and rivers, including gutting NEPA, stripping environmental safeguards, mandated drilling and logging increases that would include roadless areas, cutting old-growth protections and many others. If passed into law in the final budget, the land sales and these extreme provisions could directly threaten roadless headwaters, ancient forests and salmon streams on Olympic National Forest and block public input over the management of our own public lands.
Please contact your congressional Senators and Representatives immediately. Tell them that our nation’s public lands and waters are among our greatest assets, and they are not for sale at any price!
Contact your Senators here.
Contact your Representative here.
Thanks to the Washington Native Plant Society and the Wild Olympics Campaign for information used in this alert.