Use Your Voice to Protect Endangered Lynx Habitat and Old Growth on the Colville National Forest

Contact the Forest Service to ensure the Dollar Restoration Project gets robust environmental and public review!

DEADLINE: JUNE 23RD, 2023 11:59 PM PST

The Colville National Forest is planning a timber sale in the Kettle River Range in northeast Washington called the Dollar Project.

Located on the south slopes of the Kettle Range in a federally designated restoration landscape, the project area abuts the remarkable Bald Snow, and South Huckleberry Roadless Areas, contains deer and elk winter range, and provides important Canada lynx habitat. This project, under the Tribal Federal Protection Act, requires consultation with the Colville Confederated Tribes since it abuts the northern border of the reservation and contributes to sensitive corridor habitat for the lynx reintroduction work that their wildlife biologists are conducting. The Colville National Forest is proposing to thin almost 33,000 acres of forest here. Our primary concern is their proposal of extensive thinning before considering which actions make the most sense or which will be most effective.

The Dollar Project contains high tree species diversity and important wildlife habitat in lieu of a long and sordid history of fire suppression and thinning that have transformed stand and landscape structure and composition. Landscape evaluations are scientifically rigorous, data-driven, logically ordered processes that diagnose restoration needs within a watershed. They are the first step for identifying and prioritizing actions that will be effective in restoring stand and landscape conditions to be resilient to natural disturbances. Landscape evaluations are necessary for sustainable forest management and have been avoided by the Forest.

Because of the scale and complexity of the project, and the necessity of the habitat for lynx recovery, the Forest should conduct a rigorous environmental and public review.  Without a robust Environmental Assessment, there is little certainty that the project will result in positive ecological restoration outcomes or have support from the public and community.  

The Dollar project is a landscape-scale forest restoration project located in the heart of the Kettle Crest. The project area includes quality habitat for Canada lynx, mule deer, and redband trout. It also includes a variety of forest types, whether that’s dry forest in lower elevation areas or high elevation areas with subalpine fir and whitebark pine on the kettle crest.

Email your comments to the Three Rivers Ranger District!

Suggested comments to submit for the Dollar Project:

• The potential short-term impacts of cutting trees, including opening up the canopy and altering hydrologic pattern, on lynx habitat must be disclosed in the EA.
• Stage treatments in lynx habitat over time to provide a steady supply of quality hare habitat coming on line every few years.
• Ensure protections for old growth of 150 years and older and protect and restore large trees (>20” dbh).
• Revise the distance around old trees where other trees can be removed to 50ft (approximately double the canopy drip line)
• The EA fails to quantify cumulative efforts of thinning in mature and old-growth trees and stands, especially goshawk habitat, or thinning and other habitat alteration of lands adjacent to the project area.

Feel free to use our comment portal to ensure this project protects valuable old growth and lynx habitat.

More Context

The project includes many things we’re happy about including aquatic restoration, forest health treatments, hazardous fuels treatments, and recreational improvements. They have particularly focused efforts on ensuring the resilience of sensitive lynx corridor habitats. The report incorporates figures of spatially explicit habitat locations and treatments, tables of detailed impacts to LAUs, and models in a Forest Vegetation Simulator that all contribute to the elucidation of proposal impacts on lynx habitat

For this project, the specialists have completed a white paper that helps intersect habitat classifications in the Lynx Conservation Assessment Strategy with lynx vegetation types on the Colville. Through this analysis, they were able to identify another forest type that is suitable for lynx that was not identified in the 2019 Colville Land Management Plan Remapping effort. They will be managing this new habitat type in the project.

Additionally, the forest has identified a novel approach to managing suitable lynx habitats in sub-alpine forest types of Lynx Analysis Units. They will be utilizing a variety of modified expanding gap treatments. They will be leaving 70% of each unit untreated and 30% treated in long meandering openings ranging from 50-300ft (FS-GDL-WL-09) with the intention of shifting treatments in a 20-year second entry. Variable Density Thinning is proposed for subalpine forest types transitioning to Northern Rocky Mixed Conifer in LAU habitats with a retention of 10-30% untreated and 70% treated. The Subalpine Habitat Enhancement is similar in that it would leave 20% treated, but have a greater percentage of clearings. We are hopeful that these treatments have the potential of increasing heterogeneity on the landscape but are also concerned that these treatments will have unintended impacts on sensitive lynx habitat when cumulative “thorough analysis consisting of quantifiable acreages of impacted habitat within affected Lynx Analysis Units was not completed” within the North Sherman LAU.

We are also concerned about a previously erroneous buffer for old-growth logging. Old-growth forests provide disproportionately high ecological value as wildlife habitat, carbon storage, and resilience to natural disturbance. Scientists have described large and old trees as the ecological backbone of dry and mesic forests. Old-growth trees are the foundation that aids resilience, just like a robust mental health foundation, can help people get through hard times.

Before the new forest plan, the Colville National Forest had a policy called Eastside Screens. Eastside Screens provided assurances that no trees larger than 21” DBH would be harvested. The 21”-rule, as it is sometimes called, used 21” DBH as a quantitative metric that was meant to be equivalent to old-growth trees older than 150 years old. However, there are trees between about 21” DBH and 25” that are not old-growth trees but are actually young, large trees.

During the forest plan revision, we supported quantitative metrics, because they provide clear assurances that old growth will be protected. However, during the process, we collaborated to find a solution that still protects old growth but still allows the forest follow the best available science. Recently released science tells us that in some circumstances it is appropriate to cut trees about 21” DBH and 25” DBH.

The intent of the proposal is to harvest shade-tolerant species of large (>21” DBH), young trees. However, the proposal doesn’t provide assurances that all old trees (>150 years old) are preserved. 

Large, young trees may be large in size, but they haven’t developed the thick, fire-resistant bark of old trees, and may have branches that are close to forest floor. These characteristics mean that these trees are more likely to die during a wildlife, and are functionally similar to trees with a smaller diameter. When these trees are near old-growth trees, they can increase the likelihood that old trees will die too.

Collaborative Solutions

We are working with NEWFC and the Colville National Forest to determine where science tells us it may be appropriate to remove these large, young trees. These are ecologically different from large, old trees, and in specific circumstances, may decrease the likelihood that large, old trees persist if not removed. We’ve provided clear communication that we do not support removing any large, old trees, specifically any trees older than 150 years old, as science tells us that would be inappropriate for ecological forest restoration. NEWFC has also reaffirmed that our standard principle on the topic is not to remove any trees >21″ DBH, and negotiations/collaboration will occur if the CNF proposes something different. This is the case with the Dollar project.

In 2021, NEWFC organized a field trip with leading scientists to discuss these principles of forestry. While progress has been slow, there was a general consensus around the prioritization of species-specific treatments. This included, in order, treating hazard trees, retaining old trees, retaining very large (>25DBH) trees, retaining large (20-25DBH) Ponderosa Pine and Larch trees, and removing large (20-25DBH) trees that are within 50ft of Ponderosa Pine in Dry Douglas Fir forests. The area that we are still addressing is the removal of large (20-50DBH) trees within 50ft of Douglas Fir and Western Larch in other forest types and ones that do not increase the risk of old growth mortality. Since then, the Forest has moved forward without developing clarity with the local collaborative, Northeast Washington Forestry Coalition. In the recent EA they have increased this exception of thinning old growth buffer to 100ft without the consideration of various processes and conditions that negate the need for this buffer. These are extensions that have not been supported by scientific literature and have no citations in the Draft EA. Neglecting the concerns of the community and refusing the willingness of partnership from experts results in avoidable legal entanglements that previous projects are currently facing.

Disclaimer: Conservation Northwest is a Northeast Washington Forest Coalition (NEWFC) Board member, however, the views expressed in this blog are expressly those of Conservation Northwest and we are not representing NEWFC’s position on this subject.

Email your comments to the Three Rivers Ranger District today with our suggested comments!

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