Forest Practices Board Public Hearings on Proposed Np Rule Change
The proposed Np rule that advanced on June 6th will result in the removal of over 200,000 acres of forest land, the loss of $2 billion in asset value, and reduced harvest of 4.1 Billion Board Feet. Countywide economic impacts from loss of harvesting, milling, silviculture, and support industries are in addition to these costs. The impacts are concentrated in Southwest Washington, but touch all counties in Western Washington. See this spreadsheet for breakdown by county.
Rulemaking is a long and complicated process. We have made plenty of comments during this process over the past 15 years – some were considered, others discarded. The vote on June 6th moved the process to the next step – called a CR102. At this point we are now in official rulemaking under the Administrative Procedures Act. That means there is an open public comment period. All comments received during that time are collated and the government entity responsible for the rule MUST develop a response to every comment and every question. Before this official rulemaking period those comments could be noted, but without the requirement for a formal response/action or incorporation. For each of you who already submitted a letter, you can resubmit it. One additional step that would help is to take your thoughts and ideas and turn them into questions – whether specific or general – and send them to the Forest Practices Board (FPB) to ensure they capture the full breadth of the impact of this rulemaking. Even if some of them are repetitive it doesn’t matter. They will group them – and if there is enough repetition on specific issues maybe we will move the needle. Also, please engage your networks. It will take more than private landowners to carry the day.
Showing up and expressing your opposition and/or concerns is one way to hold government accountable. Submit written testimony for the record and please show up to testify. DNR booked larger venues as they expect a big turnout. Let’s not disappoint them. Details on testimony submission/presentation are as follows.
| Date | Time | Location |
| July 23 | 4 p.m. | McClelland Center, 951 Delaware Street, Longview |
| July 29 | 4 p.m. | Northwest Conference Center, 703 Pacific St, Sedro Woolley |
| August 4 | 4 p.m. | Vern Burton Gym, Parks & Recreation Department, 308 East 4th Street, Port Angeles |
| August 12 | 4 p.m. | Office Building 2,1115 Washington Street SE, Auditorium, Olympia |
| Submit written comments to: |
| Patricia Anderson, Washington Department of Natural Resources |
| USPS mail: Address P.O. Box 47012, Olympia, WA 98504-7012 |
| Email: forest.practicesboard@dnr.wa.gov |
| Submit by: August 12, 2025, 5 p.m. |
| Assistance for persons with disabilities: |
| Contact Forest Practices Division |
| Phone 360.902.1400 |
Department of Ecology Public Hearing on Their ‘No Temperature Change, at No Time, in No Place’ Rule for Non-Fish Streams
This Forest Practices Board (FPB) non-fish perennial (Np) buffer rulemaking has been driven by the Department of Ecology’s interpretation of a water quality standard best described as there can be no temperature change at no time in no place for our dispersed timber harvest activities. This interpretation was forced into the science and policy development process leading up to the proposed rule, even though our headwater streams are considered Tier II streams. In Tier II streams there are allowances for measurable change if there is an overriding public interest. The Department of Ecology’s no temperature change at no time and in no place interpretation is contrary to it’s own rules in WAC 173-201A-320, contrary to the biological opinion for the Habitat Conservation Plan governing timber harvest in Washington state, and sets a terrible precedent for any land use activity near water.
Nevertheless, the Department of Ecology has decided to proceed with its draconian interpretation. To do so, it will have its own public hearing process on the Tier II analysis which underpins the Type Np rulemaking. Their Department of Ecology public hearing process is online ONLY on July 31st. Details on how to participate and where to submit written comments for that process can be found here.
Compelling stories of how this rulemaking is not in the overriding public interest because of the impacts to you or your community should be submitted to that process. More details to understand what this all means are here.
Sample testimony letters from fellow small forest landowners (SFLOs) can be viewed here. Peruse these letters if you’re looking for ideas on how other SFLOs have addressed their concerns with the FPB. As these letters have been submitted as a matter of public record, no personal information has been redacted.