Commentary: DNR Fails to Disclose Environmental and Social Impacts of Carbon Scheme


The Washington Department of Natural Resources (DNR) is rushing to approve a “carbon project” that would lease 10,000 acres of forested state trust lands in western Washington to private interests under the guise of reducing carbon emissions.

Instead of selling timber to local manufacturers as required by law, the carbon scheme seeks to sell “carbon credits” in an unregulated voluntary carbon market for a fraction of the fair market value. The plan would effectively shut down thousands of acres of working forests to help “greenwash” polluters while neglecting the DNR’s real fiduciary responsibility to state trust land beneficiaries.

This scheme will cost beneficiaries, including Lewis County, millions of dollars to improve public school facilities, purchase emergency equipment for firefighters and first responders, support libraries (such as Timberland Regional Library), and maintain county roads, among other public priorities without additional taxes.

DNR expects carbon leases to generate approximately 90 percent less revenue than traditional timber harvests. Yet the agency is failing to fully analyze the project’s impact on funding for schools and other public services. Not only is this analysis required by the State Environmental Policy Act (SEPA), but it also goes to the core of the DNR’s fiduciary obligations to the named beneficiaries of the trust lands. The Washington State Supreme Court recently reaffirmed the trust duties and fiduciary obligations the DNR has to the beneficiaries through the management of state trust lands.

DNR recently concluded a brief 14-day public SEPA comment period after rejecting requests from beneficiaries, local governments, state legislators and the forest sector to extend the comment period to give stakeholders more time to analyze the project and comment.  DNR has also failed to respond to letters from about two dozen legislators, including an April 19 letter from legislative leaders and an April 25 letter from 22 legislators from central and eastern Washington expressing concerns about the project and lack of public transparency.

The agency has ignored calls from Lewis County and other beneficiaries to properly and legally account for how the scheme affects Washington's environment, communities, wildlife, and the current and future management of these working forests. This project also risks the forest infrastructure needed to address forest health concerns and to reduce the risk of catastrophic wildfire and associated emissions. The Department needs to analyze this potential outcome and how it will affect the environment and local communities.

Such an analysis would clearly demonstrate that stopping management of our working forests is the wrong solution for climate change. Research finds that active forest management is more effective in capturing and storing atmospheric carbon in forest and wood products. Instead, a “no-management” policy results in increased carbon emissions and reduced timber supply at the expense of rural communities and public service providers.

Leakage is when the reduction in timber supply is replaced with increased timber outputs from other forestland owners, other regions of the United States and other countries. Substitution occurs when more carbon intensive building products such as concrete and steel, are substituted for a wood product, because that wood product is not available or has become too expensive. Neither of these alternatives are beneficial to the environment or the communities who benefit from management of these lands.

The International Panel on Climate Change (IPCC) and the UN Food and Agriculture Organization (FAO) have both identified scientifically based sustainable forest management and the use of long-term wood products for building as key tools in the efforts to mitigate carbon in the atmosphere.

Even the Washington State Legislature in RCW 70A.45.090 recognizes the important role the forest products sector plays in mitigating carbon emissions. Sustainable forest management essentially means repeating a never-ending cycle of harvesting, planting, growing and sending that harvested wood that is roughly 50% carbon by weight- off to become wood products, especially building products, that we use every day.

By removing state trust lands from timber management, the DNR is breaking that sustainable forest management cycle in favor of a scheme that will not reduce the emissions of greenhouse gasses but benefits deep-pocketed polluters.

Climate leadership is not a short-sighted, politically driven preservation of trees in a carbon scheme. Real climate leadership is working hard to meet sustainable harvest levels to assure local wood products are here to meet our housing and construction needs along with other wood products we all use for current and future generations. The DNR should be held accountable for a scheme that not only rewards polluters but fails Lewis County and other state trust lands beneficiaries.


Matt Comisky is the Washington manager for the American Forest Resource Council. Comisky has worked in the forest products sector, as a forest engineer, forester and policy analyst for nearly 25 years in Washington state for both public and private land managers. He currently oversees the American Forest Resource Council’s Washington State program of work related to DNR-managed trust lands and the U.S. Forest Service.