A U.S. Forest Service map highlights the North Fork Nooksack Vegetation Project area (in pink outlined by dark green) and proposed treatment stands (bright green), in the Mount Baker-Snoqualmie National Forest.

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The U.S. Forest Service closed its comment period April 3 on its Draft Environmental Assessment (EA) of the North Fork Nooksack Vegetation Management Project proposal to cut trees and manage vegetation to improve habitats and stand conditions and to harvest timber. Next steps — including whether to conduct an Environmental Impact Statement (EIS) — are up to project managers to decide.

The draft proposal drew 299 comments across a range of environmental groups, logging interests and tribal government during the comment period. 

The draft EA does not address conducting an EIS, despite many of the more than 1,000 comments calling for one during the project scoping process. 

The Nooksack Indian Tribe in 2017 began participating in the project but since then, tribal representatives “have not been engaged in a formal consultation process on how this project affects tribal treaty rights,” Nooksack Cultural and Natural Resources Director George Swanaset, Jr., wrote in a comment letter.

“Given the lack of follow-through in tribal consultation through the scoping phase to the current EA, we cannot continue to support this project without more information and analysis about the specific impacts to treaty resources,” the tribe said. 

Forest Service Darrington District Ranger and project spokesperson Greta Smith said that an EIS typically wouldn’t happen at this stage, but public comments on the draft EA would determine the need for an EIS. 

According to Smith, “it is about complexity, and it is about the content, context, and intensity.” Factors like effects on the public, altering unique characteristics of the area, unknown effects, or potential violation of environmental protection laws that haven’t yet been assessed could justify an EIS under the National Environmental Policy Act (NEPA).

Matt Cominsky, Washington state manager for the American Forest Resource Council (AFRC), said that in his experience, he’s “never reviewed an EIS for a timber vegetation management project on Forest Service ground in Western Washington.” 

However, in the letter from the AFRC during the public comment of the scoping phase, Cominsky and the AFRC called for an EIS. He explained this was because they believed that the Forest Service would be well-served to have it as litigation defense, because of the wide variety of land type in the proposed project area. 

According to Smith, the proposed area has shrunk — approximately 20% — between scoping and the EA. “As a result of internal and external comments, we have analyzed the project area, and it may look narrower in scope,” said Smith. The commercial thinning in late successional reserve forest areas has been reduced from 1,798 acres to 1,530 acres, and noncommercial thinning has been reduced from 2,054 acres to 1,533 acres in both alternative plans. 

Smith specifically said the project no longer includes any areas with high slope instability which could become a risk with logging. 

Despite the reduction in thinning areas and Cominsky’s claim that effective logging is typically 10-40% less than planned due to on-site changes for environmental protection, activists like Jim Scarborough of the North Cascades Conservation Council are still opposed to the project. 

The North Cascades Conservation Council is requesting that “the Forest Service drop this proposal altogether” and “failing that, they’re obligated to complete a full Environmental Impact Statement.”

The plan also calls for the reopening of 18 miles of existing roads, and only two miles of temporary roads will be built in total.

According to Scarborough, any logging will require the construction of logging roads into the forest, which could impact small streams and tributaries, amongst other impacts. 

Cominsky said that the plan does provide for mitigation of these effects, and that while mitigation takes a lot of work, it can be very effective. 

“I spent a good part of my career doing [mitigation]” said Cominsky. “When done properly, I’ve done projects where I’ve taken people out afterwards and said ‘find the road,’ and they can’t.”

In its written comment, the Anderson, California, company Sierra Pacific Industries supported the project on behalf of their 12 sawmills throughout Washington and California which “rely on timber that is generated on federal forests.” They called for increasing the “economic benefit to the local community” and maximizing all other commercial treatment areas.

Scarborough said that “it’s now up to the Forest Service to decide whether it wants to meet society’s immediate needs for clean water, carbon sequestration, sensitive wildlife habitat, and compatible recreation … or give the public’s trees away to a multinational logging corporation like Sierra Pacific.”

In the coming weeks and months, the Forest Service will be reading the comments and looking for “any potential concerns that may lead us to a determination of ‘significance’ or lack thereof,” said Smith. If significant concerns are found, he said, an EIS may be warranted. 

More reading: “More scrutiny sought on proposed logging around North Fork near Glacier,” Salish Current, June 26, 2020.