Comment by the end of the day on Thursday, May 16 here. 

What it is: A 53,009-acre forest restoration plan in the middle and upper Twisp River and Little Bridge Creek and Wolf Creek sub-watersheds that includes overstory thinning, understory thinning, fuel breaks, road decommissioning, temporary road construction and prescribed burning.

About the Midnight Project:

The Upper and Middle Twisp River watershed is a very special place. Flowing straight from the high peaks of the North Cascades, the Twisp River cuts a path through a valley that supports some of the oldest forests in the area. Bordering a sprawling Wilderness to its west, this river valley hosts rich habitat for a wide variety of species and provides a key corridor from lower elevation forest to subalpine and alpine zones. Canada lynx, fisher, moose, mule deer, and mountain goats all call this place home. When wolves returned to Washington, this was one of the first places they were documented breeding. The cold, clear water flowing in the Twisp River make it an important federally recognized recovery zone for Bull Trout, Spring-run Chinook and Steelhead.

From when this habitat was first included in the Twisp Restoration Project in 2020 (and later dropped into the Midnight Project after the Cedar Creek fire) we have recognized the need for restoration in this watershed. Due to over a century of fire suppression and selective logging, there are large patches of forest that are dominated by small dense stands of mostly Douglas Fir. These areas could benefit from selective thinning and burning. However, there are also areas of high-quality habitat with older trees that need to be treated carefully. These late-successional reserves already contain complex forest structure and there is very limited rationale for cutting larger trees in these areas. From the beginning of this Project we have been critical of how commercial objectives have influenced a project that is meant to be restorative in nature. The overall goal of this project should be to help the forest be more resilient in the face of drought and warmer temperatures from climate change. With federal infrastructure funds available to help pay for it, income from log sales shouldn’t drive the direction of this project. One of the most significant criticisms of this Environmental Assessment is to close exceptions that allow the logging of trees up to 25” in diameter. Large and old trees are already deficient in this landscape and should be kept standing.

For this project the Methow Valley Ranger District has outlined four main needs for the project that the proposed actions (thinning, burning, road maintenance) are intended to address. In our comment guide (just below the map) under each need we outline what actions we have concerns about as well as the actions we support.

You are welcome to use our suggested comments but we also encourage you to find and put your own “why” with them. Focus in on parts of the project you are passionate or knowledgeable about. Express what you support about the Project. When expressing your concerns, include proposed, specific actions which would help address the need the Methow Valley Ranger District is trying to meet.  Be aware of using a respectful tone: individuals within our community are reading, considering and responding to these comments.  See our guide to effective public commenting here. See also the Methow Valley Ranger District’s guide to effective comments.

How to Engage:

Submit a Comment Here

You can read the full Environmental Assessment here.

Check out the maps of proposed treatments, roads, WUI zones and more here. 

Comment Guide:

Need#1: Move current vegetation structure, spatial patterns, and composition toward desired reference conditions.

What concerns us:

• The Midnight proposal continues to allow far too many exceptions for the logging of large trees. By the Methow Valley Ranger District’s own evaluations, large trees are deficient in this landscape and are an essential component of maintaining the structure and function of the forest. These trees can withstand fire and drought and play an important role in storing carbon. To restore old forests on the Midnight Project, all large trees over 20.9” in diameter should be kept. Ask that the Forest Service drop all exceptions for cutting large trees especially in the Late-Successional Reserves. Only true safety hazards trees should be cut and they should be documented and reported.
  • An example of one of the most frequently used exceptions is that trees 20.9” to 24.9” can be cut if they have dwarf mistletoe greater or equal to 2 and are within 50 ft. of a healthy tree greater or equal than 18 inches.
    • Dwarf mistletoe is often used as a rationale for cutting larger trees. However, large trees with mistletoe have additional values, including adding valuable wildlife habitat and forest structure. Trees with mistletoe should not be removed from Late Successional Reserves unless they are a stand wide problem. They provide important structure and complexity and shouldn’t be used as an exception.
    • You can find more exceptions in the Environmental Assessment Appendix A (A-4)
  • Logging should be minimized on steep slopes because it conflicts with restoration objectives.
    • The Ranger District outlines in its decision criteria for thinning that to make logging on steep slopes economically viable requires twice as many trees to be cut than units that are flat to moderate in slope. This economic incentive conflicts with restoration objectives. Significant soil disturbance from tracked equipment and deep rutting left behind from cable logging can be seen on the moderate to steep slopes logged on the Mission project. Cable logging impacts large and old trees that are often girdled for use as operational anchors. Commercial logging on steep slopes should not be dependent on economic viability but should be carried out in a way that meets restoration objectives (even if it comes at an economic loss; steep units can be funded by infrastructure funds).
  • Where condition-based management is used in this project, trees over 20.9” under the exception should be marked before harvest and total leave tree requirements should be met.
    • Although we appreciate leaving condition-based management out of the Late Successional Reserve, where it is being considered in Matrix thin prescriptions we would like to see any exceptions (trees over 20.9”) marked and recorded.  Where condition-based management is being applied in the matrix, we would like to see the total leave tree target of 70-105 trees per acre in various size classes achieved. In matrix units on the Mission Restoration Project we have seen areas logged where no understory is kept which delays the development of a complex multi-story forest.
  • Firewood gathering should not be allowed in the Late Successional Reserves remaining consistent with the Northwest Forest Plan’s current policy
    • Although the Environmental Assessment cuts the number of acres available for firewood gathering by 50%, 385 acres are still left open for firewood cutting in the Late Successional Reserve. Land clearing associated with commercial logging improves access to large snags in these areas that were previously inaccessible to woodcutters. As we have seen in logged units on Mission, newly accessible snags are felled for firewood. There are plenty of other places to cut firewood on the forest and these valuable large snags should be protected.

What we Support:

• The return of fire to the landscape
  • Prescribed fire rejuvenates the forest and reduces the likelihood of high severity fire. Because it is labor intensive, challenging to implement and non-commercial, often prescribed fire is left out of the implementation of restoration projects. Numerous scientific studies show that to improve forest resiliency to fire, thinning should be followed by burning. It is a crucial part of the restoration of dry forests and should be prioritized in this Project!

• The thinning of smaller diameter trees
  • In many places, the noncommercial thinning of smaller trees opens up the forest canopy, creates a healthy understory plant community and, when paired with fire, makes the forest more resilient and adapted to fire.

• Thinning during winter months
  • We applaud and support the Forest Service’s proposal to treat Riparian Reserves during winter months to minimize soil disturbance and erosion. We believe this is an important approach for preserving soil quality that should be considered across more of the landscape.

Need #2 – Protect and maintain wildlife habitat and complex forest in strategic places.

What concerns us:

• Treatments that impact lynx habitat
  • Lynx habitat is limited in the project area but where it is present it should be a priority to keep.  This habitat should be treated in a way that retains plenty of trees to maintain dense cover lynx prefer. The threat of catastrophic wildfire should be more carefully evaluated and not be used broadly to justify degrading habitat. If wildfire is serious risk in certain stands, then then treating surface and ladder fuels and thinning of smaller diameter trees should be prioritized not overstory removal.

• Treatments that impact spotted owl habitat
  • Spotted owl habitat is also limited in the project area and should be a priority to keep as complex multi-story forest. As with lynx habitat the threat of wildfire should be more carefully evaluated and not be used broadly to justify degrading habitat.

 What we support:

• Protecting the limited northern spotted owl habitat
• Designating key lynx habitat and maintaining remaining bitterbrush habitat for mule deer winter range
  • All of actions described in Need #2 of the Restoration Plan could benefit from specific mapping of the habitat for each species. It would also be helpful to detail the resiliency of the existing habitat under a changing climate.

Need #3 – Provide an affordable, safe, and efficient transportation system and reduce sedimentation from roads on the National Forest System

Over 172 miles of open, closed or unauthorized road exist within the Midnight Project area. Some of the closed roads will be opened for commercial thinning operations on this project. Of the roads that are opened, some will be decommissioned, while others will be left open mostly for administrative use.

What Concerns Us: 

• All currently closed roads should be decommissioned post-project.
  • Currently only 17 of 34 miles of the closed roads are being decommissioned after the project.
  • There should be dedicated funding to remove temporary roads after the project

What we Support:

• The decommissioning of 52 miles of road throughout the project area.
  • Decommissioned roads can help to reduce fragmentation of the forest, sedimentation of creeks and rivers, and illegal, unauthorized use of the road network.
• We appreciate that the district has removed the building of any new permanent roads.

Need #4 – Reduce fire risk to communities, reduce hazards along ingress/egress routes and improve firefighting effectiveness within and adjacent to Wildland/Urban Interface.

What concerns us:

• The threat of severe, catastrophic wildfire is often used to justify the need for treatment on this project instead of focusing on restoring fire resiliency across the forest landscape
  • Many proposed commercial treatments on this project are justified based on simulations representing the most severe wildfire weather forecasts. Wildfires burn at different severities depending on many different conditions. Rather than trying to prevent the unknown impacts from a hypothetical wildfire the focus should be on establishing fire resiliency throughout the forest.
• Putting in machine firelines instead of hand firelines for prescribed burning especially along ridgetops.
  • Up to 18.7 miles of machine fireline is proposed for the project. These are often created by bulldozers, create a significant disturbance and can become unauthorized trails when they are used by WATVs.

• The adding of new shaded fuel breaks. Shaded fuel breaks can be linear, unnatural breaks in the forest that fragment habitat
  • Where shaded fuel breaks intersect with a treatment unit, the prescription of the unit should prevail –especially in areas of complex old forest stands. As detailed above, treatments across a full landscape are more effective than isolated, linear treatments
  • We would encourage you to question the Ranger District about how shaded fuel breaks intersect with a larger study about anchor points for fighting fires. Are fuel breaks far away from the Wildland Urban Interface (WUI) necessary to slow a fire?
• We support the maintenance of existing shaded fuel breaks as fuel breaks when not maintained, can fill in with dense understory fuels and become more of a fire threat
  • Much like thinning should be followed by burning, shaded fuel breaks also need to be maintained with fire overtime to be effective.

What we support: 

• Properly thinning and burning the landscape as a whole will help this landscape be more resilient to fire and far less likely to carry wildfire quickly at high severities
  • As extensive scientific research indicates thinning small diameter trees followed by regular prescribed burning is one of the most effective ways to control fire on the landscape. When fires do burn through these areas, they burn at low and moderate intensities that stay out of the canopy and maintain the ecological function of the forest. With properly implemented thinning and burning, linear, unnatural shaded fuel breaks (areas along roads that are thinned more intensively) become unnecessary as there are numerous anchor and control points in the forest itself from which to fight fire.