In western Washington, Golden Eagles nest in lowland and mid-elevation forest landscapes, where they are quite scarce. A couple of territories I am familiar with are centered on cliff nests (e.g. foothills of central Cascades). These territories seem to be fairly consistently occupied. Territories centered on tree nests are also known, and have been reported from lower elevation forests where cliffs are absent (e.g. southwestern Washington). Tree nest territories are apparently rather ephemeral, perhaps due to nest loss or the fact that forest succession rapidly makes specific foraging sites unavailable (when clearcuts become young forests).