Lake Whatcom Cooperative Management Program Joint Councils & Commissioners (Annual Meeting Part 2)

No formal votes were taken at this discussion-focused meeting. However, several commitments and directions emerged: **Whatcom County committed** to bringing forward resource estimates for code analysis work as part of the mid-biennium budget review to assess aligning land use regulations with city standards. **Staff confirmed** implementation of new aquatic invasive species monitoring, including monthly eDNA and plankton sampling, installation of gates at Blue Canyon boat launch, and camera monitoring at South Bay launch. **Forest management planning** will proceed with public tours scheduled for June 18th and July 16th, with a draft plan expected in August covering 13,000 acres of city and county lands. **Policy group discussions** will continue examining comprehensive plan updates through the Lake Whatcom lens, with potential meetings in September addressing Senate Bill 5471's middle housing provisions in watershed areas.

**Lisa Anderson, on wildfire preparedness:** "I just kind of feel like we might be on our heels a little bit and not on our toes over the next few years, and I'm wondering what the county is doing to address that." **Anderson, on equipment pre-positioning:** "You need to plan for it before you need it. So once those are identified, I'd really like to make sure that we're working across the board for shared budget to make sure those purchases are made." **Kaylee Galloway, on policy group effectiveness:** "It doesn't really feel like we're a working group like, we're not actually pumping out policy, or we're not actually reviewing documents, or we're not actually contemplating budgets." **Todd Donovan, on phosphorus standards:** "If they were made both 0.15, how much more engineering or cost is that to a homeowner to get that extra 20%? Is it trivial, or is it huge?" **Ben Scanlon, on regulatory gaps:** "Wait, I can't do that, but this can do this? I'd be pissed off. So I'm wondering what we could do between our jurisdictions to do some lobbying around this." **Mike Ralston (City), on DNR fire retardant policy:** "DNR has a map that they use to identify sensitive watersheds for where they can and or will or will not use retardant. Lake Whatcom specifically is on the do not use retardant list."

# Real Briefings — Supplemental Content --- ## MODULE S1: STUDY GUIDE ### Meeting Overview The Lake Whatcom Cooperative Management Program held its annual joint meeting between Whatcom County Council, Bellingham City Council, and Lake Whatcom Water & Sewer District commissioners on June 4, 2025. The meeting focused on implementation challenges for the 2025-2029 work plan, coordination between jurisdictions on land use regulations, and upcoming projects including wildfire preparedness and invasive species response planning. ### Key Terms and Concepts **Lake Whatcom Policy Group:** A smaller working group with representatives from each jurisdiction that meets regularly to coordinate lake management efforts and policy discussions. **TMDL (Total Maximum Daily Load):** A federal water quality standard that sets limits on phosphorus pollution entering Lake Whatcom, driving many of the regulatory requirements. **Phosphorus Loading Limitation:** Regulations limiting how much phosphorus can run off from new development - city requires 0.15 pounds per acre per year, county allows 0.1875 pounds per acre per year. **Forest Management Plan:** Joint planning effort between city and county covering 13,000 acres of publicly-owned land around the lake to protect water quality and forest health. **Aquatic Invasive Species (AIS) Rapid Response Plan:** Emergency protocols being developed to respond quickly if zebra mussels, golden mussels, or faga mussels are detected in Lake Whatcom. **Full Dispersion vs. Engineered Systems:** Two approaches to managing stormwater runoff - full dispersion uses natural vegetation on large properties, engineered systems are built treatment facilities. **Homeowner Incentive Program (HIP):** Voluntary program helping property owners remove lawns and install native landscaping to reduce phosphorus runoff. **Land Acquisition Program:** City program using dedicated revenue to purchase developable land around the lake to permanently protect it. ### Key People at This Meeting | Name | Role / Affiliation | |---|---| | Kaylee Galloway | Whatcom County Council, meeting chair | | Lisa Anderson | Bellingham City Council | | Todd Donovan | Whatcom County Council | | Barry Scanlon | Whatcom County Council | | Michael Lilliquist | Bellingham City Council | | Kathy Craver | Whatcom County Public Works, lead presenter | | Jason Porter | City of Bellingham, Lake Whatcom program manager | | Mike Ralston | City of Bellingham Natural Resources | | Morgan Ruff | City of Bellingham Special Projects Manager | | Renee Swenson | Retiring City of Bellingham Lake Whatcom coordinator | ### Background Context Lake Whatcom serves as the primary drinking water source for Bellingham and surrounding areas, but development pressure and climate change threaten water quality. The lake has been on Washington's impaired waters list due to excess phosphorus, which can cause harmful algae blooms. Three jurisdictions - Whatcom County, City of Bellingham, and Lake Whatcom Water & Sewer District - coordinate management efforts through a formal cooperative program with 5-year work plans. The current challenge is that most of the watershed (about 70%) is in unincorporated county jurisdiction, but the city has more aggressive water quality regulations and dedicated funding sources. This creates coordination challenges and questions about whether regulations should be made more consistent across jurisdictions. Recent wildfire threats and invasive species discoveries in nearby waters have added new urgency to protection efforts, requiring rapid response planning and cross-training between agencies. ### What Happened — The Short Version Council Member Anderson opened with detailed questions about coordination between jurisdictions, particularly around inspection and enforcement of stormwater systems and boat launch monitoring for invasive species. Staff provided updates on the homeowner incentive program, showing the city has worked with 180 property owners to remove over 1 million square feet of lawn, while the county worked with 56 property owners on 195,000 square feet. The discussion then shifted to wildfire preparedness, with Anderson expressing concerns about fire retardant use in the watershed and cross-training needs. Staff confirmed DNR has agreed not to use fire retardant in the Lake Whatcom watershed and that wildfire response planning is underway. Budget challenges emerged as a key theme, with officials discussing the need for dedicated revenue sources and noting that land acquisition costs continue rising while invasive species threats require more monitoring and rapid response capabilities. The major presentation covered differences in land use regulations between city and county, highlighting that the county allows 25% more phosphorus runoff (0.1875 vs 0.15 pounds per acre per year) and has different enforcement mechanisms. A clear-cut photo sparked discussion about gaps in private forestry regulation. ### What to Watch Next • Mid-biennium budget discussions will determine resources for analyzing and potentially aligning city-county development codes • Forest management plan draft expected in August 2025 • Lake Whatcom Policy Group meetings may expand scope to more active policy development rather than just updates • Comprehensive plan updates in fall 2025 may address watershed protection and growth allocation issues --- ## MODULE S2: FLASH CARDS **Q:** What percentage of the Lake Whatcom watershed is in county jurisdiction versus city jurisdiction? **A:** About 70% of the watershed is in unincorporated county jurisdiction, while the city's jurisdiction covers a much smaller portion of the overall watershed. **Q:** What are the different phosphorus loading limits between city and county regulations? **A:** City of Bellingham requires 0.15 pounds per acre per year (forested condition), while Whatcom County allows 0.1875 pounds per acre per year - 25% more phosphorus runoff. **Q:** How many property owners has the city's homeowner incentive program worked with in the last 5-year work plan? **A:** 180 property owners on just over 200 projects, removing over 1 million square feet of lawn and replacing it with native landscaping. **Q:** How many property owners has the county's program worked with during the same period? **A:** 56 property owners, enhancing 195,000 square feet of area with improved landscaping and runoff management. **Q:** What is the Lake Whatcom Policy Group? **A:** A smaller working group with representatives from county council, city council, and water district that meets regularly to coordinate policy discussions and lake management efforts. **Q:** When was the major down-zoning of the Lake Whatcom watershed completed? **A:** 2002, when the county down-zoned the watershed to R5A (1 house per 5 acres), removing 1,800 potential development units after months of emergency moratoriums and late-night hearings. **Q:** What additional density reduction occurred in Sudden Valley? **A:** In the mid-1990s, Sudden Valley Community Association implemented a density reduction program removing 1,400 lots from development potential, keeping them in open space. **Q:** What is DNR's policy on fire retardant use in the Lake Whatcom watershed? **A:** DNR has Lake Whatcom on their "do not use retardant" list, meaning fire retardant would not be used in the watershed during firefighting operations. **Q:** What three invasive mussel species is the rapid response plan designed to address? **A:** Zebra mussels, golden mussels, and faga mussels - all of which could severely impact drinking water infrastructure and natural ecosystems. **Q:** How many acres will the joint forest management plan cover? **A:** 13,000 acres across City of Bellingham's Lake Whatcom land acquisition program land and Whatcom County park land within the watershed. **Q:** What is the construction/seasonal closure window when land disturbance is restricted? **A:** October 1st to May 31st - both city and county have the same seasonal restrictions to prevent erosion during wet months. **Q:** When did the city adopt its Lake Whatcom Reservoir regulatory chapter? **A:** 2001, creating dedicated and specific development regulations for the watershed (often called the "Silver Beach Ordinance"). **Q:** What happens when someone exceeds 300 square feet of new development in Bellingham? **A:** The entire property must be retrofitted to meet the 0.15 phosphorus loading limit, not just the new addition. **Q:** Who is taking over as main point of contact for the Lake Whatcom Management Program? **A:** Jason Porter, supported by Mike DeParoskin and Morgan Ruff, as Renee Swenson retired in June 2025 after years managing the program. **Q:** What Senate bill could potentially increase housing density in watershed areas? **A:** Senate Bill 5471, which addresses middle housing and could allow up to 4 units per lot in LAMIRDs (Limited Areas of More Intensive Rural Development), though county has discretion to implement. **Q:** When do gates at boat launches become more actively enforced? **A:** Starting in fall when seasonal aquatic invasive species inspectors are no longer stationed there - people with permits can call to have gates opened. **Q:** What is "full dispersion" versus engineered stormwater systems? **A:** Full dispersion uses 65% of property in native vegetation as natural treatment (common on large lots), while engineered systems are built treatment facilities. **Q:** What was the timeline given for the climate vulnerability assessment? **A:** RFP expected by end of 2025, consultant hired, with formal work launching in 2026 to assess climate threats to lake systems. **Q:** Where can the public sign up for forest tours and provide input? **A:** The Engage Bellingham webpage, with tours scheduled for June 18th and July 16th, 2025. **Q:** What is the major gap in forestry regulation within the watershed? **A:** Private commercial forestry is only subject to statewide forest practice rules, not the stricter watershed protection standards that apply to DNR lands or development projects. --- ## MODULE S3: QUIZ WITH ANSWER KEY **Question 1: What is the difference in phosphorus loading limits between City of Bellingham and Whatcom County regulations?** - A) City allows 25% more than county - B) County allows 25% more than city - C) Both have identical limits - D) County has no phosphorus limits **Question 2: How many property owners did the City of Bellingham's homeowner incentive program work with during the last 5-year work plan?** - A) 56 property owners - B) 96 property owners - C) 180 property owners - D) 200 property owners **Question 3: When was the major down-zoning of the Lake Whatcom watershed completed?** - A) 1999 - B) 2001 - C) 2002 - D) 2013 **Question 4: What is DNR's policy regarding fire retardant use in the Lake Whatcom watershed?** - A) Fire retardant is required for all fires - B) Lake Whatcom is on the "do not use retardant" list - C) Fire retardant can only be used with special permits - D) No specific policy exists **Question 5: What three invasive species is the rapid response plan designed to address?** - A) Asian carp, northern pike, and bass - B) Zebra mussels, golden mussels, and faga mussels - C) Eurasian watermilfoil, purple loosestrife, and hydrilla - D) New Zealand mud snails, quagga mussels, and clams **Question 6: What happens when someone exceeds 300 square feet of new development in Bellingham?** - A) Only the new area must meet phosphorus limits - B) The entire property must be retrofitted to meet phosphorus limits - C) Development is prohibited - D) Additional fees are required **Question 7: When are land disturbance restrictions in effect for both jurisdictions?** - A) June 1st to September 30th - B) September 1st to May 1st - C) October 1st to May 31st - D) November 1st to April 30th **Question 8: Who is taking over as the main point of contact for the Lake Whatcom Management Program?** - A) Mike Ralston - B) Jason Porter - C) Morgan Ruff - D) Kathy Craver **Question 9: How many acres will the joint forest management plan cover?** - A) 8,000 acres - B) 10,000 acres - C) 13,000 acres - D) 17,000 acres **Question 10: What is the major regulatory gap identified for private commercial forestry in the watershed?** - A) No seasonal restrictions apply - B) Only subject to statewide forest practice rules, not watershed-specific protections - C) No permits are required - D) Clear-cutting is completely prohibited **Answer Key:** **1. B** — County allows 0.1875 pounds per acre per year while city requires 0.15 pounds per acre per year, making county limits 25% higher. **2. C** — The city worked with 180 property owners on just over 200 projects, removing over 1 million square feet of lawn. **3. C** — The down-zoning to R5A (1 house per 5 acres) was completed in 2002 after months of emergency moratoriums and contentious hearings. **4. B** — Staff confirmed that DNR has Lake Whatcom on their "do not use retardant" list for firefighting operations. **5. B** — The rapid response plan specifically addresses zebra mussels, golden mussels, and faga mussels that could impact drinking water infrastructure. **6. B** — Unlike the county which only applies rules to new areas, Bellingham requires retrofitting the entire property when development exceeds 300 square feet. **7. C** — Both jurisdictions maintain the same seasonal closure from October 1st to May 31st to prevent erosion during wet months. **8. B** — Jason Porter is taking over from retiring Renee Swenson, supported by Mike DeParoskin and Morgan Ruff. **9. C** — The plan covers 13,000 acres across city land acquisition program properties and county parkland within the watershed. **10. B** — Private commercial forestry only follows statewide forest practice rules, not the stricter watershed protection standards that apply to other land uses. --- ## MODULE S4: Q&A — COMMON QUESTIONS **Q: Why does the county allow more phosphorus runoff than the city if they're protecting the same lake?** A: This reflects different policy decisions made in 2013. City staff recommended identical standards, but after extensive public process including input from the building industry and engineering firms, the County Council voted to allow 25% more phosphorus (0.1875 vs 0.15 pounds per acre per year). The county felt this balanced water protection with development costs and feasibility. **Q: What happens if zebra mussels or other invasive species are found in Lake Whatcom?** A: The rapid response plan being developed will create unified incident command between the county, city, Lake Whatcom Water & Sewer District, and Department of Fish and Wildlife. Pre-positioned containment equipment and chemicals would be deployed immediately, as the longer the delay, the less likely successful control becomes. Treatment would likely be funded through a governor's emergency declaration. **Q: Are there enough inspections to ensure stormwater systems keep working after installation?** A: Currently, follow-up inspections are complaint-driven or occur when staff observe problems in the field, rather than on a regular schedule. Both city and county acknowledged this as a gap, with plans being developed for more systematic inspection of private stormwater systems. **Q: Why can private timber companies clear-cut in the watershed with fewer restrictions than regular development?** A: Private commercial forestry is only subject to statewide forest practice rules, not the watershed-specific protections. This creates a significant regulatory gap since these operations can have major water quality impacts. DNR lands must follow a stricter "landscape plan," but that doesn't apply to private forestry. Officials suggested this may require legislative action. **Q: How much does it cost property owners to meet the different phosphorus standards?** A: Staff acknowledged they don't have cost analysis comparing the city's stricter 0.15 standard versus the county's 0.1875 standard. The stormwater treatment systems themselves are the same, but meeting stricter standards requires treating more of the property's runoff, potentially requiring larger or additional systems. **Q: What's the biggest remaining source of phosphorus pollution if development is being controlled?** A: The presentation showed significant undeveloped land remains, particularly in county jurisdiction zoned R5A (1 house per 5 acres). However, officials noted the "low-hanging fruit" for major reductions through down-zoning has largely been achieved, with future gains likely to be more marginal. **Q: Will climate change affect the lake and what's being done about it?** A: A climate vulnerability assessment is beginning with RFP expected by end of 2025 and formal work starting in 2026. This will examine how changes in precipitation, temperature, and extreme weather events like atmospheric rivers and wildfires could affect the lake system and existing protection programs. **Q: How much land is left that could be developed around the lake?** A: The 2023 buildout analysis shows potentially 610 units could still be built in rural county areas under current R5A zoning, plus additional development possible in city areas. Most remaining development potential is on larger parcels away from the immediate shoreline. **Q: What happens to this program when people retire or budgets get tight?** A: Budget pressures are a major concern since land acquisition costs keep rising and invasive species threats require more resources. Most lake work is funded through dedicated revenue sources rather than general funds, providing some protection. Jason Porter is taking over from retiring coordinator Renee Swenson with support from other experienced staff. **Q: Should the Lake Whatcom Policy Group be doing more than just receiving updates?** A: There was significant discussion about this, with some members wanting the group to become more of an active policy-working group rather than just a briefing forum. Ideas included jointly reviewing comprehensive plan updates, coordinating code changes between jurisdictions, and developing shared budget priorities for lake protection work.

## MODULE S1: STUDY GUIDE **Meeting ID:** WHA-CON-2025-06-04 ### Meeting Overview The Lake Whatcom Cooperative Management Program held its annual joint meeting between Whatcom County Council, Bellingham City Council, and Lake Whatcom Water & Sewer District commissioners on June 4, 2025. The meeting focused on implementation challenges for the 2025-2029 work plan, coordination between jurisdictions on land use regulations, and upcoming projects including wildfire preparedness and invasive species response planning. ### Key Terms and Concepts **Lake Whatcom Policy Group:** A smaller working group with representatives from each jurisdiction that meets regularly to coordinate lake management efforts and policy discussions. **TMDL (Total Maximum Daily Load):** A federal water quality standard that sets limits on phosphorus pollution entering Lake Whatcom, driving many of the regulatory requirements. **Phosphorus Loading Limitation:** Regulations limiting how much phosphorus can run off from new development - city requires 0.15 pounds per acre per year, county allows 0.1875 pounds per acre per year. **Forest Management Plan:** Joint planning effort between city and county covering 13,000 acres of publicly-owned land around the lake to protect water quality and forest health. **Aquatic Invasive Species (AIS) Rapid Response Plan:** Emergency protocols being developed to respond quickly if zebra mussels, golden mussels, or faga mussels are detected in Lake Whatcom. **Full Dispersion vs. Engineered Systems:** Two approaches to managing stormwater runoff - full dispersion uses natural vegetation on large properties, engineered systems are built treatment facilities. **Homeowner Incentive Program (HIP):** Voluntary program helping property owners remove lawns and install native landscaping to reduce phosphorus runoff. **Land Acquisition Program:** City program using dedicated revenue to purchase developable land around the lake to permanently protect it. ### Key People at This Meeting | Name | Role / Affiliation | |---|---| | Kaylee Galloway | Whatcom County Council, meeting chair | | Lisa Anderson | Bellingham City Council | | Todd Donovan | Whatcom County Council | | Barry Scanlon | Whatcom County Council | | Michael Lilliquist | Bellingham City Council | | Kathy Craver | Whatcom County Public Works, lead presenter | | Jason Porter | City of Bellingham, Lake Whatcom program manager | | Mike Ralston | City of Bellingham Natural Resources | | Morgan Ruff | City of Bellingham Special Projects Manager | | Renee Swenson | Retiring City of Bellingham Lake Whatcom coordinator | ### Background Context Lake Whatcom serves as the primary drinking water source for Bellingham and surrounding areas, but development pressure and climate change threaten water quality. The lake has been on Washington's impaired waters list due to excess phosphorus, which can cause harmful algae blooms. Three jurisdictions - Whatcom County, City of Bellingham, and Lake Whatcom Water & Sewer District - coordinate management efforts through a formal cooperative program with 5-year work plans. The current challenge is that most of the watershed (about 70%) is in unincorporated county jurisdiction, but the city has more aggressive water quality regulations and dedicated funding sources. This creates coordination challenges and questions about whether regulations should be made more consistent across jurisdictions. Recent wildfire threats and invasive species discoveries in nearby waters have added new urgency to protection efforts, requiring rapid response planning and cross-training between agencies. ### What Happened — The Short Version Council Member Anderson opened with detailed questions about coordination between jurisdictions, particularly around inspection and enforcement of stormwater systems and boat launch monitoring for invasive species. Staff provided updates on the homeowner incentive program, showing the city has worked with 180 property owners to remove over 1 million square feet of lawn, while the county worked with 56 property owners on 195,000 square feet. The discussion then shifted to wildfire preparedness, with Anderson expressing concerns about fire retardant use in the watershed and cross-training needs. Staff confirmed DNR has agreed not to use fire retardant in the Lake Whatcom watershed and that wildfire response planning is underway. Budget challenges emerged as a key theme, with officials discussing the need for dedicated revenue sources and noting that land acquisition costs continue rising while invasive species threats require more monitoring and rapid response capabilities. The major presentation covered differences in land use regulations between city and county, highlighting that the county allows 25% more phosphorus runoff (0.1875 vs 0.15 pounds per acre per year) and has different enforcement mechanisms. A clear-cut photo sparked discussion about gaps in private forestry regulation. ### What to Watch Next • Mid-biennium budget discussions will determine resources for analyzing and potentially aligning city-county development codes • Forest management plan draft expected in August 2025 • Lake Whatcom Policy Group meetings may expand scope to more active policy development rather than just updates • Comprehensive plan updates in fall 2025 may address watershed protection and growth allocation issues ---

## MODULE S2: FLASH CARDS **Meeting ID:** WHA-CON-2025-06-04 **Q:** What percentage of the Lake Whatcom watershed is in county jurisdiction versus city jurisdiction? **A:** About 70% of the watershed is in unincorporated county jurisdiction, while the city's jurisdiction covers a much smaller portion of the overall watershed. **Q:** What are the different phosphorus loading limits between city and county regulations? **A:** City of Bellingham requires 0.15 pounds per acre per year (forested condition), while Whatcom County allows 0.1875 pounds per acre per year - 25% more phosphorus runoff. **Q:** How many property owners has the city's homeowner incentive program worked with in the last 5-year work plan? **A:** 180 property owners on just over 200 projects, removing over 1 million square feet of lawn and replacing it with native landscaping. **Q:** How many property owners has the county's program worked with during the same period? **A:** 56 property owners, enhancing 195,000 square feet of area with improved landscaping and runoff management. **Q:** What is the Lake Whatcom Policy Group? **A:** A smaller working group with representatives from county council, city council, and water district that meets regularly to coordinate policy discussions and lake management efforts. **Q:** When was the major down-zoning of the Lake Whatcom watershed completed? **A:** 2002, when the county down-zoned the watershed to R5A (1 house per 5 acres), removing 1,800 potential development units after months of emergency moratoriums and late-night hearings. **Q:** What additional density reduction occurred in Sudden Valley? **A:** In the mid-1990s, Sudden Valley Community Association implemented a density reduction program removing 1,400 lots from development potential, keeping them in open space. **Q:** What is DNR's policy on fire retardant use in the Lake Whatcom watershed? **A:** DNR has Lake Whatcom on their "do not use retardant" list, meaning fire retardant would not be used in the watershed during firefighting operations. **Q:** What three invasive mussel species is the rapid response plan designed to address? **A:** Zebra mussels, golden mussels, and faga mussels - all of which could severely impact drinking water infrastructure and natural ecosystems. **Q:** How many acres will the joint forest management plan cover? **A:** 13,000 acres across City of Bellingham's Lake Whatcom land acquisition program land and Whatcom County park land within the watershed. **Q:** What is the construction/seasonal closure window when land disturbance is restricted? **A:** October 1st to May 31st - both city and county have the same seasonal restrictions to prevent erosion during wet months. **Q:** When did the city adopt its Lake Whatcom Reservoir regulatory chapter? **A:** 2001, creating dedicated and specific development regulations for the watershed (often called the "Silver Beach Ordinance"). **Q:** What happens when someone exceeds 300 square feet of new development in Bellingham? **A:** The entire property must be retrofitted to meet the 0.15 phosphorus loading limit, not just the new addition. **Q:** Who is taking over as main point of contact for the Lake Whatcom Management Program? **A:** Jason Porter, supported by Mike DeParoskin and Morgan Ruff, as Renee Swenson retired in June 2025 after years managing the program. **Q:** What Senate bill could potentially increase housing density in watershed areas? **A:** Senate Bill 5471, which addresses middle housing and could allow up to 4 units per lot in LAMIRDs (Limited Areas of More Intensive Rural Development), though county has discretion to implement. **Q:** When do gates at boat launches become more actively enforced? **A:** Starting in fall when seasonal aquatic invasive species inspectors are no longer stationed there - people with permits can call to have gates opened. **Q:** What is "full dispersion" versus engineered stormwater systems? **A:** Full dispersion uses 65% of property in native vegetation as natural treatment (common on large lots), while engineered systems are built treatment facilities. **Q:** What was the timeline given for the climate vulnerability assessment? **A:** RFP expected by end of 2025, consultant hired, with formal work launching in 2026 to assess climate threats to lake systems. **Q:** Where can the public sign up for forest tours and provide input? **A:** The Engage Bellingham webpage, with tours scheduled for June 18th and July 16th, 2025. **Q:** What is the major gap in forestry regulation within the watershed? **A:** Private commercial forestry is only subject to statewide forest practice rules, not the stricter watershed protection standards that apply to DNR lands or development projects. ---