This is an email I received from Director Cami Apfelbeck, answering my questions at 6:00 this morning. Very much NOT a slacker, Dir. Apfelbeck. My original questions are in italic, for your reading pleasure. As of 12:45pm, I’ve reviewed it after 3 readings. My comments are in bold italic, following Cami’s responses.

“Good morning, Anna: Here are the responses to your questions. Kind regards,

1) How does clear-cutting 20.3 ac of 70-year-old trees, directly above the reservoir, contribute to the stated goal: “To maintain the units in a sustainable productive forest while providing for water quality, fish and wildlife habitat”? The current stand of forest in the Union River Watershed is the product of natural re-growth after the complete loss due to fire in the 1930’s. This resulted in single-species dominance (predominantly Douglas Fir) w/relatively little species diversity. Further, the trees are predominantly the same age, and spreading pockets of Laminar Root Rot have been identified. These factors make the forest particularly vulnerable to climate change and less resilient to fire.

Careful, focused units of harvest allows for the diversification of species, age, and habitat and the removal/control of disease. Thinning further reduces competition and allows for healthy, robust growth, leading to healthier habitat. Overall, this promotes a healthier more resilient forest.

Any harvest activity in the watershed is provided special oversight and scrutiny and conditioned with operational constraints and environmental protections that exceed those required by the Forest Practices Act and Forest Practices Application.

Laminated Root Rot, per the US Forest Service, “is nearly ubiquitous throughout most Douglas-fir and grand fir forests in Oregon and Washington”. … “Douglas-fir, mountain hemlock, grand fir, and white fir are often killed. Other tree species vary in susceptibility and degree of tolerance (Table.fid-2). Hardwoods are immune.” … “Once infected trees die, the fungus continues to live on-site as a saprophyte in small roots for 8 years or more, and in large stumps and large roots for as long as 50 years.” … “Laminated root rot usually intensifies when infection centers and adjacent areas are regenerated with highly susceptible species.” … “Ground fire severity may increase as a result of the abundant down wood in infection areas. On recreational and administrative sites, forest work sites, and along roadsides, trees with laminated root rot have a high potential for failure and can present a significant safety hazard.” https://apps.fs.usda.gov/r6_decaid/views/laminated_root_rot.html

In short, it’s everywhere, it provides great wildlife habitat, and replanting to Doug fir, as called for in the FPA, will actually intensify it. Canopy cover opens up as trees fall down, creating areas perfect for replanting to hardwood natives like big-leaf maple, red alder, etc.

2)  Item #19, p. 5 of 9 in the Forest Plan, calls for harvest of 97% of the area (i.e., clear-cut), with a yield of 480 mbf (thousand board feet) — please clarify. The presentation of this contract to Council called for removal of 2.4M (million board feet) per year, the figure I used in previous correspondence. I apologize for the confusion here. The agenda bill background information section is intended to give the Council and the public a summary of the overall program and how the particular consultant was selected. Specifics about the contract are detailed in the contract itself. EXHIBIT B Fee Schedule explicitly states “The City of Bremerton does not warrant or guarantee any specific level of harvest or income with this agreement. Harvest levels, if any are entirely the decision of the City of Bremerton.”

The sustainable harvest level was calculated to be, on average, 2.5 million board feet per year. However, this is not the driver that dictates the level of harvest that occurs each year (though it does set an upper limit on average to ensure that we are protecting sustainability). Other criteria determine where, when, and how much.  Harvest levels (particularly, since 2010) have been significantly less. My presentation tonight will dive a little deeper into the selection criteria and harvest statistics.

The harvest level specified in the FPA is 97%. I look forward to your presentation tonight.

3) The contract was described as being with Lusignan Forestry, who have performed this work for 11 years. The final page of the Forest Plan, Notice of Transfer of Forest Practices Application/Notification. is signed by Eric Hurd, dba Hood Canal Logging. Please explain the discrepancy. Hood Canal Logging is Lusignan’s subcontracted harvester.

4) May I conclude that the Forest Plan comprises all of Forestry’s directions to Lusignan? Because I requested Forestry’s directions to Lusignan on what, where, when, and how to cut, and was sent the Forest Plan. A copy of the Forest Practices Application (FPA) for harvest unit Inside 55 was provided as an example of the directives to Lusignan specifically in regards to harvest activity. Lusignan must conduct activities explicitly in compliance with the approved FPA. Depending upon the particular unit (for example, any unit within the Union River Watershed), the City gives additional directives regarding operational constraints and environmental protective measures above and beyond what is required and reflected in the FPA. These directives are delivered and discussed at an initial meeting with Lusignan (and any subcontractors) once the FPA is approved and prior to any activity.  Each harvest unit has its own FPA, so these directives will vary for each unit. The City supervises activities in progress and may choose to submit an amendment to the FPA and/or provide additional directives depending upon the circumstances. Directives regarding other contractual obligations such as communications, invoicing and reporting are detailed in the contract.

Please provide an example of these additional directives.

5) On p 11 of the Forest Plan, the Forest Practice Activity Map shows a stream, per the map legend and per the icon depicting a stream crossing. The stream is water-typed A: Ns (non-fish seasonal stream) Does this rainy season stream feed the reservoir? Yes. This is a seasonal stream that has not been identified in state mapping and, therefore, not required to be addressed by the FPA. However, the City identified the drainage course as part of the pre-application site inspection/survey and chooses to include it. Further, as is standard practice with any activity in the watershed, the City voluntarily imposes additional protections (sediment and erosion control, buffers, etc.) to ensure protection of the drinking water. These measures have been proven effective during previous harvest of this unit with no impacts to the reservoir.

The previous harvest of this unit was done over 120 years ago, was it not? Since you stated that the unit was leveled by fire in the 1930s. The climate and surrounding use have changed dramatically since then.

6) This is a ten-year statement of intent — what are future plans for similar timber harvest? Each timber harvest unit will have its own FPA with associated 10-year statement of intent. This is DNR’s insurance that each unit will be reforested.

As far as comprehensive policy governing utility land and forest management, that conversation will begin in 2022 with the update to the Utility Land Management Planand the Forest Land Management Plan. In keeping with past practice, this will be a public process soliciting public  comment and input and ultimately going to the Council for Council acceptance.

7) The Forest Plan reports numerous trees >32”dbh, with others measured as >42”dbh. Since no survey was conducted, per this document, were these particularly large trees accessible from the network of roads? You are referring to information provided in the Marbled Murrelet Form. To clarify, the “survey” to which this form refers, is a detailed survey required if the initial harvest area inspection/survey by the City identifies qualifying Marbled Murrelet habitat. As our initial survey did not identify qualifying habitat, we were not required to conduct the detailed survey. However, we are required to provide the general stand conditions including species, age, and max size identified in our initial survey. The initial harvest inspection/surveys are conducted on foot, so these trees were identified and measured as part of that survey.

8) Since no survey was done, how was it determined that planting exclusively Doug fir would replicate the diversity of existing forest, upon which a diversity of wildlife habitat depends? Again, the City does conduct an initial site inspection/survey to identify unit characteristics. As it is predominantly Douglas Fir at this time, it is known that reforestation will include Douglas Fir and so it is listed in the FPA. However, the City can and does go “above and beyond” FPA requirements, including reforestation with additional species. By not explicitly stating additional species, it allows us the flexibility to select based upon conditions discovered on site during the harvest. For example, if areas of root rot are discovered, we would not replant Douglas Fir in those areas. Rather, we would select a species less vulnerable to root rot and more specifically tailored to the soil conditions onsite.

That makes sense, given the USFS findings on laminated root rot. Not that reading one article makes me an expert! In my permit applications, I’d typically include a species list from which final plantings would be chosen. Is that not possible with WA-DNR?

9) The Scope of Work appears to state that the City pays L&I for Lusignan Forestry employees, which is about the highest L&I rate there is. Can you tell me what this L&I is projected to cost for this contract? The City does not provide insurance to contractors/consultants. It is explicitly written in Section VI that the consultant/contractor must procure and maintain all insurance and provide proof of said insurance.  The only reference to insurance in the Scope of Work that I can see refers to the Loggers Broad Form insurance coverage required to be carried by any subcontractors. It is required that the City be named as an additional insured party to provide protection to the City from any work done by subcontractors to the consultant, but the City does not pay for that insurance.”

My bad. Sorry about that.

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Cami ApfelbeckCity of Bremerton, Public Works & UtilitiesWater Utility and Forestry Manager(360) 473-2315 (office)/ (360) 509-0746 (mobile) Cami.Apfelbeck@ci.bremerton.wa.us