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Virginia: As we noted in the discussion on Tennessee BMP compliance, we do not see how these reported levels of implementation could be characterized as "broad application". The emphasis on the high percentage of "efforts to implement" BMPs belies the poor overall performance of the BMPs in actually protecting water quality. Of particular concern is the fact that 80% of the sites visited did not have the requisite water quality BMPs adequately installed, and at over two-thirds of the already inadequate sites the "efforts" were such that they "lacked sufficient water control structures or had water control structures installed that did not meet DOF standards." Also, the failure of adequate SMZs at almost one-third of the sites visited is troubling because of their critical importance to maintaining healthy instream environmental conditions. -- Draft Report
See above comment. -- Final Report
Tennessee: Regarding the discussion in Section 5.4 and BMP compliance: In the first place, we do not see how these reported levels of implementation could be characterized as "broad application" of BMPs. More importantly, we do not believe that such reports could have been accepted as evidence of actual widespread BMP implementation or widespread protection of streams from the impacts of timber cutting and removal. -- Draft Report
See above comment. -- Final Report
In the absence of strong monitoring programs, an accurate determination of BMP compliance rates is impossible. Due to the serious weaknesses in state BMP monitoring programs across the region, state BMP compliance reports are likely inadequate and, in fact, seriously overstate forestry BMP compliance. -- Draft Report
In Section 5.4, we limit our discussion to describing the variety of implementation monitoring approaches employed in southern states , their history and their status. No modifications were made in response to this comment. -- Final Report
Wetlands issues are largely ignored in this chapter. Given the discussion about wetlands losses in Aqua-2 (particularly in Arkansas, Georgia, Louisians), that issue should have been addressed here. No mention is made of the 15 BMPs for wetlands and the regulatory framework that make activities that change wetlands to uplands illegal. -- Draft Report
As pointed out by the commentor, there is another Chapter devoted to wetland discussions. Section 5.4 references the 15 mandatory BMPs and states, "There are also 15 mandatory Federal BMPs, or conditions, required in all states for exemption of certain silvicultural activities conducted in waters of the United States. See Chapter Socio-3 for a more thorough discussion of Section 404(f), of the CWA. -- Final Report
In 5.2 Other Benefits:There are two periods at the end of the section. -- Draft Report
Correction noted. -- Final Report
In 5.4.1 on BMP monitoring: In Oklahoma, you could say that we are conducting our first sampling since the late 1970s. Oklahoma completed a BMP monitoring program in 1977-78 after we first started our water quality program. -- Draft Report
We have received no information or documentation of any kind regarding 1977-1978 BMP monitoring, thus the suggested modification was not made. -- Final Report
What have been the trends in forest diversity and soil health on lands subjected to so called BMPs and the majority of lands where they are not used? How have BMPs promoted forest health and resiliency, soil building, and soil ecosystem health? -- Draft Report
As noted in the Chapter, the purpose of BMPs is water quality protection, and the scope of this Chapter was to look at BMPs in relation to water quality. Information requested in the comment, while important, is outside the scope of the Chapter, however, the third Research Need listed suggests a need to determine other benefits of BMPs. -- Final Report
The Sustainable Forestry Initiative program requirements on implementation of BMPs and logger training have contributed broadly to the overall use and effectiveness of BMPs throughout the region. This is a significant fact that should be acknowledged in the report. -- Draft Report
References had already been made to SFI in Sections 5.4 and 5.5. No additional acknowledgements were added. -- Final Report
Section 6 notes: "Resource benefits provided by BMPs other than water-quality protection should be studied and documented." This is a critical need for additional syntheses. It also states "Reasons that landowners comply or do not comply with BMPs are not well understood. Additional information of this kind would be useful for targeting outreach efforts and adjusting state programs." This statement is not forceful enough; this information is "critical" if water quality and biodiversity are going to be protected in the areas of the southern forest identified as stressed, threatened, and endangered. We believe that the SFRA must include a more robust examination of the nonregulatory and regulatory forest practice programs we have identified in our comments (see comment letter #35). -- Draft Report
By virtue of the referenced statements' inclusion in Section 6, we agree that these research needs are important. A sentence was added to the first statement that notes that better landowner understanding of other benefits of BMPs may increase their committment to BMPs. -- Final Report
Analysis of regulatory versus nonregulatory approaches in Section 5.5 contains several broad observations that are misleading without additional fine detail on the problematic nature of compliance with nonregulatory BMPs. Moreover, this section omits any substantive discussion of silvicultural regulatory programs, such as those of California, Oregon, and Washington. Those programs should be described in order that there is some standard of comparison of the advantages and disadvantages of both types of programs. -- Draft Report
A brief discussion of two reports comparing voluntary and regulatory forestry programs has been added in Section 5.5. Some additional discussion was added regarding typical regulatory programs, but description of non-southern states' regulatory programs was not added. Focus is on comparing effectiveness of approaches for protecting water quality, not characteristics of the programs themselves. -- Final Report
The assertion in Section 5.4 on BMP implementation in southern states on very flimsy evidence that "State reports indicate broad application of BMPs during forestry operations in the South" justifies the conclusion that their implementation is widespread in the south is a major error in the report. The major problem with forestry BMP programs in the south is that with several exceptions, they are voluntary. -- Draft Report
The Section has been modified to remove the word "broad" . It has been replaced by a statement that BMPs are being implemented in all states in the South, and that the 5 states that have monitored and reported implementation in comparable manners report from 63% to 96% implementation. This provides more factual information. -- Final Report
Key Finding 3 states BMPs are designed to reduce nonpoint source pollution and maintain stream channel integrity so that State water quality standards are met...quote: "Where their effectiveness has been evaluated, they have achieved that goal." The analysis of voluntary BMP implementation by various environmental groups tends to dispute the contention that the effectiveness of BMPs achieving the goal of water quality protection has been widely evaluated. -- Draft Report
BMP implementation monitoring and effectiveness monitoring serve different purposes. Implementation monitoring addresses whether BMPs have been implemented as designed. Effectiveness monitoring addresses whether BMPs are effective at performing the function they are designed to perform. No change in the Key finding was made. -- Final Report
In Aqua-4, on page 11, seven states that have completed more than one comprehensive BMP monitoring survey are listed, and South Carolina is not included in this list. South Carolina has been very aggressive in monitoring BMP implementation, and should be included in this list. To date, we have published results from four harvest monitoring and two site preparation monitoring surveys. -- Draft Report
The sentence immediately following the one referenced by the commentor is one addressing South Carolina, and states, "South Carolina has completed four harvesting and BMP surveys and two site-preparation BMP surveys." Comprehensive monitoring surveys, for the purposes of this Chapter, addressed multiple categories of activities statewide. A sentence has been added immediately following to emphasize the aggressiveness of their program. -- Final Report
Section 6: This section inadequately adresses the role professional foresters play in present current information about BMPs and ensuring that private landowners successfully implement BMPs. -- Draft Report
A Key Finding in this Chapter already states, "Professional forestry assistance increases the likelihood that BMPs will be properly implemented.", and a statement at the end of the individual State implementation summaries states, " … forest management operations that involve advice and oversight by forestry professionals exhibit higher BMP implementation rates than operations not having that involvement.". No modifications were made. -- Final Report
To make the SFRA more accurate, I would suggest making the following addition at the end of the first paragraph on page 12 of chapter Aqua-4: "For example, South Carolina's longstanding BMP monitoring progam fully meets the intent of the SGSF protocols while allowing for a unique, nontraditional approach that emphasizes the identification of water quality impacts on monitored sites rather than just reporting BMP implementation." -- Draft Report
While not making the suggested changes as quoted, additional discussion on SC monitoring has been added where suggested. -- Final Report
In Section 5.4 reference is made to the BMP implementation monitoring procedures recommended by the SGSF in 1997. Six states are reported to have redesigned their programs to incorporate these recommendations. South Carolina is not among the states listed. I feel South Carolina not only meets the intent of this protocol, but exceeds it in several ways. I ask that you review the attached document that directly compares the SCFC procedure for BMP monitoring to the SGSF protocol.(see attachment to comment letter #31) -- Draft Report
Revisions in section 5.4 discuss the similarities of the SC program and the SGSF 1997 recommendations. While much of the same information is collected, results are reported differently and are not directly comparable to other states. -- Final Report
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