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This type of data aggregation [use of FIA data at 8-Digit HUC] does not result in the statistical level of confidence necessary for the type of projections needed, or to "see" the types of water quality degradation resulting from timber cutting and removal, which typically occur at the stream reach and subwatershed level. The use of more "real world" data sources that can "see" these impacts, such as a satellite-data based approach, should be discussed in this paper. -- Draft Report
The author agrees with this comment. The lack of statistically reliable results using FIA and IWI data was noted in the Chapter. However, a comparison of the various methods of analyzing land-use change (e.g., plot-based, aerial photography, satellite imagery) is outside the scope of the intent of AQUA-1. However, the small area forestry demonstration project report for the southern Cumberland Plateau of Tennessee identified a number of the data sources mentioned by the commentor and contains a comprehensive analysis of several techniques that can be utilized to assess land use change at various scales. No modification is required. -- Final Report
During final review of the draft Chapter, a few calculation errors were identified in the various spreadsheets used to identify the leading sources of impairment of rivers and stream in Southern States. This affected some of the numbers and percentages contained in Table 4 and Figures 1, 2, and 3. In addition, "channelization" was removed as a separate "major source" of pollution from Tables 2, 3, and 4 and Figures 1 and 3, as it was determined that the impaired river miles attributed to "channelization" were already included in the major source "hydrologic/habitat modification". -- Draft Report
The calculation errors were corrected and Tables 2, 3, and 4 and Figures 1, 2, and 3 were changed to reflect the new numbers. -- Final Report
In its discussion of "Incentive and Stewardship Programs" in Section 5.4.5, the study mentions the AFPA's SFI certification program, the USFS Stewardship Program, and the Stewardship Incentive Program. However, the discussion fails to mention the Forest Stewardship Council (FSC) certification program and contains no analysis of the differences between these various programs. -- Draft Report
A discussion of the Forest Stewardship Council certification program will be included in Section 5.4.5. An analysis of the differences between these various programs is outside the scope of the intent of AQUA-1. -- Final Report
In general the Aqua reports are informative and well written. However, the region-wide, broad-brush approach limits their utility to decisionmakers and the public interested in specific local and subregional issues on the ground. It also limits their usefulness in determining the "small areas" that are by design the second tier of the SFRA study. This shortcoming needs to be corrected in the final study if it is to fulfill its stated objectives. -- Draft Report
Water quality information was presented in AQUA-1 at several different scales, the smallest of which was at the 8-Digit HUC (avg. size in the South of ~810,000 acres). Given the time and content constraints on analysis for SFRA, it was not possible to include comprehensive water quality information at smaller scales (e.g., individual stream reaches) for all 13 states. However, it is entirely possible to review and overlay the watershed information (Figures 4 & 5) with other information contained in the SFRA report to assist in determining appropriate "small areas" for additional study. No modification is required. -- Final Report
The report (p. 24) misstates EPA's authority with respect to TMDLs under section 303(d) of the Clean Water Act. Section 303(d) assigns the responsibility to prepare the TMDL to the state. If a state does not do so, then section 303(d) directs EPA to step in and prepare the TMDL. -- Draft Report
Section 5.4.3 will be rewritten to reflect appropriate Clean Water Act and EPA authority. -- Final Report
A major effort needs to be made to synthesize cumulative water quality impacts of all "major" sources of water quality [degradation] at the stream reach and watershed level. Analysis of the water quality effects of timber cutting and removal needs to be at the reach and subwatershed level. It should be pointed out that the level of detail in the EPA Index of Watershed Indicators is too coarse to produce significant analytical results. -- Draft Report
Given the time and content constraints on analysis for SFRA, it was not possible to include cumulative water quality information at smaller scales (e.g., individual stream reaches) for all 13 states. In addition, consistent delineation of sub-watershed boundaries has not occurred for all 13 states. It should be noted that the EPA Index of Watershed Indicators and State Unified Watershed Assessments attempt to synthesize a number of individual data layers into a single, consistent "cumulative" index that represents the overall condition and vulnerability of watersheds. As stated previously, it is entirely possible to review and overlay this watershed information with other information contained in the SFRA report to assist in determining appropriate "small areas" for additional study. No modification is required. -- Final Report
This discussion inaccurately minimized the effects of cutting and removing timber. The point is not that silviculture is only number 10 out of 11 "major" sources of water quality degradation but that it is one of the top 10 causes and operates cumulatively with most of the other 10 in contributing sediment, nutrients and toxic chemicals to the south's waterways. This is a case of "editorializing" in what should be a scientific study. -- Draft Report
Chapters AQUA-1 and AQUA-3 (and key findings included in the Summary Report) provide a balanced reporting of the technical information that was compiled to address both questions. The report appropriately identifies silviculture as a "major" source of water quality impairment in the South (~3,600 miles of rivers and streams as impaired by silviculture), but also appropriately provides the context of impairment to rivers and streams when compared with other land uses [originally written as 10th out of 11 major sources (rewritten as 9th out of 10 after edits to AQUA-1) over the time analyzed]. Presentation of the information in this manner did not constitute "editorializing." No modification is required. -- Final Report
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