Public Inputs on Preliminary Question AQUA-1605

assessment of sustainability of our forests

Southern Forest Resource Assessment

Below is the original wording of one of the preliminary questions and public suggestions or concerns submitted about it--for details see our Public Input or Methods pages

"What is the history, status, and likely future of aquatic habitats and species in the South?"

What is the percentage of sedimentation problems in the region due to logging? What are the ecological and economic costs of increased silt?
Would these costs be mitigated by increased compliance with Best Management Practices?
Of critical concern is that BMP's have not been well monitored or followed.
Increased cutting and poor adherence to Best Management Practices has led to increased siltation.
The Assessment should recognize the role BMPs have played in defining Streamside Management Zones (SMZs) and resulting high water quality in managed forests.
In evaluating the implementation rates and effectiveness of BMPs in the South, the Assessment should note in which states BMPs are regulated by law and in which they are voluntary. Implementation rates and effectiveness of BMPs should be evaluated and reported by state, not in aggregate. Evaluation procedures of BMP implementation rates and effectiveness should be in accordance with those of the overseeing body or agency within each state.
The BMP's do not work because the very veins of streams, the ephemeral streams, are not protected and BMP's are voluntary and not mandatory. There is no law enforcement presence to make sure that BMP's are followed and loggers rationalize they have to log riparian zones or some other logger will do so and will not log as well in these areas as they will.
BMP's are a failure. Voluntary programs do not work. We need regulations with teeth.
The TFS will tell you they are very high. But their program is inadequate. Their sample is not large enough to provide an accurate picture of how well BMP's are being implemented. We are not impressed with the Texas, voluntary, BMP program.
Please look also at the effectiveness of Best Management Practices. In my neck of the woods, I can't see that they are working. What must we do to put teeth in them? They should be mandatory, not optional. If we stiffen and enforce the punishment for BMPs, and enforce the Endangered Species Act, there would be habitat, and less ditching of wetlands, for example. And wouldn't BMPs be more effective if we required rules like the 30-foot stream buffer, but made a practice like single tree selection (where you harvest individual trees over decades instead of clearcutting the entire forest and thus destroying it) the optional management practice to shoot for?
Analysis of the need for region-wide uniformity of compliance of Best Management Practices (BMPs); not excluding recommendation of complete change of this 'voluntary' policy that often does not adequately protect riparian systems before the fact.
Is there a significant difference in water quality between States/Counties with required BMP's versus those where BMP's are voluntary?
Develop BMP's for herp conservation (with focus on agricultural lands, vernal pools, subdivision/residential areas and road construction).
BMP's. Ultimate goal is to prevent erosion. Of the total land use within the south, what is the percentage of sedimentation from the urban settings, streets and highways, new home and shopping center developments, agricultural, and forest? What is the cost benefit ratio between clean up or correctional costs and regulated enforcement expense for each of the above.
Assessment should document the high water quality produced for forested watersheds that are actively managed with high rates of BMP implementation by the forest industry and forest landowners. The effectiveness of BMPs in protecting water quality should also be documented using the results of state forestry or environmental agency BMP assessments.
The Report should point out that the state forestry agencies have had the primary responsibility for promotion, education, and implementation of state best management practices. The role of states in addressing private forestland management, particularly in regards to water quality, should be documented and recognized.
But I want to know if there exists a region-wide attempt to educate landowners to protect our watersheds; any attempts that have teeth? How many counties lack effective policies and staff to do the job? Should such protection be mandatory? We certainly know the data in VA reflects the voluntary BMPs are a joke.
We are also interested in the success of Best Management Practices (BMPs) in controlling siltation in forested wetlands and in upland streamside management zones. State BMPs should be evaluated for their effectiveness in protecting freshwater mussels, limiting logging damage to natural regeneration, and discouraging high-grading.
Decrease sedimentation loading in streams and rivers.
What is the implementation rate and effectiveness of BMP in promoting ecological sustainability of riparian and wetland systems?
Forest industry and landowners implement BMPs at a high compliance rate and the study should document the results of state assessment reports.
Assessment should document the high water quality produced from forested watersheds that are actively managed with high rates of BMP implementation by the forest industry and forest landowners. The effectiveness of BMPs in protecting water quality should also be documented using the results of state forestry or environmental agency BMP assessments.
The Assessment should query all southeastern states to best determine compliance rates with state BMPs. The result should be stratified by landowner type and timber purchaser.
Results of state forestry and environmental agencies assessments concerning BMPs and their effect on water quality should be used as part of the assessment. State Forestry Agencies throughout the South have the responsibility for overseeing BMP implementation. This role played by individual states should be documented and used in developing the final results for the assessment.
Please point out the important role that the state forestry agencies have had in the promotion, education, and implementation of state best management practices.
The study should look at localized effects under various demands with and without strict, enforceable Best Management Practices. It should look at localized effects when BMP's are not followed and compare the cost savings to the cost to the public in water pollution and soil loss.
The Report should point out that the state forestry agencies have had the primary responsibility for promotion, education, and implementation of state best management practices. The role of states in addressing private forestland management, particularly in regards to water quality, should be documented and recognized.
To what extend do scenarios such as this occur: Landowner put 160 acres of timber land up for bid to be clearcut, not requiring BMPs. Timber Company A successfully bids on tract and voluntarily implements BMPS, including a significant area of Streamside Management Zone, to their economic disadvantage. Afterwards, Landowner hires Logger to harvest Streamside Management Zone. Logger does not follow BMPs. How can this be addressed?
To what extend can it be verified that BMP implementation has directly contributed to reductions in non point source pollution with a resulting increase in water quality?
Blanket figures on compliance must have some substantive basis, and the methods for compiling them must be clear. For the federal study to be credible, it cannot accept bald or blanket assertions from state agencies or the timber industry about the extent to which BMPs are being implemented. The methods for arriving for any figures, and the limitations of such methods - indeed, whether they have any real value in assessment - must be openly discussed by the federal study.
In regard to reforestation efforts, it should be clearly stated whether standard BMPs incorporate ecological considerations.
What impact would mandatory BMP's with enforcement requirements, as opposed to voluntary BMP's with no enforcement, have on the forests of the Southeast?
Include methods of BMP implementation, where these are mandatory and effects of voluntary/regulatory BMPs on various indicators.
This is a very important issue warranting thorough evaluation; including compliance records, BMP models and their differential adequacy, and attitudes among public and forest user groups toward BMPs and their role in forest protection.
How many logging operation are using experts, consultants or technical assistance in planning and implementing a forest harvesting plan and how may are not? Re: water quality. What are the relative water quality impacts associated with planned or unplanned logging sites? Are voluntary BMPs sufficiently protecting water quality and sensitive species when used?
Is the existing number of forestry service personnel able to monitor the increased rate of harvesting that is occurring in the Southeast with regards to gross negligence of BMP's? Are the existing deterrents for gross negligence of BMP's by loggers sufficient or is it more cost effective for them to ignore BMP's and hope that they don't get caught and more economical for them just to pay the fine if they do?
The accuracy of state reporting regarding Best Management Practice (BMP) implementation. The methods, if any, of verifying the accuracy of self-reported compliance with BMPs, or determining the type and extent of compliance with BMPs in the absence of self-reporting. The effectiveness of BMPs in reducing erosion and preventing water quality degradation in local watersheds associated wit intensive timber harvest, particularly in light of the apparent conflict between state reported BMP compliance exceeding 90% and continuing evidence of ever increasing nonpoint source pollution throughout the Southeast. The existence of enforceable, versus voluntary BMPs, in Southeastern states and a comparison of the effect of BMP implementation in voluntary versus compulsory BMP states on levels of nonpoint source pollution in those states.
Are the state's BMPs protecting the various soil types of the region? Soil on recent and older forest harvest sites as well as non harvest sites should be studied and compared. Soil profiles should be collected and comparisons of compaction, available water capacity, water percolation and permeability, thickness of various layers including loam, erosion factors, pH, and productivity should be determined.
Are the State's voluntary BMP's adaquate to protect water quality in areas with steep slopes and erodable soil?
I'm concerned that pressure from environmental groups might cause the USFS to stop commercial timber sales. I've always view the FS a leader in hardwood timber management and providing on the job training for loggers in best management practices in the eastern mountains. If the FS is not there to set a good example, who will? Will we continue to improve as much as we have?
The Report should point out that the state forestry agencies have had the primary responsibility for promotion, education, and implementation of state best management practices. The role of states in addressing private forestland management, particularly in regards to water quality, should be documented and recognized.
Look at localized effects when Best Management Practices (BMP) are not followed and project increased damage with increased demand and harvest activity; compare the cost savings to a logger who doesn't follow BMPs to the cost to the public in water pollution, soil loss, and environmental services such as air quality, water filtration, and water quality and quantity.
Compare BMPs by watershed types or land use – forestry, agriculture, urban, etc.
In most areas BMP's are only voluntary so there are really no solid laws regulating how the logging will be done. State forestry personnel are already spread too thin to oversee the big increase in cutting. The relatively low price paid for wood cut for chipping does not allow for better timber management such as selective practices. At $5 a ton, everything gets cut and loaded on the truck as fast as possible.
I am appalled that Best Management practices are not mandatory. Yes, the forester can execute some power in making loggers adhere to certain regulations, but the reality is there are no good, solid, regulations, and often punishment is too little, too late. Quality of life is seriously diminished by destructive logging practices. This disregard could be largely eliminated by making Best Management Practices a way of life for all members of the timber industry.
Look at localized effects when Best Management Practices (BMP) are not followed and project increased damage with increased demand and harvesting.
What is the success rate of wetlands "mitigation" (panacea) measures? How much time does it take for a mitigated "wetland" to support the full spectrum of biological functioning as was provided by the displace native wetland? What level of forestry activity can be performed in a wetland before there is significant impact to the functioning or health of the wetland ecosystem.
How extensive are the BMP's being ignored especially on private land? WIth current over harvesting will the introduction of new markets, particullarly chip mills, mulitiply the rate of overharvesting?
Point out limitations of current research on BMP effectiveness monitoring.
Can you correlate water quality conditions, BMP implementation, and status of research?
Explore good things that have been accomplished by state non-point source agencies in protecting water quality in partnership with forestry community.
Tie-in weather database from EPA and relate it to climatic regimes.
How do you define “implementation rates”? (94% implementation means what)? Clarify difference in implementation versus compliance since this varies state by state agency.
Use of implementation rates is invalid since it perpetuates a less scientific approach to BMP monitoring. Suggest use of compliance versus implementation.
Implementation rates are relative over time, so keep this measure in order to not lose BMP information, even if you cannot directly link implementation rates to water quality parameters. It does offer a measure of program success and promotes watershed partnerships between timber industry, state and federal agencies.
Water quality parameters such as TSS are setup in non-forested watershed. We need data for forested wetlands.
Define what is normal for water quality parameters and relate to water quality standards. How do you consider agricultural runoff, non-forest road construction, and other activities when discussing sustainable forestry?
Are there mechanisms in place to address poor practices (=bad actors) that result in water quality degradation? Who, what when and where?
ADD question: “What landowners incentives exist (or where do you get information on incentives) for implementing forestry BMPs”? Address financial incentives, peer pressure, conservation group/state/federal partnership programs, etc.
High BMP compliance rate in FL 85 %; good training -master loggers certification. FL BMP study done.
Good BMPs provide good protection of the wetland system - (FL exp).
Better BMP implementation, better self policing - greater education & awareness.
BMPs are not really voluntary, but regulatory via the WQ criteria. GA Pacific has good info. (NASA conversion study/analysis information?)
Greater public education - difference in attitude between resident & absentee landowner.
Cost/ benefit of successful BMPs vs. cost of WQ/stream cleanup.
State by state differences in BMP's - logger may need to know differences - FL/GA reciprocity cross state training.
GA Pacific believes that BMPs should be tailored to terrain, soil and eco-regions etc.
Assess the sufficiency of current or proposed BMP’s on paper as written prior to studying implementation.
Assess all of the costs to the public when BMP’s aren’t followed, with regard to water degradation.
Assess the usefulness of education programs for BMP’s implementation rates.
Evaluate implementation differences between states that require BMP’s vs. those that support voluntary BMP’s.
Address the differences in each state’s BMP’s, and evaluate their effectiveness.
What is actual NPS pollutant loading from forestry to non-forestry? BMPs to no BMPS?
Perception is there is low BMP implementation in MS, i.e., logging up to the stream (on private lands). Not consistent across land ownerships.
Incentives to encourage BMP implementation.
Actual BMP implementation is relatively low despite implementation reports.
Implementation rates now fairly well documented. It is time now to document and/or BMP effectiveness on protecting water quality.
Education about and expanded use of NPS BMP implementation, not just forestry.
Acknowledge progress in forestry BMP implementation.
Validity of the literature review on BMP effectiveness; would really like to see bibliography.
Would like to preview work in progress, to review any models, to review any data.
Effectiveness of BMPs on private/government/corporate lands. Assess cost of BMPs.
Why are attitudes different from one landowner type to another?
How will water quality be measured? Compare source of contaminants? Impact from roads?
The Neuse Rule in North Carolina may not be able to affect this study, but it may in the future provide good data on implementation rates. (Previously, BMPs were voluntary; with passage of rule, they've become essentially mandatory). It may also show what is more acceptable to the various landowners. This Rule doesn’t much affect forestry, but may give data that can be extrapolated.
Compare legal requirements by states.
Start with published reports on BMP implementation by states.
How are BMP requirements being enforced by each state?
Document the effectiveness of BMPs as enforced by the states.
Document the existence of and effective of BMP training program for getting them “on the ground”.
Compare and contrast BMPs for other land uses. Implementation and effectiveness
What are costs and benefits of mandatory BMPs? Prior notification of timber sales? How does prior notification affect BMP compliance?
List of BMPs by state and Nationwide.
What are costs to individual landowner, loggers, and timber buyers -- to implement BMPs?
What are pros and cons of the voluntary nature of BMPs in South?
BMPs effectiveness study available for FL.
BMPs - not just sediment load also- temp. carbon. Is the 35-foot buffer adequate?
Need to exam the BMP implementation rate, Raburn Co. BMP Study. Exam specific elements and not just the average compliance.
How are BMP ratings made - better consistency among states - FL, AL, GA.
Buffer requirements under BMPs are not adequate to protect the eco-functions in some instances.
Acknowledge work by forestry in achieving high quality water through use of BMP.
How are state incentive programs working for BMPs?
How will this study impact industry compliance with the Clean Water Act?
Who enforces existing/current regulations? How do they enforce? Can they effectively enforce and who pays for it?
What is effectiveness of mitigation practices?
Compare watershed conditions with and without BMPs.
Conduct a comprehensive literature search on BMP compliance and water quality impacts.
What is the difference in effectiveness between voluntary BMPs and mandatory BMPs?
Does the timber harvester have any economic benefit from ignoring BMPs and how could this affect the productivity of the land?
How are BMPs developed and updated?
Need to compare the effectiveness of BMPs along physiographic lines - soil types, vegetation types, slopes, etc.
One person suggested using data from the National Council for Air and Stream Improvements - specifically have data that compares voluntary vs. mandatory BMPs.
How effective is the USFS in utilizing BMPs to protect water quality?
Federal managers (USFS) “teach” achieving good water quality through BMPs, but seemingly not with private lands. Need to have more educational efforts to reach private landowners about BMPs and good water quality.
How has water quality progressed since BMP implementation?
BMP's - Frank Green - Athens Data (EPA?) show forested watersheds better than non-forested.

Question as revised in response to these comments
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modified: 1-MAR-2000
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