### Date: June 6, 2016

To: Prasad Chumble, OWM, U.S. EPA

From: Peter Sherman and Kelly Meadows, Tetra Tech Inc.

Re: Updated Summary of State Forest Road BMP Program Information

Table A

- 1 below presents a summary of state program BMPs for forest road management. This table was adapted from two similar

table s in GLEC/ Endicott (2008)

, 1 

### additional state program research conducted during 2014, and a May 2016 update of the data based

on information co llected from two sources : The National Association of State Foresters’ ( NASF ’s) 201 3 survey of the state forest best

management practices accessed through the NASF’s 2015 website ( http://www.stateforesters.org/action

- issues

- and

- policy/state

forestry

- BMPs

- map

- o

- o ) and NCASI’s Compendium of Forestry Best Management Practices for Controlling Nonpoint Source

Pollution in North America (NCASI 2009). Th e 2016 update was not intended to constitute new, comprehensive state program

research, but to add available information (i.e., update) to the draft table since the GLEC document was developed in 2008

.

Please note the following with regard to Table A

- 1:

 Progra m type is based on NASF 2013 survey information. 2



###  State BMP provision s range from comprehensive to minimal . A n X in the table indicates that a state has some level of BMP in

the relevant category.

 Monitoring information has been carried forward from GLEC 2008 and interim work. In addition, more recent NASF survey

info rmation has been added.

 The two source documents for the 2016 update generally did not address enforcement. As a result, the e nforcement

informat ion has been carried forward from the earlier documents

.

1 National Level Assessment of Water Quality Impairments Related to Forest Roads and Their Prevention by Best Management Practi ces , Final Report, Great

Lakes Environmental Center, 2008, (See Tables 4

- 1, pg. 222, and Table 4

- 2, pg. 227).

2 Note that c haracterizations of state forestry BMP programs can differ because of the way reviewers categorize the programs, aspects of t he programs they

review, different interpretations of program elements, and the fact that state forestry BMP programs have evolved and continue to evolve over time.Table A

- 1. Summary of state programs for forest road management.

State Forest

program

type * Last

edition of

forest

practices Has BMPs for :

Monitor and

evaluate

effectiveness

of BMPs? Compliance

and

enforcement

mechanisms? Forest road

location/

design/

construction Forest road

maintenance Stream

crossings SMZ/ Bank

Stabil./

Buffer

Strips Forest

road

retirement Wet Weather/

Winter Use

AL QR Update

2007 X X X X X X X

AK R FRPA 2003;

Regs 2013 X X X X X X X X

AZ NR 3 X

AR NR 2002 X X X X X X X

CA R 2016 X X X X X X X X

CO NR 1998

Guidelines

2010 X X X X X X X

CT QR Field Guide

2007 X X X X X X

DE QR 1996 4 X X X X X X X X

FL QR 1993

Revised

2008 X X X X X X X X

GA NR 5 1999

Update

2009 X X X X X X X

HI NR 1996 X X X X 6 X X

3 NCASI Technical Bulletin 966 (2009) states AZ has not prepared guidelines. Half of AZ’s productive forest is federal land, so the state relies on USFS BMPs and tribal provisions

. Document indicates that NPS pollution from forest management is a low priority for the state (silviculture is not a source of impairment in 2004 305(b) report ) . NASF website indicates

BMP monitoring.

4 NASF site indicates BMP m anual dated 2006, but link does not work. NASF also has a link to most recent BMP manual, which is undated.

5 NASF indicates program is voluntary. BMPs include 40 CFR 232.3 (dredge and fill silviculture 404 permit exemption requirements) and some federal wetlan d requirements. Also

notes that Georgia Water Quality Control Act prohibits the discharge of excessive pollutants into s tate waters in harmful amounts (civil and criminal penalties, pg. 58).

6 BMPs address SMZs, but not expressly in the context of forest roads.State Forest

program

type * Last

edition of

forest

practices Has BMPs for :

Monitor and

evaluate

effectiveness

of BMPs? Compliance

and

enforcement

mechanisms? Forest road

location/

design/

construction Forest road

maintenance Stream

crossings SMZ/ Bank

Stabil./

Buffer

Strips Forest

road

retirement Wet Weather/

Winter Use

ID R 2003 7 X X X X X X X X

IL QR Revised

2012 X X X X X X

IN NR 2005 X X X X X X X

IA NR 1996 X X X X X X

KS NR X

KY R 1996 X X X X X X X

LA NR 2000 X X X X X X

ME QR 2004 X X X X X X X 8

MD R 2015 X X X X X X

MA R 9 2013 X X X X X X X

MI QR 2009 X X X X X X X X

MN NR 2013 X X X X X X X X

MS NR 2008 X X X X X X

MO NR 2014 X X X X X

MT QR 2015 X X X X X X X X

NE NR 2001 X X X X X

NV QR 10 2008 X X

NH QR 2016 X X X X X X

NJ R 1995 X X X X X

NM R 2013 11 X X X X X X X

7 NASF linked BMPs do not include a published date. Dates for forest road reg ulatory provisions (i.e., sec. 040) range from 1 985 to 2006.

8 Regulatory elements.

9 NASF indicates regulatory, however, BMP manual includes required and recommended provisions.

10 NASF link is for urban forestry. NASF indicates monitoring.

11 NASF survey says 2013, but BMP manual linked from website is 2008. St ate website doesn’t indicate year.State Forest

program

type * Last

edition of

forest

practices Has BMPs for :

Monitor and

evaluate

effectiveness

of BMPs? Compliance

and

enforcement

mechanisms? Forest road

location/

design/

construction Forest road

maintenance Stream

crossings SMZ/ Bank

Stabil./

Buffer

Strips Forest

road

retirement Wet Weather/

Winter Use

NY QR 2011 X X X X X X X

NC QR 2006 X X X X X X X

ND NR 2010 X X X X X

OH V 2004 X X X X X X X

OK NR 2008 X X X X X X

OR R 2014 X X X X X X X X

PA QR 2001 X X X X X

RI 12 QR X

SC QR 20 12 13 X X X X X X

SD NR 2003 X X X X X X X X

TN NR 2003 X X X X X X X X

TX NR 2014 X X X X X X 14 X

UT NR 2001 X X X X X X X

VT QR 2011 X X X X X X X

VA QR 2011 X X X X X X 15 X X

WA R 2013 X X X X X X X X

WV R 2014 X X X X X X X

WI QR 2010 X X X X X 16 X X

WY NR 2014 X X X X X X X

* Regulatory (R), Non

- regulatory (NR) , Quasi

- regulatory (Q R ) . Based on NASF 2013 sur vey information.

12 NASF identifies BMP manual date of 2003, however, no link to BMPs is provided and only BMPs independently identified include cover letter date d 1996.

13 NASF identified BMP manual date of 2012, however, document linked is undated.

14 Limit operations on sensitive sites and in SMZs during periods of wet weather.

15 Addresses BMPs for wet weather operations in wetlands.

16 Addresses BMPs for inactive roads.