### National Level Assessment of Water Qu ality Impairments Related to Forest Roads and Their Prevention by Best Management Practices

Final Report

Prepared by:

Great Lakes Environmental Center

739 Hastings Street Traverse City, MI 49686

Phone: (231) 941-2230

Principal Investigator: Douglas Endicott

for:

U.S. Environmental Protection Agency Office of Water Office of Wastewater Management Permits Division

Virginia Garelick, Task Order Project Manager

Contract No. EP-C-05-066 Task Order 002

December 4, 200 8Assessment of Water Quality Impairments Related to Forest Roads Page i Contract # EP-C-05-066, TO # 0002 December 4, 2008

TABLE OF CONTENTS

1. BACKGROUND AND INTRODUCTION ................................................................................1

2. WATER QUALITY IMPACTS OF FOREST ROADS..............................................................8 2.1 What are Forest Roads? ..................................................................................................... ..10 2.2 What is the Nature, Extent and Severity of Water Quality Impair ments Due to Forest Roads Across the Country?.................................................................................................14 2.2.1 Water Quality Impairments ........................................................................................16 2.2.1.1 Increased Loading of Fine and/or Coar se-Grained Sediment Due to Erosion and Mass Wasting ..........................................................................................16 2.2.1.2 Increased Suspended Solids and Turbidity ....................................................22 2.2.1.3 Increased Sediment Deposition and Bed Load ..............................................25 2.2.1.4 Siltation of Coarse Streambed Substrates ......................................................26 2.2.1.5 Alteration of Stream Morphology (E.G., Reduced Pool Volume) and Channel Simplification...................................................................................27 2.2.1.6 Physical Barriers to Fish Migration and Downstream Transport of Coarse Sediment and Large Wood.............................................................................27 2.2.1.7Altered Streamflow .........................................................................................29 2.2.1.8 Pollution from Other Chemicals Associated with Roads (Spills, Deicing and Dust C ontrol Agents, and Herbicides) ..........................30 2.2.2 Degradation of Habitat for Salmonids , Other Fish, Invertebrates, and Other Aquatic Organisms ...........................................................................................31 2.2.2.1 Sediment.........................................................................................................33 2.2.2.2 Flows ..............................................................................................................38 2.2.2.3 Temperature ...................................................................................................38 2.3 Extent and Severity of Water Quality Impairments Due to Forest Roads ...........................39 2.3.1 Western Inland Conifers.............................................................................................39 2.3.2 Pacific Coast Conifers ................................................................................................40 2.3.3 Northeastern Conifers.................................................................................................41 2.3.4 Eastern Hardwoods.....................................................................................................41 2.3.5 Southern Conifers.......................................................................................................4 2 2.3.6 How and Why Do Water Quality Im pacts from Forest Roads Vary?........................42 2.3.6.1 Surface Erosion...............................................................................................46 2.3.6.2 Mass Movements of Soil ...............................................................................48 2.3.6.3 Road Drainage and Sediment Delivery ..........................................................49 2.3.6.4 Road Maintenance ..........................................................................................50 2.3.6.5 Age of Roads and Road Network...................................................................52 2.3.6.6 Road Density and “Critical” Locations ..........................................................53 2.3.6.7 Cumulative Impacts and Effects.....................................................................56 2.4 How are the Water Quality Impacts from Forest Roads Quantified and Documented? ......59 2.5 What Total Maximum Daily Loads Have Been Developed for Sediment Associated with Forest Roads?............................................................................63

3. DESCRIPTION, EFFECTIVENESS AN D COSTS OF FOREST ROAD BMPS ...................71 3.1 What are the Types of BMPs an d how are they Maintained?..............................................74Assessment of Water Quality Impairments Related to Forest Roads Page ii Contract # EP-C-05-066, TO # 0002 December 4, 2008

TABLE OF CONTENTS (continued)

3.1.1 Road Planning and Design .........................................................................................75 3.1.2 Construction/Reconstruction ......................................................................................77 3.1.2.1 Surface Erosion Control..................................................................................78 3.1.2.2 Landslide Avoidance ......................................................................................81 3.1.2.3 Sediment Delivery Reduction.........................................................................81 3.1.2.4 Stream Crossings ............................................................................................82 3.1.2.5 Wetlands and Bottomlands .............................................................................83 3.1.3 Road Management......................................................................................................84 3.1.3.1 Maintenance ...................................................................................................84 3.1.3.2 Upgrading .......................................................................................................85 3.1.3.3 Closure............................................................................................................87 3.1.4 Decommissioning/ Putting-To-Bed and Obliteration/ Removal ................................87 3.2 How Well do Forest Road BMPs Work? .............................................................................89 3.2.1 Site Level Forest Road BMPs Effectiveness..............................................................91 3.2.2 Watershed Scale Forest Road BMPs Effectiveness ...................................................96 3.3 What are the Costs of Installi ng and Maintaining These BMPs? ......................................103 3.4 What are the Recent Promising I nnovations in Forest Road BMPs?.................................107 3.5 Why do Forest Road BMPs Fail to Protect Water Quality? ..............................................110 3.5.1 Lack of Effective Implementation............................................................................111 3.5.2 Erosion Rates and Mass Failures can Ex ceed Capacity of BMPs to Prevent Generation, Transport and/ or Delivery of Sediment to Water Bodies.....................111 3.5.3 Legacy Roads and Crossings: Lack of Ma intenance, Failure to Upgrade and/or Remove.....................................................................................................................112 3.5.4 Cumulative Impacts..................................................................................................112 3.5.5 Highly Sensitive Aquatic Resources ........................................................................113 3.5.6 Rare Events ..............................................................................................................113 3.6 How can Failing BMPs be Improved? ...............................................................................114

4. STATE FOREST ROAD BMP PROGRAMS .......................................................................115 4.1 What are the State Programs that Address Forest Roads?.................................................116 4.2 State BMP Implementation and Effectiveness Monitoring ...............................................124 4.3 Are Compliance and Effectiveness Monitori ng of BMP Programs Actually Capturing the Success of These Programs in Addressing Fo rest Road Runoff?................................127 4.4 BMP Implementation Data: Examples from States...........................................................129 4.4.1 California..................................................................................................................130 4.4.2 Colorado ...................................................................................................................135 4.4.3 Florida.......................................................................................................................136 4.4.4 Georgia .....................................................................................................................138 4.4.5 Idaho .........................................................................................................................140 4.4.6 Maine........................................................................................................................141 4.4.7 North Carolina ..........................................................................................................1 44 4.4.8 Minnesota .................................................................................................................145 4.4.9 Oregon ......................................................................................................................148 4.4.10 Virginia...................................................................................................................149Assessment of Water Quality Impairme nts Related to Forest Roads Page iii Contract # EP-C-05-066, TO # 0002 December 4, 2008

TABLE OF CONTENTS (continued)

4.4.11 Washington.............................................................................................................1 51 4.4.12 Summary.................................................................................................................152 4.5 Are Voluntary or Regulator y BMP Programs Effective?..................................................152 4.6 How Often do States Revise Their BMPs? .......................................................................154 4.7 Do Existing BMPs Include the Most Technol ogically Up-To-Date and Useful Practices Available?..........................................................................................................................156 4.8 What Processes are used to A ddress and Correct Failing BMPs?.....................................157 4. 9 Is Concurrence or Approval by the Stat e Agency Administering Clean Water Act Required for: (a) Forest Road BMPs? (b) Fo rest Practice Rules Related to Roads and Water Quality? (c) Forest Operations or Plans Involving Road Construction and Maintenance? ....................................................................................................................158 4.10 What are the Circumstances Produci ng Effective BMP Implementation? 159 Case Studies of Successf ul State BMP Programs: Washington, Oregon and Idaho.........159 4.10.1 Washington Watershed Assessment Process .........................................................159 4.10.2 Idaho Cumulative Watershed Effects Process .......................................................160 4.10.3 Oregon Watershed Assessment Process ................................................................161 4.10.4 Special Issue Management Systems ......................................................................162 4.10.4.1 Habitat Conservation Plans .....................................................................162 4.10.4.2 Oregon Plan for Salmon and Watersheds................................................163 4.10.4.3 Washington Forest and Fish Agreement .................................................164

5. SUMMARY AND CONCLUSIONS ......................................................................................165

6. REFERENCES .................................................................................................................. ......171Assessment of Water Quality Impairments Related to Forest Roads Page iv Contract # EP-C-05-066, TO # 0002 December 4, 2008

LIST OF TABLES

2-1. Results of Keyword Searches in the TMDL Tracking System Database.............................204

3-1. Best Management Practices fo r Forest Roads: Descriptions, Measures of Effectiveness, and Costs..................................................................................205

3-2. Effectiveness of Surface Erosion Control on Forest Roads. ................................................222

3-3. Estimations of Overall Cost of Complia nce with State Forestry BMP Programs by Program Type ................................................................................................................. .....223

3-4. Table 3-4. Estimations of Implementation Costs by Management Measure in the Southeast and Midwest...................................................................................................224

3-5. Table 3-5. Estimations of Construction and Implementation Costs for Individual Road Construction a nd Erosion Control BMPs, by Region................................225

4-1. Summary of State Programs for Forest Road Management: States in which BMPs for Forest Roads are Voluntary .................................................................................226

4-2. Summary of State Programs for Forest Road Management: States in which BMPs for Forest Roads are Mandatory................................................................................231

4-3. Detailed Review of State Forest Practices and Selected Habitat C onservation Plan (HCP) Provisions for Roads .......................................................................................................... ..235

4-4. Summary of State Forest Road BMP Impl ementation Surveys for States in which BMPs for Forest Roads are Voluntary. ................................................................................236

4-5. Summary of State Forest Road BMP Impl ementation Surveys for States in which BMPs for Forest Roads are Mandatory................................................................................243Assessment of Water Quality Impairments Related to Forest Roads Page v Contract # EP-C-05-066, TO # 0002 December 4, 2008

LIST OF FIGURES

2-1. Distribution of Forest Land in the Continental United States. .............................................250

2-2. Cross-sectional Diagram of the Forest Road Prism and Components..................................250

2-3. Legal Basis and Definitions fo r Roads in the National Forests............................................251

2-4. Response of Suspended Sediment Con centrations to Forest Harvesting at Experimental Watersheds.....................................................................................................25 2

2-5. Figure 5 from Chapman (1988). Graph of Percent Survival of Salmonid Embryos to Emergence in Relation to Percent Fines Smaller than 0.85 mm. Data Provide Comparisons of Coho Salmon Survivals in the Laboratory (Lab.) and Field (Cederholm et al., 1981), of Coho Salm on in Two Different Streams (Koski, 1966; Cederholm et al., 1981), and of Ch inook Salmon in Gravels with a Range of Percentages of Particles Smaller than 9.5 mm......................................................253

2-6. Distribution of Major Forest Type s in the Continenta l United States..................................254Assessment of Water Quality Impairments Related to Forest Roads Page vi Contract # EP-C-05-066, TO # 0002 December 4, 2008

LIST OF ACRONYMS

ATV All-terrain Vehicle

BMP Best Management Practices

CAL FIRE California Department of Forestry and Fire Protection

CSBOF California State Board of Forestry

CSES Critical Site Erosion Study

CWA Clean Water Act (Federal Water Pollution Control Act Amendments of 1972, PL 92-500)

CWE Cumulative Watershed Effects

CSBOF California State Board of Forestry and Fire Protection

BLM Bureau of Land Management

DAT Days After Treatment

DEC Department of Environmental Conservation

DOF Department of Forestry

EDC Environmental Defense Center ESA Endangered Species Act

FORPRIEM Forest Practice Rule Impl ementation and Effectiveness Monitoring

FPA Forest Practices Act

FPGs Forest Practice Guidelines

FPR Forest Practices Regulations FPWQ Forest Practices Water Quality audit

FRTA National Forest Ro ads and Trails Act of 1964

ICBEMP Interior Columbia Basi n Ecosystem Management Project

MCR Modified Compliance Report

MDC Maine Department of Conservation

MFS Maine Forest Service

MOA Memorandum of Agreement

NAASF Northeastern Area Associ ation of State Foresters

NCASI National Center for Air and Stream Improvement

NCDFR North Carolina Divisi on of Forest Resources

NFS National Forest SystemAssessment of Water Quality Impairments Related to Forest Roads Page vii Contract # EP-C-05-066, TO # 0002 December 4, 2008

NIPF Non-industrial private forest

NMFS National Marine Fisheries Service

GAO Government Accountability Office

GFC Georgia Forestry Commission GIS Geographic Information System

HA Hectare (1,000 square meters)

HCP Habitat Conservation Plan

HMP Hillslope Monitoring Program

IMMP Interagency Mitigation Monitoring Program

JTU Jackson Turbidity Unit

LA Load Allocation LW Large Wood

MS4 municipal separate storm sewer systems

NAASF Northeastern Area Asso ciation of State Foresters

NAD National Assessment Database

NFC North Fork Caspar Creek Gauging Station

NOAA National Oceanic and A tmospheric Administration

NPDES National Pollutant Discharge Elimination System

NPS nonpoint source pollution

NTU Nephelometric Turbidity Units NWQI National Water Quality Inventory

ODF Oregon Department of Forestry

ODFW Oregon Department of Fish and Wildlife OHV Off-highway Vehicle

PNW Pacific Northwest QAPP Quality Assurance Project Plan

SABS Suspended and Bedded Sediments

SFI Sustainable Forestry Initiative

SFRA Sustainable Forest Resources Act

SHA Stream Habitat Assessment

SGSF Southern Group of State ForestersAssessment of Water Quality Impairme nts Related to Forest Roads Page viii Contract # EP-C-05-066, TO # 0002 December 4, 2008

SMA Streamside Management Area

SYP Sustained Yield Plan

TFW Timber/Fish/Wildlife program

TIFS Texas Intensive Forestry Study

TH/FM Timber Harvesting and Fo rest Management Guidelines

THP Timber Harvest Plans

TMDL Total Maximum Daily Load

TSS Total Suspended Solids

USFS Unites States Forest Service

USEPA Unites States Environmental Protection Agency

USLE Universal Soil Loss Equation

VA DOF Virginia Department of Forestry

WLA Wasteload Allocation

WATERS Watershed Assessment, Tr acking & Environmental ResultsAssessment of Water Quality Impairments Related to Forest Roads Page 1 Contract # EP-C-05-066, TO # 0002 December 4, 2008

1. BACKGROUND AND INTRODUCTION

Most of the measures to protec t water quality in the United St ates owe their origin to the

Federal Water Pollution Control Act Amen dments of 1972 (PL 92-500), which became known as the Clean Water Act (CWA) (ee U.S.C. §1251 et seq. CWA section 301(a) generally prohibits the discha rge of a pollutant from a point source to navigable waters unless in compliance with a National Pollutant Discharge Elimination System (NPDES) permit. The NPDES program requires permits for the discharge of pollutants from any point source into waters of the Un ited States. Section 502(14) of the CWA defines point sources as “any discernible, confined, and discrete conveyance,” and includes, among other things, any pipe, ditch, channel, t unnel, or conduit from which pollutants are discharged. It follows that any source that is not a point source is a nonpoint source, although nonpoint source (NPS) pollution is not specifically defined in the CWA. This

lack of definition has resulted in some conf usion. For example, storm water runoff from construction sites, industrial f acilities, certain municipal ar eas, and concentrated animal feeding operations are point sources. However, diffuse sources such as agricultural storm water runoff and irrigated agri culture return flows are specifically excluded from the definition of point source. Generally, a N PS is diffuse runoff caused, for example, by rainfall or snowmelt moving over the gr ound carrying pollutants into waterbodies. Atmospheric deposition and hydrologic modifi cation are also generally considered NPS pollution.

Silvicultural operators are speci fically categorized in 40 C. F.R. section 122.27(b) either as as point or nonpoint sources. Silvicultural point sources include any discernible, confined and discrete conveyance related to rock crushing, gravel washing, log sorting, or log storage facilities whic h are operated in connection with silvicultural activities and from which pollutants are discharged into waters of the United States. Silvicultural point sources are subject to the NPDES permit pr ogram. NPS silvicultural activities include nursery operations, site prepar ation, reforestation and subs equent cultural treatment, thinning, prescribed burning, pest and fire control, ha rvesting operations, surfaceAssessment of Water Quality Impairments Related to Forest Roads Page 2 Contract # EP-C-05-066, TO # 0002 December 4, 2008

drainage, or road construction and mainte nance from which there is natural runoff 1

. Oversight of NPS pollution has been delegated to the states primarily through Sections

208 and 319 of the CWA. Section 208 of the CW A requires all states to identify nonpoint sources of pollution, their cumulative effect s, and methods of controlling them 933. U.S.C. 208(b)(2)(F). Silviculture was one of the nonpoint sources specifically mentioned in the Act. Sediment is the primary pollutant from forestry 2 activities and forestry-related sediment is a leading sour ce of water quality impairment to rivers and streams nationwide (USEPA, 2000 and 2002). Roads are the primary source of sediment from forest management activities in the wester n United States (Megahan and Ketcheson, 1996), the southern states (Prud’homme and Greis, 2002), the Midwest and the Northeast (NCASI, 2007). The dominance of road-related erosion over erosion from other forestry

activities has been noted in studi es since at least 1954 (Anderson, 1954).

In 1975, USEPA developed regulations to guide the states in implementing Section 208 by establishing non-regulatory nonpoint source pollution programs. States were required to develop Best Management Practices (BMPs) for the major land uses, as well as an implementation schedule. BMPs are structural and nonstructural measures used to reduce nonpoint source pollution to receiving waters (See 40 C.F.R. section 130.2(m). Forest Practice Regulations (FPRs) may be part of some state’s efforts to satisfy the requirements of Section 208 and specify the BM Ps necessary to control the water quality effects of forest roads (Rice, 1992). Every state with significant silvicultural activities has some type of program (Ice et al., 1997), but they vary widely across the country due to regional, geographic, and cu ltural differences. Consequent ly, states have developed regulatory programs which require permits or mandatory BMPs; nonregulatory programs with voluntary BMPs; nonre gulatory programs with enforcement where BMP use is voluntary but severe violations may lead to fines or citations; and a combination of programs that mix aspects of regulator y and nonregulatory programs. Repeated assessments have shown that compliance with state BMPs and FPRs prevents major

1 However, some of these activities (such as stream crossing for roads) may involve point source discharges of dredged or fill material which may requ ire a CWA section 404 (a regulatory program for the disposal of dredged or fill materials in the waters and wetlands) permit.

2 In this report, “silviculture” and “forestry” are used interchangeably, despite the subtle differences among the definitions of these terms.Assessment of Water Quality Impairments Related to Forest Roads Page 3 Contract # EP-C-05-066, TO # 0002 December 4, 2008

water quality impacts under most circumstan ces (Ethridge and Heffernan, 2000; NCASI, 2001). However, detrimental impacts from fo rest roads have been documented in many

water bodies and the extent of such impacts can be large (Williams, 1999).

The control of nonpoint source pollution under the CWA has been controversial. The Act originally envisioned that nonpoi nt sources of pollution would be dealt with at the state and local level through area waste management plans mandated by Section 208. This section requires states to engage in a pla nning process that, among other things, identified and controlled nonpoint sources of pollution. Th is planning process was not sufficient to address nonpoint source pollution (BLM, 2005).

Recognizing the continuing problem of nonpoint source pollution, Congress added Section 319 to the CWA through the 1987 amen dments (33.U.S.C. section 1329). This section specifically addre sses the creation of nonpoint source management programs through a three-stage process: 1) states develop nonpoint so urce assessment reports; 2) states adopt nonpoint source mana gement programs; and 3) st ates phase in the programs

with the assistance of Federal funds. States are to identify waters not attaining water quality standards without additional nonpoint source controls, identify BMPs for categories of nonpoint source problems, and develop programs to implement the BMPs. Federal grants are made available to de velop and implement these measures. This nonpoint source management program is intended to operate voluntarily through financial incentives from the federal gove rnment. The voluntary approach to nonpoint source water pollution reflects Congress’s re luctance to encroach upon traditional state and local prerogatives to contro l land use decisions (BLM, 2005).

Although there is general consensus that Section 319 has brought about some positive steps, there is also criticis m that it has not comprehensively addressed nonpoint source pollution problems (BLM, 2005). In 1988, USEPA indicated that NPS pollution had

become the dominant fraction of the Nati on’s remaining surface water pollution problem (EPA, 1988). Another section of the CWA, 305(b), requires th e states to describe the quality of their surface waters including the extent to which water quality standards areAssessment of Water Quality Impairments Related to Forest Roads Page 4 Contract # EP-C-05-066, TO # 0002 December 4, 2008

being met; USEPA then summarizes these assessments and reports the results to Congress. Fourteen such reports have b een published since 1975; the most recent National Water Quality Inventory reports 3 were published in 2000 and 2002. The 2000 report listed a number of nonpoi nt sources – agriculture, hydr ologic modification, habitat modification, urban runoff, and silviculture - as leading sources of river and stream impairment. Silviculture was the 5th ranked source, responsible for impairment of 28,156

river miles. The 2002 report lists silviculture as th e 9th leading source, responsible of impairment of 18,463 miles 4 . Significantly, USEPA noted in the 2002 report that:

“...it is important to note that the information about specific sources and causes of impairment is incomplete. States do not always report the pollutant or source of pollutants affecting every impaired river and stream.”

In 1999, USEPA provided Congress with a li st of 1,040 waterbodies identified as impaired by silviculture in states without author ity to regulate forest activities. This list and the National Water Quality Inventory reports were criticized by the Society of American Foresters (Ice, 2000), which cont ended that silvicu lture was a minor contributor to nonpoint source pollution nationwide. They cited numerous inconsistencies and discrepancies between data sources, pointin g out that 48% of the listed waterbodies did not appear on the most recent 303(d) lists, and that an additiona l 37% were listed on the basis of sparse or unreliable data. In ge neral, their critique of the list of waterbodies impaired by forestry operations pointed out th e shortcomings and diffi culties of assessing water quality progress using 305( b) and 303(d) lists.

In 1999, USEPA also issued the Phase II NPDES rule for stormwater dischargers. 64 Fed. Reg. 68,722 (Dec. 9, 1999) (codified at 40 C.F.R. pts. 9, 122, 123, and 124). This rule did not contain any provisi ons to require permits for forest roads. This rule was challenged in the Fifth, Nint h, and D.C. Circuit Courts in three separate actions ultimately consolidated before the Ninth Circuit Court. In the suit filed by the Environmental Defense Center (EDC), in cooperation with the Natural Resources

3 The 2000 and 2002 National Water Quality Inventory reports are discussed furt her in Section 2.4.

4 Overall, more river miles were assessed in 2002; however, three states (including Washington) were not included in this latest round of reporting.Assessment of Water Quality Impairments Related to Forest Roads Page 5 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Defense Council, plaintiffs asserted that th e regulations failed to meet minimum Clean Water Act statutory requirements because, among other reasons, they neglected to

address stormwater runoff associated with fo rest roads and other si gnificant sources of runoff pollution. EDC v. USEPA 344 F.3d 832.859 (9 th Cir. 2003). In September 2003, the Ninth Circuit Court of Appeals remanded the forest road issue to the Agency. The court asked USEPA “to consider, in an appr opriate proceeding, the petitioners contention that Section 402(p)(6) requi res USEPA to regulate forest roads.” Id. at 879.

USEPA needs a better understanding of wate r quality impacts associated with forest roads and the effectiveness of state program s to address these impacts. Specifically, additional research is needed to assess: (1) the extent to which runoff from forest roads has degraded water quality and aquatic habitat, and (2) th e effectiveness and state of technology of state BMP programs for forest ry operations to prevent water quality degradation.

At the request of USEPA, Great Lakes Environmental Center (GLEC) conducted a

literature review and evaluate d data to explore whether, why, and how forest roads impact water quality and the effectiveness of BMPs in preventing these impacts. The analysis was based on GLEC’s review of documents provided by USEPA and a limited survey of on-line literature. This report concisely answer s the following questions, based

on the literature searches and evaluation of available data.Assessment of Water Quality Impairments Related to Forest Roads Page 6 Contract # EP-C-05-066, TO # 0002 December 4, 2008

What is the nature and extent of water quality impairments due to forest roads across the country?

How are the water quality impacts from forest roads quantified and documented?

What total maximum daily loads (TMDLs) have been developed for sediment associated with forest roads?

What are the state programs that address forest roads?

Are forest roads defined differently among states?

Are voluntary or regulatory BMP programs effective?

What are the circumstances producing effective BMP implementation?

How often do states revise their BMPs?

Do existing BMPs include the most technologically up-to-date and useful practices available?

What processes are used to address and correct failing BMPs?

Are compliance and effectiveness monitoring of BMP programs actually capturing the success of these programs in addressing forest road runoff?

How representative are the results of BMP monitoring?

What are the types of BMPs and how are they maintained?

How well do Forest Road BMPs work?

What are the costs of installing and maintaining these BMPs?

What are recent promising innovations in forest road BMPs?

How can failing BMPs be improved?Assessment of Water Quality Impairments Related to Forest Roads Page 7 Contract # EP-C-05-066, TO # 0002 December 4, 2008

The report is organized around several basic issu es, which are divided into three sections,

as follows:



### y Section 2 describes and quan tifies the impacts of forest roads on water quality and aquatic resources.



### y Section 3 describes the forest road BMPs, their effectiveness and costs.



### y Section 4 inventories and discusses state BMP programs for forest roads.Assessment of Water Quality Impairments Related to Forest Roads Page 8 Contract # EP-C-05-066, TO # 0002 December 4, 2008

2. WATER QUALITY IMPACTS OF FOREST ROADS

Forests cover about 1/3 of the continental United States (Figure 2-1). Most of the headwaters of major rivers and streams arise in forested catchments (NCASI, 1994), and 80% of the nation’s scarce freshwater resources originate in thes e forests (USFS, 2000). Various assessments show that the quality of surface wate r draining forested watersheds is generally among the highest in the country (NCASI, 1994). Natura l geologic erosion is quite lo w from most forested lands. Although forests typically occur on the steepest po rtions of the landscape, the annual sediment yields from forested lands are lower than any ot her rural land use (Swank et al., 1989; Gianessi et al., 1986). Unit area loads (also called expor t coefficients) are routinely used to develop estimates of pollutant loads in a watershed. An e xport coefficient is a value expressing pollutant generation per unit area and time for a specifi c land use (Novotny and Olem, 1994). The use of unit area loading or export coefficients has been used extensively in estimating loading contributions from different land uses (Beaula c and Reckhow, 1982; Utto rmark et al., 1974). The concept is straightforward; different land use area s contribute different load s to receiving waters. By summing the amount of pollutant exported per uni t area of land use in the watershed, the total pollutant load to the receiving system can be calculated. Export coe fficients for undisturbed forest lands are typically the smallest of all la nd uses. This is the case for sediment as well as nutrients (nitrogen and phosphorus). Thus, the qu ality of surface waters in forests should be

excellent and in most forested watersheds th e water quality usually is (Rummer et al., 1997), assuming that the integrity of the wate rshed and its functions are maintained.

The high quality of water supplies from forests is widely recognized as a valuable resource. In 2000, the US Forest Service (USFS) calculated the marginal value of water from all National Forest lands to be at least $3.7 billion per year (USFS, 2000). The rivers and streams in forests are also critical habitat for aquatic biota including fish species that are in decline, face significant ecological challenges, or are listed as species of concern or endangere d species. According to surveys of Washington state residents, the most important use of priv ate forestland is as “a source of clean water” as the number one priority , followed by “fish and wildlife habitat”(Reiter et al., 2004). Likewise, the most generally valued and utilized "commodity" produced by California's forest lands is clean water (Reid, 19 99). In fact, the origins of the National ForestAssessment of Water Quality Impairments Related to Forest Roads Page 9 Contract # EP-C-05-066, TO # 0002 December 4, 2008

system are tied directly to watershed concer ns (Ice and Whittemore, 1998). Steen (1991), writing about the early legislation that established the National Forests, concluded that "the primary driving force behind forest reserve legislati on at that early time was the protection and enhancement of water supplies, including flood protection."

Forest management activities associated with timber harvesting can affect the physical, chemical, and biological properties of the soil (Swank et al., 1989). Any management activity that exposes and/or compacts the soil and reduce s infiltration can concentrate surface runoff and thereby accelerate erosion. If th ese activities increase soil er osion, for example, then water quality may be decreased through stream sedime ntation, accompanied by a loss of long-term site and stream productivity. Felling trees alone seldom causes erosion although some soil compaction and surface gouging may occur during th is operation. In contrast, road building, skidding and stacking logs, and some site prepar ation activities, can produce major soil surface disturbance that greatly increases the erosion on a site. Soil losses ar e greatest during and immediately after road construc tion (unstabilized road prism, disturbances by heavy equipment passage). However, water quality impacts can co ntinue throughout the ac tive lifetime of a road

and even afterwards.

Sediment is the most significant pollutant of surf ace waters due to forestry activities, often where there is a legacy of roads or road-related drainage issues (Rehder and Stednick, 2006 ) . Unpaved roads and stream crossings are the major source of erosion from forest lands (Anderson et al., 1976, Megahan and Kidd, 1972; Patric, 1976; Rothwe ll, 1983), contributing up to 90% of the total sediment production from forestry operations. Surface erosion rates from roads are typically at least an order of magnitude greater than rates from harveste d areas, and as much as three orders of magnitude (1,000 times) greater than erosion rates from undisturbed forest soils (NCASI, 2001). Mass wasting events such as landslid es are also frequently attributed to forest management and associated with ro ads in steeply sloped terrain. Both erosion and mass wasting can increase the loading of fine and/or coarse-grained sediment to surface waters in forests.

However, soil erosion and mass wasting do not necessarily represent sediment contributions to streams (Kochenderfer and Helvey, 1987). Whethe r eroded soil reaches a stream depends onAssessment of Water Quality Impairments Related to Forest Roads Page 10 Contract # EP-C-05-066, TO # 0002 December 4, 2008

many factors such as road location, the volume of water available for sediment transport, effectiveness of sediment traps, and slope steepness. The distance that sediment travels downslope is also an important factor in dete rmining how much eroded soil is delivered to a water body as sediment. Soil losses and erosion occurring closer to a stream have greater potential to deliver sediment a nd lead to water quality impairment. In this regard, stream crossings have the greatest poten tial to adversely impact water quality on the forest landscape (Grace, 2002).

Effects of sedimentation on stream water quality are numerous and the extent of such impacts is large (Williams, 1999). Among all pollutants measured in streams, sediment has the largest effect on stream biota (Aitken, 1936; Trautm an, 1933). Sediment delivery from improperly

constructed or maintained forest roads can adversely affect str eam water quality and associated beneficial uses (Furniss et al., 1991; Megahan et al., 1992). As discussed below in Section 2.2, sediment loading can degrade water quality and impair numerous physical and biological

functions.

2.1 What Are Forest Roads?

Roads are vital components of the human use of forested systems (Gucinski et al., 2001). Without roads, development of the economic activit y critical to the qualit y of modern life would have been difficult, and roads remain central to many forest uses today. Roads provide access for people to extract resources from natural and modified ecosystems, as well as providing access to forests for other activities such as fire suppression and recreation

. Figure 2-2 provides a crosssectional diagram of a forest road.

Different kinds of roads comprise the forest road network. Primary or mainline roads are the most heavily traveled forest roads and generally originate from paved county or state highways (NCASI, 2001). They are generally graveled roads, are built fo r use throughout the year, and easily accommodate two-way traffic. Secondary ro ads generally depart from primary roads and may or may not be graveled. Thes e roads are commonly closed duri ng at least part of the year. Two-way traffic is usually accommodated by tu rnouts spaced along the route. Temporary roadsAssessment of Water Quality Impairments Related to Forest Roads Page 11 Contract # EP-C-05-066, TO # 0002 December 4, 2008

are generally unsurfaced, although gr avel surfacing of temporary roads is a common practice in particularly wet areas of the West Coast and Alas ka. These roads are generally closed to traffic immediately after completion of log hauling and/or silvicultural activities such as slash disposal, thinning, and tree planting. Temporary roads are used to access individual sites and landings, where logs are processed and stacked before loading onto log trucks.

Road networks differ greatly in development th rough time and layout over terrain, and they carry this history into their present performance and environmental impacts (Gucinski et al., 2001). In many parts of the National Forest system, th e major roads were bui lt in the 1950s and 1960s, with secondary and tertiary feeder roads fo llowing as the road networks expanded into watersheds. In other areas, loggi ng roads developed from previous road systems used for mining in the Rocky Mountain and southwestern states or agriculture in the southern Appalachians, Ozarks, and New England. Thus, changes in road standards through time (for example, width, construction methods, position in the landscape) have affected different parts of road networks. Consequently, each road network commonly cont ains a collection of old and new types and standards of roads designed for various purposes th at cross terrain of diffe ring sensitivities. This mosaic of road segments has implications for how the road network will interact with the forest watershed, streams, and other downstream aquatic resources.

While the term ‘forest road’ is not defined in the CWA or in EPA regulations States have developed many definitions of forest roads. Not surprisingly, there is no one, clear definition of a “forest road”. This may be one of the problem s with the issue because forest road BMPs areonly required for roads meeting the definition. Although the definition of a road may seem selfevident, definitions of forest roads have been constructed that confuse rather than clarify the relationships of roads and streams (NCASI, 2001). Many different definitions of forest roads are

included in the individual states’ fo rest practice rules. Here are seve ral examples of definitions of

forest roads:



### y A forest road is used principally for forest management activities and includes any road used by truck or pick-up since 1972 and that has not been formally vacated. (Oregon)Assessment of Water Quality Impairments Related to Forest Roads Page 12 Contract # EP-C-05-066, TO # 0002 December 4, 2008



### y "Forest road," as it applie s to the operation of the road maintenance and abandonment plan element of the forest practices rules on small forest landowners, means a road or road segment that crosses land that meets the definition of forest land, but excludes residential access roads. (Washington)



### y Roads, skid trails and landi ngs are all part of a forest transportation system. Roads connect the forest land to existing public ro ads. They provide forest access for such activities as managing timber, improving fish and wildlife habitat, fighting fires, and recreation. (Wisconsin)



### y Active Road: a road that can be either te mporary or permanent that allows vehicle movement in and out of forestland. Forest Road: an access route for vehicles into forestland. (Arkansas)



### y “Road” refers to truck or haul roads.



### y Unpaved pathway in a forested landscape used at one time or another by vehicles in a logging operation.



### y A road built through natural hab itat, typically to access res ource extraction or recreation activities.



### y Roads are smooth-surfaced corridors for truc k and automobile transportation (NCASI, 2001).

States’ Forest Practice Rules also define diffe rent types and categories of forest roads. Depending on the state, many different forest road categories may be defined, including: mainline, primary, secondary, temporary, perman ent seasonal, permanent all-season forest, collector, spur, administrative, abandoned, vacate d, active and inactive. These definitions often tend to overlap. The forest road definitions usually exclude state and county roads that may cross

forestlands. The definitions also exclude skid trails, which are addressed as timber harvesting operations. However, skid trails involve many of the same issues (lack of soil stabilization, inadequate stream crossings, poor placement), impacts and BMPs as forest roads. These distinctions among types of forest roads are mo re than academic, because forest practice rules and forest road BMPs apply to specific roads. For example, a county road crossing state forests in Oregon is not subject to the Oregon Forest Pr actices Act, because it is not a road owned by a public or private forest manager (T. Lorenson, ODF; letter to A. Wiedeman, USEPA, December 12, 2007).Assessment of Water Quality Impairments Related to Forest Roads Page 13 Contract # EP-C-05-066, TO # 0002 December 4, 2008

There is a rich variety of road standards and road jurisdictions within the National Forests; Figure 2-3 summarizes the legal ba sis and definitions relative to forest roads in the National Forest System (NFS). The USFS definition of a forest road is “any road who lly or partly within, or adjacent to, and serving the NFS and which is necessary for the protection, administration,

and utilization of the NFS and the use and deve lopment of its resources” (Coghlan and Sowa, 1998).

A recent controversy involving negotiations between the USFS and Plum Creek Timber Company over road access in Montana illustra tes how changing land use, driven by economic development, can complicate forest road mana gement issues. Negotiations between the USFS and the nation's largest private la ndowner over use of Montana forest roads could set a precedent for commercial development near forests nationwide, according to the Government Accountability Office (Bontrager, E. 2008).

Until January 5, 2009, the USFS and Plum Creek Timber Co. were engaged in private negotiations for nearly two years to amend shared access easements on forest roads. The easements were conveyed to Plum Creek and its predecessors under the National Forest Roads and Trails Act of 1964 (FRTA), 16 U.S.C. secti ons 532-538, for large tracts of land in western Montana. According to the Government Account ability Office (GAO), the negotiations between the USFS and the nation's largest private landowner over use of Montana forest roads could have set a precedent for commercial development near forests nationwide.

The proposed amendment would have allowed the company, which owns 8 million acres nationwide and 1.2 million in Montana alone, to us e federal timber roads on national forests to develop the company's private holdings adjacent to the forests. Critics of the plans said a roadsharing deal would have made it easier for Plum Creek to sell timberland for development. They

contend the roads were intended for logging only.

The controversy began after a forest ranger info rmed a potential buyer of Plum Creek land that

the easement did not allow access for residential use. That opinion was echoed in a regional

forest memorandum in 2007 that stated that the FRTA easements "were not developed forAssessment of Water Quality Impairments Related to Forest Roads Page 14 Contract # EP-C-05-066, TO # 0002 December 4, 2008

residential use and the roads were rarely de signed to accommodate it safely." (memorandum from Regional Foresters to Forest Supervisor s June 18, 2007But the USFS overruled the ranger following discussions with Plum Creek, agreeing that the company could use certain NFS roads for any purpose, according to the GAO report. The proposed agreement being hammered out between the agency and Plum Creek would allow fo r the company to use the roads for any future development. GAO found that the property valu e of many Plum Creek lands would have a significantly higher value if the amendment is finalized.

2.2 What is the Nature, Extent and Severity of Water Quality Impairments Due to Forest Roads Across the Country?

Roads can have very different effects on wa ter resources depending on road size, design, location, construction, access, usage and maintena nce techniques. Although most roads will have some effect on their watersheds, a small percentage of road area (or length) is often responsible for most of the erosion. For example, in a st udy of road-related erosi on, Rice and Lewis (1986) found only 0.6% of the road length had events disp lacing significant quantities (greater than 15

m 3 , approximately 2 dump trucks) of eroded materi al. Roads creating significant erosion impacts may not be completely controllabl e (McCashion and Rice, 1983).

Forest roads can severely and permanently harm streams and their biota. The water quality impairments due to forest roads include physical, biological and eco logical impacts. Forest roads degrade aquatic ecosystems by increasing levels of fine sediment input to streams and by altering natural streamflow patterns. Constr uction, use and existence of logging roads detrimentally affects stream health and aqua tic habitat by increasing sediment delivery and stream turbidity which adversely affects the survival of dozens of sensitive aquatic biota (salmon, trout, other native fishes, amphibians and macroinvertebrates). Even when well-located and carefully designed, adverse impacts can resu lt from forest roads if they are not properly operated and maintained. Increased fine sediment deposition in streams and altered streamflows and channel morphology result in increased adult and juveni le salmonid mortality, a decrease in aquatic amphibian and invertebrate abundance or di versity, and decreased habitat complexity.Assessment of Water Quality Impairments Related to Forest Roads Page 15 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Some degree of environmental impairment is an inevitable consequence of forest roads. Although the impacts of forest roads are widespr ead, the severity of the resulting impairments vary considerably between locations. In fact , the extent and severity of water quality impairments due to forest roads is debated by vari ous interest groups. This may in part reflect the spatial variability of impairments attributed to forest roads. The variations in rates of erosion, sediment delivery, and the intensity of forestry activities (as measured by road density and traffic levels) lead to vastly different impacts in different locations and watersheds. The issue is further complicated because:



### y The impairments can be difficult to detect and/or measure;



### y Erosion only usually occurs during wet weather;



### y There are no reliable data at the national level to use for such an assessment; and



### y Many studies in the peer re viewed literature were conduc ted 10 or 20 years ago and may not represent present conditions.

This latter point is relevant b ecause, to some degree, the water quality impairments from forest roads have been, and continue to be, a consequen ce of past forestry practices and activities. In some states, such as Connecticut and New Me xico, BMP regulations have changed greatly within a single decade. In other states, in cluding Idaho and Washi ngton, FPRs are almost continuously evolving. Changes in logging systems, reforestation techniques, and environmental protection requirements have meant that the concepts of best fore st management practices have always been evolving (Bisson et al., 1992). The broad changes in road management practices that managers have enacted ar e a result of the gradual deve lopment of water quality and environmental objectives over the past 40 years or more (NCASI, 2001). Thus , the issue of forest roads and their water quality impacts is both dynamic and spatially variable.

In the sections that follow, specific water qualit y impairments attributable to forest roads are discussed, along with factors that cause these impairments to vary. No attempt has been made to distinguish impairments due to historical vers us modern forest management practices, although this can sometimes be inferred from the dates of specific studies.Assessment of Water Quality Impairments Related to Forest Roads Page 16 Contract # EP-C-05-066, TO # 0002 December 4, 2008

2.2.1 Water Quality Impairments

The physical impacts of forest roads on streams, rivers, downstream water bodies and watershed integrity can be dramatic and have been we ll documented. Roads impact watershed integrity through three mechanisms: they intercept, concen trate, and divert water (Williams, 1999). Roads intercept water falling as rainfall directly on road surfaces and cutbanks as well as subsurface water moving underground down the hillslope. They concentrate flow on the road surface and in adjacent ditches and channels. Roads divert bot h surface and subsurface water from flow paths

that otherwise would be taken in the abse nce of a road. The hydrologic and geomorphic consequences resulting from these three processe s can be large, as discussed below. Roads directly affect natu ral sediment and hydrologic regimes by altering streamflow, sediment loading, sediment transport and deposition, channel morphology, channel stability, substrate composition, stream temperatures, water quality, a nd riparian conditions within a watershed (Lee et al., 1997).

Potential effects of roads on water quality include increased loading of sediment due to erosion and mass wasting, increased suspended solids an d turbidity, increased sediment deposition and bed load, siltation of coarse streambed substrates , physical barriers to migration and downstream transport, altered streamflow and pollution from other chemicals associated with road use. The physical and chemical impacts of roads have de trimental effects on fish and other aquatic organisms and their habitat; these are discussed separately in Section 2.2.2.

2.2.1. 1 Increased Loading of Fine and/or Coarse -Grained Sediment Due to Erosion and Mass Wasting

Roads and especially stream crossings are a ma jor source of sediment to streams (Eaglin and Hubert, 1993; Furniss et al., 1991) , and contribute more sediment to streams than any other land management activity (Gibbons and Salo, 1973; Meeh an, 1991). Soil erosion rates were 30 to 300 times higher on forests with roads than undistur bed forest (Furniss et al., 1991). High rates of

stream sedimentation can result from this incr eased erosion. Most fine sediment from surface erosion processes is delivered during common rain fall events and is relatively chronic (FPAC, 2001). A survey conducted in one watershed in th e southeast revealed th at 80 percent of theAssessment of Water Quality Impairments Related to Forest Roads Page 17 Contract # EP-C-05-066, TO # 0002 December 4, 2008

sources of sediment delivery to streams and rivers were from the road prism; i.e., road surface, ditches, banks (van Lear et al., 1995; Grace a nd Clinton, 2006). Surface erosion from forest roads affects the fine sediment budget and may im pose a chronic condition of sediment inputs to streams directly affecting the stream substrate an d the health of aquatic life (Luce et al., 2001).

Surface erosion rates from roads are typically at least an order of magnitude greater than rates from harvested areas, and three orders of magnit ude greater than erosion rates from undisturbed forest soils (NCASI, 2001). For example, estimates of road surface erosi on rates in California, Idaho, and Washington are generally in the range of 10 to 100 tons/acre/y ear (Cline et al., 1981; McCashion and Rice, 1983; WFPB , 1997), with extreme estimates as high as 480 tons/acre/year in Washington’s Olympic Mountains (Reid a nd Dunne, 1984). These extremely high erosion rates may be contrasted with sediment yields measured on undisturbed forested lands in the

eastern and western United Sate s (0.09 tons/acre/year; Gianessi et al., 1986 and Patric, 1984), intact pine forests the southern US (0-0.09 tons /acre/year), clearcut forests with BMPs (0.04-0.18 tons/acre/year), and harvesting and site preparation without BMPs (1.3-6.2 tons/acre/year; Yoho, 1980).

It should be noted that some i nvestigators have reported erosion rates for roads, ranging from 5 to 550 tons/acre/year, whereas others have report ed erosion rates of watersheds containing roads in the range of 0.02 to 2 tons/acre/year. The wide range results from differences in measuring erosion (on the road or at the watershed outlet) and in the f actors causing erosion, including the presence, density, and design of the road ne twork on the watershed (Elliot, 2000). Although a wide range of erosion rates and sediment yields are reported in the literature, all sources agree that these rates are considerably higher in forests containing roads in comparison to areas

without roads.

Bilby et al. (1989) studied erosion from two ki nds of forest gravel roads in southwestern Washington. The sediment produced from each road segment was related to traffic rate and type of road surfacing material. The majority of the sediment produced (80%) was material finer than 0.004 mm. Steeper roads produced a higher proporti on of coarser material (primarily sand). Average sediment concentrations from seconda ry road sites were 2,000 mg/L, with a maximumAssessment of Water Quality Impairments Related to Forest Roads Page 18 Contract # EP-C-05-066, TO # 0002 December 4, 2008

of 19,500 mg/L. Hourly concentrations from a mainline road ranged from 500-700 mg/L, occasionally exceeding 20,000 mg/L.

Roads also greatly increase the frequency of la ndslides, debris flows, and other mass movements (Burroughs et al., 1976; Clay ton, 1983; Dunne and Leopold, 1978; Furniss et al., 1991; Hammond et al., 1988; Megahan et al., 1992). La ndslides have been reported to be the predominant form of erosion from roads in several studies of steep, hazardous (as evidenced by presence of natural failures) terrain (Megahan and Kidd, 1972; O’Loughlin, 1972; Swanson and Dyrness, 1975). Landslides from road fills or sidecast are the most common type of failure, tend to form debris avalanches or debris flows (often down steep draws and small streams), and are the most destructive to downstream fish-bearing channels (Benda et al., 1997; Furniss et al., 1991; Gonsior and Gardner, 1971; O’Loughlin, 1972; Dy rness, 1967). Cutslope failures often block

road ditches and divert concentr ated water onto fillslopes, contri buting to their failure (Dyrness, 1967). The discharge of concentrated road draina ge water, usually from ditches through relief culverts, onto road fills or naturally unstable bedrock hollows also contributes to many failures (Benda et al., 1997).

Road-related landslides and stream crossing failures can result in significant sediment impacts

from the volume of material in the failed fill and also by scouring headwa ter channels for some distance. These types of sediment inputs tend to be episodic a nd are often the result of large rainfall events. Landslides are typically dominant erosion mechanism in areas with steep slopes, the frequency of which can be greatly accelerated by road management practices. Prior to mid1980s, excavated soil and rock from full-bench road construction was sidecast on very steep slopes below road prism. These steep slopes were often associated with landslides.

Weaver and Hagans (1996) found that roads were associated in an apparently causal manner

with 15% to 61% of the new landslides followi ng the February 1996 storm in the Oregon and Washington Cascades and Oregon Coast Range Mountains. That sa me storm resulted in a flood

event in the Fish Creek watershed on Ore gon's Mt. Hood National Forest that caused 236 landslides, of which 34% were attributed direct ly to the road system (Reeves et al., 1997). Similarly, very high associations between the ro ad system and landslides were found in IdahoAssessment of Water Quality Impairments Related to Forest Roads Page 19 Contract # EP-C-05-066, TO # 0002 December 4, 2008

following 1997 spring storms, with 65% of landslides observed in the North Fork Clearwater

Basin and 72% in the Lochsa River Basin a ssociated with roads (Weaver et al., 1998).

McCashion and Rice (1983) investig ated erosion due to forest ro ads and logging in northwestern California. Mass erosion was the predominant form of erosion occurring in the study sites. In steep watersheds, more sediment may be from mass wasting, which tends to deliver greater quantities of sediment to the stream. Road s caused 152 of the 171 ma jor erosional events inventoried and 61% of the soil volume displ aced by erosion was due to these road-related

events. In the Clearwater National Forest in Id aho, 58 percent of the landslides that occurred were associated with roads (McClelland et al ., 1998). Other studies in Oregon, however, suggest that road impacts may have been overestimated (Robinson et al., 1999), a nd that sediment from

landslides in undisturbed ar eas is similar to that in areas with roads.

Soil erosion and mass wasting do not necessarily represent sedi ment contributions to streams (Kochenderfer and Helvey, 1987). Whether er oded soil reaches a stream depends on many factors such as road location, the volume of water available for se diment transport, effectiveness of sediment traps, and slope steepness. Sediment delivery to streams from unpaved forest roads consist of a direct component, which is the sedime nt delivered from road segments leading into stream crossings, and an indir ect component which is the sediment delivered at constructed drainage outfalls and where road surface runoff flows off the roadway before reaching a ditch or drain (Woods et al., 2007). The sediment delivery ratio from road segments leading into stream crossings is close to 100%, so that the direct component of se diment delivery depends almost entirely on the road erosion rate. Active hauling on roads during wet periods results in particularly high erosion rates. The delivery ratio for indirect se diment delivery is less than 100% because a portion of the sediment eroded fr om the road is stored on the hillslope as a plume of sediment that lies on top of the natu ral soil profile. The delivery rate depends on the

distance that sediment travels downslope. Soil losses and erosion occurring closer to a stream have greater potential to deliver sediment and lead to water quality impairment. Stream crossings have the greatest potential to adversely imp act water quality on the forest landscape (Grace, 2002). Ligon et al. (1999) noted that the most common source of sedimentation was from fillslopes immediately adjacent to watercourse crossings. Plugged culverts and fill slope failuresAssessment of Water Quality Impairments Related to Forest Roads Page 20 Contract # EP-C-05-066, TO # 0002 December 4, 2008

are frequent and often lead to catastrophic increases in stream channel sediment (Furniss et al., 1997).

Researchers worldwide have measured increa sed sedimentation from roads and similar disturbances (Elliot, 2000). The magnitude of eros ion varies considerably with climate, but the relative impacts of soil, topography, and management are generally the same (Elliot et al., 1999). Erosion rates are observed to be highly variable, due to the high natural variability in the factors

that cause erosion. Even a well desi gned erosion experiment frequent ly results in variations from the mean of up to 50 percent. Th is high variability should be c onsidered when interpreting any research or monitoring results, or any erosion prediction value.

Road age and wet weather use are factors that strongly influence surf ace erosion (FPAC, 2001; Swift, 1988). Research shows newly constructed/ reconstructed roads may have 10 times more surface erosion the first winter after construction compared to subs equent years, resulting from increased erodibility because of soil disturbance during cons truction and lack of erosion pavement and vegetation to protect the soil surfac e. During periods of wet weather, road surfaces not constructed with adequate su rface materials and spacing of drai nage structures are a potential source of fine sediment delivery by allowing sedi ment laden water to enter stream channels directly. Fill failure is also a risk (FPAC, 2001).

Water quality effects of fire roads, all-terrain vehicle (ATV, also known as off-highway vehicle or OHV) trails, and public access an d recreation trails have not been studied as extensively as roads built for forestry operations. Unmanaged AT V use is a “spotlight is sue” representing this

threat because of the unauthorized creation of ro ads and trails and the associated erosion, waterquality degradation, and habitat destruction. An estimated 11 million visits to National Forests involve ATV use; this constitutes about 5 percen t of all recreation visits to national forests (English, 2003).

Repeated cross-country forays by ATV traffic resu lts in the uncontrolled pr oliferation of trails.

Unauthorized trails from motorized use currentl y cause much of the natural resource damage on National Forests, and are a major problem for fo rest managers. For example, Lewis and ClarkAssessment of Water Quality Impairments Related to Forest Roads Page 21 Contract # EP-C-05-066, TO # 0002 December 4, 2008

National Forest personnel in Montana currently estimate that the forest has 1,348 unauthorized roads and trails extending for 646 miles (Robe rtson, 2003). ATVs often blaze new paths through forests and these roads are typically unmonito red and unmaintained. The magnitude of effects varies depending on local characteristics of the landscape includi ng slope, aspect, soil susceptibility to erosion, and ve getation type. Riparian areas and riparian and aquatic species are particularly vulnerable to ATV damage. Heavy use of trails can accelerate erosion, compact soils and decrease infiltration, leading to changes in discharge magnitude/timing, channel structure, sediment routing through forest streams, and habitat destruction. Impacts may be more pronounced in the case of ATV trails, where user s develop improperly loca ted trails in addition to designated ones (Chin et al., 2004).

The Ouachita National Forest in Arkansas has 67 km of designated ATV trails. Because of prevalence of off-road exploration and ease with which ATVs traverse rugge d terrain, users also developed a network of unauthori zed trails. These can be especi ally erosive and potentially exacerbate negative impacts of planned trail syst em on stream channel in tegrity. Studies of two impacted creeks (Chin et al., 2004) indicated that watersheds with ATV trails had pools with higher percentages of sands and fines, lower de pths, and lower volumes. High turbidity levels

were observed in surface runoff from ATV trails entering creeks after light rainstorms. Pools below ATV trail crossings were sediment-laden and turbid.

Roads provide access to a wide variety of activ ities within the Wilson River watershed (Duck Creek Associates, 2008). From timber harvesting and log hauling to recreating with ORVs and motorcycles, the roads within the watershed are well used and often a busy place. During a 2006 road inventory, 42 miles of ORV trails were surv eyed, representing 28% of the designated trails but only ~5% of the undesignated trails. Undesignated trails are not maintained and tend to have steep gradients, high erosion, and impaired draina ge. Thirteen trails hydro logically connected to

streams were assessed for risk of washout. Results indicated that trail-stream and trail-road intersections were very likely to adversely affect water quality becau se the majority of hydrologically-connected trails violated trail construction guidelines (trail grades <10%, slope alignment < 1⁄2 sideslope grade). Many of the worst hydrologically connected trails were undesignated or user-created with no regard for design standards. Furthermore, none of theAssessment of Water Quality Impairments Related to Forest Roads Page 22 Contract # EP-C-05-066, TO # 0002 December 4, 2008

undesignated trails are maintained as they are no t part of the Oregon Department of Forestry (ODF) OHV-designated trail system. These unde signated trails have high impacts on water quality and are common enough throughout the waters hed to be a concern. Soil erosion estimates were made for seven sample trail segments; th e results indicate that hydrologically connected OHV trails are a significant source of sediment, especially consid ering the year round nature of use and the back log of repair and closure facing ODF staff.

2.2.1. 2 Increased Suspended Solids and Turbidity

Suspended sediment transport is generally “source limited” in rivers and streams, meaning that concentrations of suspended so lids and surrogate measures (e .g., turbidity) depend on sediment loading (Beschta, 1981). In many regions, total suspended solids (TSS) concentrations are low (<5 parts per million or ppm) under dry weat her condition, but increase to high peak concentrations (~100 ppm or higher) during majo r rainfalls. Since forest roads can increase sediment loading, it is reasonable to expect suspended solids and turb idity to increase in impacted surface waters. However, there is usually a great deal of uncertainty in determining

when and how much sediment from an erosion fe ature was delivered to a stream channel (Lewis, 1998). It can be even more difficult to determine th e origin of suspended sediment that has been measured at a stream location. To some degree, this is because the biotic and chemical variability in rivers and streams tends to mask the water qua lity effects of forestry activities (Jackson et al., 2004). Just as environmental char acteristics (soil texture, slope , road aspect) and regional variability both significantly affect sediment lo ading, these and other fact ors can also affect the water quality response.

Forest management activities, such as road construction, often cause concentrations of suspended sediment to increase. However, this is not always the case. Figure 2-4, reproduced from Binkley and Brown (1993), plots suspended sediment concentrations in undisturbed (control) and disturbed (treatment) experimental forested watersheds. Points on the graph in Figure 2-4 that fall fairly clos e to the 1:1 slope line indicat e similar suspended sediment

concentrations in undisturbed and disturbed forested situations. Many of these cases are due to proper implementation of BMPs. Local variability in soil erosivity can also affect water qualityAssessment of Water Quality Impairments Related to Forest Roads Page 23 Contract # EP-C-05-066, TO # 0002 December 4, 2008

due to sediment loading. In regions where BMPs were not imposed, substantial and variable

increases in sediment concentrations occurre d. These cases are also evident on the graph in Figure 2-4, as points where the di sturbed suspended sediment concentrations are an order of magnitude (or more) greater than in the undisturbed fo rest situations.

The use of gravel-surfaced roads during wet peri ods has been documented as a major source of fine-grained sediment and associated stream tu rbidity (Mills et al., 2003; Reid and Dunne, 1984). Impacts of water quality on fish and aquatic organisms have motivated much of the research. Sediment-laden water supplies also reduce the ca pacity of storage reservoirs and may require

additional treatment to render the water drinkabl e (Lewis, 1998). Sediment in irrigation water shortens the life of pumps and reduces soil in filtration capacity. Water quality is also an important issue for recreationa l water users and tourism.

There is also much evidence in the literature demonstrating the difficulty in evaluating the impacts of roads and other logging activities on erosion and suspended sediment transport. Monitoring and evaluating forestry impacts on st ream water quality is usually complex, time consuming, and expensive (Corner et al., 1996). Monitoring projects based on instream sampling often result in incomplete or inconclusive data, es pecially in remote areas. This is partially due to the inability to predict the timing of sediment -producing events and the many technical problems associated with water quality sampling and anal ysis. For example, Corner et al. (1996) found that instream monitoring did not reveal any significant differences in total suspended solids (TSS) between clearcut and control sample locations at three sites. On each site, data for stream TSS were generally characteri zed by high variability and low values. The data were not significantly correlated to stream discharge. Ou tliers did not necessarily correspond to sample collection dates that coincided with precipitation events, nor did they occur exclusively at the

clearcut and road locations. The instream monitoring indicated th at clearcutting and access roads

did not effect stream sediment loads in th e summer after logging. Many other studies have produced similar results. Hetherington (1976), fo r example, found no statistical difference in suspended sediment concentration above and be low logged areas in British Columbia. Sullivan (1985) demonstrated that, even with automate d equipment sampling stream water at 6 hour intervals, large volumes of sediment can ente r stream channels and be flushed off-siteAssessment of Water Quality Impairments Related to Forest Roads Page 24 Contract # EP-C-05-066, TO # 0002 December 4, 2008

undetected. Furthermore, Beschta (1978) noted that the natural variability in the sedimentdischarge relationship often makes relatively sm all changes in sediment concentrations very difficult to detect at a point in the stre am system, even with intensive sampling.

Bilby (1985) measured the size of sediment washing from a gravel-surfaced road and its fate after entering Johnson Creek, Washington. After rain fall events, sediment input from the road frequently increased the levels of suspended se diment downstream of the culvert compared to upstream levels. Maximum turbidity reached downstream was almost three times the maximum recorded upstream. The sediment was primarily very fine particles (more than 80% less than 0.004 mm in size) and was attributed to erosion from the road surface rather than roadside

ditches or banks.

In a project to monitor fine sediment delivery to streams, Mills et al. (2003) measured turbidity responses in forest streams near road crossings. For a typical site delivering sediment to streams, peak turbidity downstream from the road crossing was 110 nephelometric turbidity units (NTUs) while peak turbidity above the road was 40 NTUs (Lewis, 1998). A wide range of changes in turbidity was observed during the two winters of field monitoring. Thirty percent of the sample pairs showed no change or a decrease in turbidity downstream of road crossings. Ninety percent of the sample pairs showed a change of 20 NTUs or less. The remaining 10% of the observations ranged from an increase in turbid ity of 20 to 520 NTUs. Increases in stream turbidity levels at stream crossings during periods of wet weather hauling appeared to be impacted by several factors including precipitation, surfacing material, drainage design, and traffic factors. Depending upon these site-specific factors, as we ll as the technical difficulties of monitoring discussed above, increases in turbidity or suspended sedime nt concentrations may be undetectable, even when other impacts of forest roads are taking place.

2.2.1. 3 Increased Sediment Deposition and Bed LoadAssessment of Water Quality Impairments Related to Forest Roads Page 25 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Sedimentation is the end result of several pr ocesses, including erosion; sediment delivery, transport and deposition; and in stream morphological processes. Erosion and mass wasting

associated with forest roads can deliver both fi ne and coarse-grained sediment to water bodies. While fine-grained sediment is usually transpor ted suspended in the water column, coarse solids are mostly transported as bed load. Bedload transport is “flo w limited”, meaning that coarsegrained sediment is usually only transported and redeposit ed at high flow rates (Beschta, 1981). Deposition during and following large flow ev ents can significantly change channel characteristics in low-gradient stream reaches . Although many of these changes (e.g., filling of pools reducing pool frequency, depth and volume) ar e associated with negative impacts on biota, stream habitat can be potentially enhanced if mass erosion delivers material to streams where

coarse sediment is limited.

The capacity of a stream to carry sediment also increases with stream velocity. At a given flow, velocity varies within channels longitudinally and in cross se ction. Thus, channel erosion and sedimentation occur simultaneously. The magnitude of these processes is affected by flow rate; high flows increase channel erosion, and lo w flows increase sedimentation, or deposition (Prud’homme and Greis, 2002). These relationships are far from straightforward, however, because in many forest stream sy stems, other factors such as large woody debris or bedform are

the dominant controls on str eambed texture (Buffington, 1995).

Methods for measuring bedload transport are relatively crude, and correctly timing bedload sampling to observe transport due to management activities is difficult (Ha rris et al., 2005). Data regarding bedload transport may be best cap tured with channel geometry and substrate measurements in depositional stream reaches. Unless a stream can be intensively monitored during high flows or a settling pond exists with in a channel, bed load measurements are unreliable to the extent that they should not be monitored (Corner et al., 1996).

2.2.1.4 Siltation of Coarse Streambed SubstratesAssessment of Water Quality Impairments Related to Forest Roads Page 26 Contract # EP-C-05-066, TO # 0002 December 4, 2008

The abundance and quality of spawning substrate can be severely affected by sedimentation. Coarse gravel channel substrates are a critical habitat requirement for many stream organisms including salmonids and aquatic amphibians a nd invertebrates, and are considered a scarce resource. Fine sediment deposition may alter the quality of these gravel streambeds as fine sediment particles embed (cover) the larger particles and fill in the interstitial space in gravel substrates. Deposition may occur well downstream of the sediment source(s), because once fine

sediment is delivered to a stream it can be tr ansported relatively far dow nstream to a deposition location. In low-velocity stream reaches, excess deposition of fine sediment can completely cover suitable spawning gravel. Massive levels of fine sediment delivery can also produce changes in channel habitat by reduci ng pool frequency, depth and volume.

Burns (1984) found that roaded and logged watershe ds in the South Fork Salmon River drainage had significantly higher channel bed subs trate embeddedness ratings than undeveloped watersheds. Siltation of spawning gravels can occur ra pidly in response to road impacts. Platts et al. (1989) studied the effects of fine sediment delivery to rivers from logging and road

construction in habitat for Chinook salmon and steelhead. After logging ceased, there was a significant decline in th e percentage of fine sediment (m aterial <4.75 mm in diameter) on the surface of 84% of the spawning area locations. Within two years of resuming logging, however, surface fine sediments increased at all five sp awning areas, with overa ll increases of 22.2% to

83.8%.

Although streambed siltation has been reported to be a widespread impairment of sediment from forest roads, a number of studies have f ound no such impact (Adams, 1994). In Johnson

Creek/Deschutes River of Washington, Bilby (1985) reported th at sediments eroded from road surfaces were deposited on the streambed during lo w flow, but were “flushed” from the system by high flows. No increase in fine sediment was found in streambed gravels. The lack of deposition was attributable to sm all particle sizes of road sedi ment. Sullivan (1985) studied the Middle Fork Santiam River of Oregon in the Cascade range. Water quality remained good during the first decade of extensive timber harvest. Sediments eroded from road construction and road surfaces contributed to instream sediment yield, but the effect on an annual timescale was not detected within the natural variability of the erosion processes.Assessment of Water Quality Impairments Related to Forest Roads Page 27 Contract # EP-C-05-066, TO # 0002 December 4, 2008

2.2.1. 5 Alteration of Stream Morphology (E.G ., Reduced Pool Volume) and Channel Simplification

The increased sediment flux into streams that is associated with roads causes aggradation 5

, filling of pools, and increased channel widths and width-to-depth ratios (Jackson and Beschta, 1984; Lisle, 1982; Madej, 1982). Increas es in width/depth ratios in sensitive streams can result in higher summer water temperatures even when shade is not lost (B eschta et al., 1987; McCullough, 1999). With increasing road density th ere is a clear decline in the frequency of pools and large pools, fundamental components of high-quality fish habitat (Lee et al., 1997). Significant aggradation at channel transitions such as tributary confluences or road crossings can

force streamflows subsurface.

Forest roads can have other impacts on stream morphology. Unnatural channel widths and slope and stream bed form can occur upstream and downst ream of road crossings, and these alterations in channel morphology may persis t for long periods of time ( Williams, 1999; Heede, 1980). Concentration and diversion of flow by roads into headwater areas can cause incision of previously unchanneled portions of the landscape (Montgomery, 1994). Roads are sometimes placed partially in an existing stream channel. Riprap is placed to prevent erosion of the road fill, resulting in a dramatic change in channel form (Luce et al., 2001).

2.2.1. 6 Physical Barriers to Fish Migration a nd Downstream Transporto Coarse Sediment and Large Wood

Structures associated with forest road crossi ngs of streams are potentia l barriers to movement and migration of fish (Clancy and Reichmuth, 1990; Evans and Johnston, 1980; Furniss et al., 1991). Road crossings, especially culverts (which are also the mo st widely used crossing type), can pose as obstacles to the movement of fish a nd other aquatic biota, as well as sediment and large wood (Cupp et al., 1999). Reducing the number of road crossings of streams or using alternatives to culverts, includi ng temporary road crossings such as portable bridges, are BMPs that can greatly reduce these im pacts (see Section 3).

5 Aggradation is the accumulation of sediment in streams and rivers, that occurs when the supply of sediment exceeds the ability of the stream to transport the sediment.Assessment of Water Quality Impairments Related to Forest Roads Page 28 Contract # EP-C-05-066, TO # 0002 December 4, 2008

In western streams, anadromous salmonids migrate upstream/downstream during their life cycles, usually over long distan ces. Many resident salmonids and other fish also move extensively upstream/downstream seeking food, shelter, water quality and spawning areas. Improper culvert placement and in stallations used for stream crossings may create partial or

seasonal barriers to fish movement while others may reduce or eliminate fish passage year-round (Belford and Gould, 1989; Beechie et al., 1994). Culverts may also delay or deny access to seasonally critical habitats, fragment populati ons, and suppress the recovery of populations following disturbance.

A number of physical conditions at stream cro ssings create migration barriers (USEPA, 2005). The two most important fish passage considerat ions are maximum water velocity and minimum depth. Culverts can be insurmountable barriers to migrating fish when culvert outlet is elevated above the streambed that fish cannot enter the pi pe; this is termed an outfall barrier. It is considered acceptable culvert de sign practice to not require cond itions suitable for fish passage during the 5% of the year with highest flow s (Evans and Johnston, 1980) because fish don’t normally migrate during peak flow.

The removal of large organic debris at stream crossings can eliminate important components of fish habitat (Furniss et al., 1991). Road systems al so have the potential to block the downstream movement of large wood (LW). Where a stream crossing blocks the passage of LW there is potential for dam-break flood to occur. When a downstream reach depends on a supply of LW delivered during peak flows, road crossings not designed to pass LW can reduce upstream sources of wood and have a negative effect on ri parian functions and habitat conditions (FPAC, 2001). Extreme sedimentation above or below road crossings can cause st reamflow to become

subsurface or too shallow for fish movement (Furniss et al., 1991).

Increasing numbers of culverts ha ve been correlated with increas ing amounts of fine sediment in streams and decreasing fish densities. Eaglin a nd Hubert (1993) studied the effects of logging

and associated road construction on streams and on trout populations in the Medicine Bow National Forest, Wyoming. Both the amount of fine sediment in a stream reach and theAssessment of Water Quality Impairments Related to Forest Roads Page 29 Contract # EP-C-05-066, TO # 0002 December 4, 2008

embeddedness of fine sediment in the substrat e increased as the proportion of logged area increased, and as the extent to which roads crossed watercourses in creased. Trout standing stocks also decreased as the density of road culverts increased.

It should be noted that culver ts and other road crossings can pose migration barriers beyond the forest landscape. A survey of county and state highways in western Oregon in 1999 found more than 1,200 culverts acted as barriers to fish pa ssage (FPAC, 2001). These highways are typically

located downstream of forestlands and therefore may limit or block access to upstream fish habitat. The relatively large netw ork of nonforest roads in close proximity to streams that are currently providing (or have poten tial to provide) quality fish habitat are likely to have significant impact on salmonid maintenance and recovery.

2.2.1. 7 Altered Streamflow

The most dramatic and visible effect of a road of ten is its effect on the flow of water through the watershed (Williams, 1999). Runoff is low from undisturbed forests, but runoff rates from rainfall and snowmelt are greater from compacted ro ad surfaces than from less disturbed parts of watersheds (Elliot and Hall, 1997). The presence of roads in a watershed may increase the frequency and magnitude of peak runoff discha rges, particularly on small watersheds. Roads may also increase total runoff and decrease the time to peak runoff from major storms or snowmelt (Elliot, 2000). Roads interrupt hillslop e drainage patterns by intercepting surface and

subsurface flow and concentrati ng and diverting it into ditches, gullies and channels, thereby effectively increasing the density of streams in the landscape and altering the timing and magnitude of peak flows and changing base stre am discharge (Furniss et al., 1991; Harr et al., 1975; King and Tennyson, 1984; Wemple et al., 1996) and sub-surface flows (Furniss et al. 1991; Megahan, 1972).

In some instances, road-induced changes in wa tershed hydrology can have serious consequences. However, the magnitude of road effects on peak flows is debated in the literature (Ice et al., 2004). The impact may depend on the fraction of the forested watershed area occupied by roads. King and Tennyson (1984) monitored the eff ects of logging roads on streamflow on sixAssessment of Water Quality Impairments Related to Forest Roads Page 30 Contract # EP-C-05-066, TO # 0002 December 4, 2008

headwater watersheds in Nez Perce National Fore st in north central Idaho. In one watershed, with 3.9% of its area disturbed by roads, ther e was an increase in the 25% exceedance flows (streamflow during snowmelt runoff and summer storms), attributed to interception of subsurface flow by the roads and conversion to surface flow. Another watershed, with 4.3% of its area in roads, showed a significant decrease in the 5% exceedance flow, which represents the period of highest flow.

2.2.1. 8 Pollution From Other Chemicals Associat ed With Roads (Spills, Deicing and Dust Control Agents, Herbicides)

Roads can also contribute to water quality degrad ation through runoff of applied road chemicals (Furniss et al., 1991; Norris et al., 1991; Rhodes et al., 1994) incl uding herbicides, as well as toxic spills (Furniss et al., 1991; IDT, 1996). In recen t years, the use of chemical site preparation has become increasingly common, as indicated by the establishment of BMPs for the proper use of chemicals during forest management in many states (Williams, 1999). The use of herbicides dramatically lowers the threat of sediment tran sport to streams compared to disking and other tillage treatments by not disturbing the soil surf ace. For example, Michigan’s BMP manual states that herbicides have an “...advantage over mechan ical means [of site preparation] because there

is no soil disturbance and can be used where st eep slope prevents use of machinery “ (MI DNR & DEQ, 1994). According to NCASI (2007), the potential of impacts to water quality that result from herbicide transport to streams has been demons trated to be small. Analyses of streamwaters associated with the Texas Intensive Forestry Study (TIFS) for hexazinone, imazapyr, and sulfometuron methyl showed ma ximum hexazinone concentrations in the range of 20 to 30 ppb

in waters associated with storm events within approximately 30 days after treatment (DAT), dropping to approximately 1 ppb by 140 DAT (NCASI, 2007a). Maximum imazapyr

concentrations in waters associated with storm events were in the rang e of 30 to 40 ppb within approximately 20 DAT, dropping to approxima tely 1 ppb by 150 DAT. Maximum sulfometuron methyl concentrations in waters associated with storm events were in the range of 2 to 3 ppb within approximately 20 DAT, dropping to appr oximately 1 ppb by 30 DAT. Some details of a screening analysis for determin ation of dissolved glyphosate to 0.2 ppb are also given, and the results from analyses of some composite samp les of TIFS waters are reported. A screening analysis for determination of dissolved glyphosate indicated maximum glyphosateAssessment of Water Quality Impairments Related to Forest Roads Page 31 Contract # EP-C-05-066, TO # 0002 December 4, 2008

concentrations in water associated with storm events on the order of 10 ppb within approximately 30 DAT, dropping to approxima tely 1 ppb by 100 DAT. Because the water quality impact of other chemicals is discussed only incidentally in most of the literature on forest roads, it will not be a focus of this report.

2.2.2 Degradation of Habitat for Salmonids, Othe r Fish, Invertebrates, and Other Aquatic Organisms

The physical impacts of roads have detrimental effects on fish and fish habitat. Mechanisms through which roads exert these deleterious impact s include fine-sediment effects, changes in streamflow, changes in water temperature caused by loss of riparian co ver or conversion of groundwater to surface water, and migration barr iers. The physical impact s of roads discussed above have a widespread and profound effect on fish habitat and fish communities and populations across a range of environmen ts and conditions (Lee et al., 1997).

Serious degradation of fish habitat affecting all life-stages of fish es (including migration, spawning, incubation, emergence, and rearing) can result from poorly planned, designed, located, constructed, or maintained roads, as dem onstrated in numerous st udies conducted in the Pacific northwest (Furniss et al., 1991; Henjum et al., 1994; MacDonald et al., 1991; Rhodes et al., 1994). Well-known native aquatic species affect ed by turbidity and sedimentation are salmon (coho, chinook and chum), steelhea d, and trout (cutthroat and rai nbow) as well as other native fishes and amphibians (salamanders, tailed frogs).

Sedimentation can have obvious cons equences in stream systems, of ten leading to complete loss of salmonid fisheries (Berry et al., 2003). The effects of roads on salmonid habitats have been most studied, including effect s on migration, spawning, incubati on and juvenile rearing:

Migration- Improperly designed roads prevent and interfere with upstream migration of adult and juvenile salmon, and also impair a nd/or prevent macroinvertebrate movements by road-related changes to stream channels (P earce and Watson, 1983). Cu lverts pose the most common migration barriers associated with roa d. Improperly designed and maintained culverts

can be insurmountable barriers to mi grating fish (Fur niss et al., 1991).Assessment of Water Quality Impairments Related to Forest Roads Page 32 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Spawning- Adult salmon have exacting habitat requirements for spawning, including requirements for substrate sizes, depth and velocity. The abundance a nd quality of spawning substrate can be severely affected by sedimentat ion. In low-velocity stream reaches, excessive fine sediment can completely cover suitable spawning gravel. Gravel extraction for road construction may directly remove suitable spawning substrate.

Incubation - If gravel interstices fill with fine sediment, egg development may be slowed

or halted.

Juvenile rearing - Large amounts of fine sediment reduce and/or eliminate suitable substrate producing macroinvertebrates, which comp rise most of the diets of juvenile fish.

Modification of stream channe l configurations, decreasing the number and depth of pools, reduce the space available for rearing fis h, and can lead to reduced survival.

Road construction near streams also often dire ctly removes riparian vegetation. The essential role of large woody riparian debris in salmon streams is reviewed in Bisson et al. (1992).

Because of their great importanc e to the region, the majority of research on fish population

abundance in the Pacific Northwest has focused on salmon and trout. Very little is known about the effects of cumulative habitat changes on th e abundance of most non-salmonid species. Some may be more sensitive to habitat change than anadromous salmonids, because they spend their entire lives in freshwater and may be associated with a specific type of habitat. There have been no studies that have attempted to assess the a bundance of non-salmonid popul ations at the scale of drainage basins in the Paci fic Northwest (Bisson et al., 1992) . A change in the abundance of a single species may not be a useful measure of th e cumulative effects of forest practices on fish populations in a river system. Inst ead of using trends in designated “indicator species” to gauge the cumulative effects of forestry operations, a po tentially more powerful approach is to examine the relationship between forestry-related habitat changes and the structure of fish communities in

streams and rivers.Assessment of Water Quality Impairments Related to Forest Roads Page 33 Contract # EP-C-05-066, TO # 0002 December 4, 2008

2.2.2.1 Sediment

The increased sediment flux into streams that is associated with roads ca uses aggradation, filling of pools, and increased channel widths and wi dth-to-depth ratios (Jackson and Beschta, 1984; Lisle, 1982; Madej, 1982). These changes are associated with widespread and profound impacts on fish and other aquatic biota in streams, and ar e well documented in the scientific literature. Of all of the taxonomic groups, fishes , particularly salmonids, have received the most attention from researchers (Waters, 1995). This is because of the commercial and recreational importance of salmonids, and the obvious impact that loggi ng and other land use activities have had on salmonid fisheries, particularly in the Pacific Nort hwest. In California, a ll species of anadromous salmon are in serious decline and many local stocks have been completely extirpated. Coho have experienced some of the most precipitous declines of all west coast salmon and are at critically low levels today (EPIC, 2002).

The effects of increased embeddedness, on salmonids in particular, have been well documented (e.g., Waters, 1995). As pools are filled by sediment they support fewer fish and the individuals that reside in them suffer higher mortality (Alexander and Hansen, 1986; Bjornn et al., 1977). Furthermore, elevated levels of fine sediment adversely affect salmonid embryo survival (Bjornn and Reiser, 1991; Chapman, 1988; Everest et al., 1987) and have been linked to decreased fry emergence, decreased juvenile densities, loss of winter carrying capacity via loss of concealment cover, and increasing preda tion (Bjornn et al., 1977; Ch apman, 1988; Chapman and McLeod, 1987; Everest et al., 1987; Scri vener and Brownlee, 1989; Thur ow, 1997; Weaver and Fraley, 1993; Young et al., 1991). Fine sediment depositi on in spawning gravels smothers fish eggs. Increased fine sediment in stream gravel reduces intra-gravel wa ter exchange, thereby decreasing oxygen concentrations, increasing me tabolic waste concentrat ions, and restricting movements of alevins (Bjornn and Reiser, 1991; Chapman, 1988; Coble, 1961; Cordone and Kelly, 1960; Everest et al., 1987). This loss of unembedded interstitia l areas in stream substrates also is

correlated with a severe reduction or elimina tion of tailed frogs (Corn and Bury, 1989; Welsh, 1990) and benthic organism populations (Chutter, 1969; Hynes, 1970). Incr eased fine sediments in rearing areas are also correlated with redu ced juvenile salmonid densities (Alexander andAssessment of Water Quality Impairments Related to Forest Roads Page 34 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Hansen, 1986; Bjornn et al., 1977; Chapman and McLeon, 1987; Everest et al., 1987; Shepard et al., 1984).

Numerous studies have indicated that high sediment levels can affect fish by increasing mortality, reducing growth rates, causing physiol ogical stress, impairi ng homing instinct, and reducing feeding rates (FPAC, 2001). Efforts to re late sediment concentration to fish response have had mixed results (Everest et al., 1987) . Some studies have found that increased sedimentation reduces egg and al evin survival. Not all sediment increases have detrimental effects; there are cases where fish have maintain ed large and viable fish populations in streams with high chronic loads of fine sediment. Fish appear to re act most negatively when fine sediment concentrations are both high a nd persistent (Newcombe and MacDonald, 1991). Newcombe and Jensen (1996) reviewed 80 pub lished studies on the re sponse of fish to suspended sediment in streams. Adult and juveni le salmonids exposed to particle sizes of 0.5- 250 μm showed an increasingly negative response as sediment dose increased, and sublethal and lethal effects occurred at high doses.

Fine grained sediment suspende d in the water column contribu tes to turbidity (along with organic and dissolved material) wh ich is clearly linked to fish fo raging efficiency (Madej et al., 2003). For example, increased turbidity is associ ated with impaired salmonid sight-feeding and gill damage (Rhodes et al., 1994; Lloyd et al., 1987).

Chapman (1988) reviewed laboratory and fiel d studies on salmonid embryo survival. The majority of studies showed that survival rates d ecreased as the percentage of fine sediments in stream substrate increased, as illustrated in Figure 2-5. Si ze of emergents was also found generally to decrease as fine sediment levels increased. Despite the vari ability among studies in quantitative results, they consistently showed the adverse impacts of fine sediments on salmonid survival. Extrapolation of labor atory results to natural stream s was judged to be currently impossible without better sampling techniques, and that establishing thresholds was not yet feasible without more carefully controlled field experimentation. Scrivener and Brownlee (1989) investigated the effect of logging practices on gravel composition utilized by salmonids for spawning a nd fry survival in Carn ation Creek on the westAssessment of Water Quality Impairments Related to Forest Roads Page 35 Contract # EP-C-05-066, TO # 0002 December 4, 2008

coast of Vancouver Island. After logging, the percentage of fine sediment increased in the streambeds, although the patterns of deposition and proportion of fine sedi ment in the streambed varied among treatments and timing of logging. After logging and a subsequent large snowmelt event, the survival to emergen ce rates of coho salmon fry declined to 16.4%, compared to a prior

survival rate of 29.1%. The declin e was correlated to d ecreasing mean particle sizes in the lower layers of the streambed cores. Survival to emer gence of chum salmon fry declined from a prior rate of 22.2% to 11.5% post-logging, and was corre lated to decreasing mean particle size in the whole streambed core and in the top layers of th e core. Peak survival occurred during years when pea gravel and sand were washed out from the top layer. Phillips et al. (1975) conducted laboratory ex periments at the Alsea Watershed Study field station. As the proportion of fine sediment in the gravel mixtures increased, coho salmon fry emerged earlier and were smaller in size. Their survival rates decreased as fine sediment percentage increased, from 96% survival in the control gravel mixture to 8% survival in the mixtures containing 70% sand. Hillman et al. (1987) investigated th e effect of fine sediment on juvenile chinook salmon, particularly the impact of fine sediment deposition on winter survival. Salmon winter rearing densities in creased eightfold in glide areas (slow, shallow areas) after cobble was added, compared to densities the pr evious year. A significan tly higher density of young chinook salmon (five times higher) used intersti tial spaces in the altere d areas than in the unaltered areas. When the cobble subsequently became heavily embedded with fine sediment, juvenile salmon densities decr eased by more than 90% and we re similar to densities prealteration.

Survival of incubating salmonids from embryos to emergent fry has been negatively related to the proportion of fine sediment in spawning gravels (Chapman, 1988; Everest et al., 1987; Scrivener and Brownlee, 1989; Weaver and Fral ey, 1993; Young et al., 1991). As a rule of thumb, a 2% reduction in survival of coho salmon fry to emergence can be expected for each 1% increase in percent fines over natural levels (C ederholm et al., 1981). Juvenile salmonid densities decline as fine sediment concentrations increase in rearing areas. Increases in fine sediment can also reduce winter carrying capacity of streams by loss of concealment cover. Pools that lose volume from sediment (Jackson and Beschta, 1984; Lisle, 1982) support fewer fish (Bjornn et al., 1977), and fish that reside in them may suffer higher mo rtality (Alexander and Hansen,Assessment of Water Quality Impairments Related to Forest Roads Page 36 Contract # EP-C-05-066, TO # 0002 December 4, 2008

1986). McHenry et al. (1994) reporte d that no steelhead or coho eggs survived if more than 13%

fine sediment intruded into the redd 6 . Fine sediment can also affect the population of aquatic insects (Hicks et al., 1991). Similarly, populations of tailed frogs can be severely reduced or eliminated by increased sedimentation. Increa sed sediment reduces populations of benthic organisms by reducing interstitial spaces and fl ow used by many species and by reducing algal production. Waters (1995) consider ed the effects of increased de position of sediments on benthic invertebrates as one of the most important c oncerns within the sedi ment pollution issue, especially in regards to th e dependence of freshwater fi sheries on benthic productivity. Welsh and Ollivier (1998) studied the impact of highway construction and the resulting erosion on the abundance of stream amphibians in Califo rnia old-growth redwood forest. The density of Pacific giant salamanders and southern torrent salamanders was significantly lower in streams impacted by road sediment. The density of tailed frogs was lower in their preferred riffle and step run habitat in sedimented streams as oppos ed to control streams. Corn and Bury (1989) compared the occurrence and abundance of am phibians in streams flowing through unlogged forest versus streams flowing through forest s with prior logging in Oregon's Coast Range. Results were analyzed for the four amphibian species reported to be the most common and the

dominant vertebrates of small streams in the Oregon Coast Range: tailed frogs ( Ascaphus truei ), Pacific giant salamanders ( Dicamptodon ensatus ), Olympic salamanders ( Rhyacotriton olympicus ), and Dunn's salamanders ( Plethodon dunni ). All four species occurred more frequently and had higher density and biom ass in the streams flowing through unlogged as opposed to logged forest stands. The only physical habitat variable found to be significantly

different between stand treatment was that str eams in logged stands had more fine sediment. Studies from Oregon, Idaho, British Columbia, a nd Alaska, for instance, showed that salmonid abundance and fry survival decreased as fine sedi ment levels increased after logging (Hicks et al., 1991). Fine sediment in deposits or suspensi on also reduced the av ailability of food in streams by reducing invertebrate abundance and primary production. Suspended sediment

increases were shown to affect salmonids in various ways, including avoidance, cessation of feeding, and disrupted social behavior. The in creased frequency of la ndslides and other mass erosion events due to logging and roads ch anged channel morphology, reducing pool area and depths and resulting in stream reaches that we re wider, shallower, and more prone to bank

6 Redd: The depressions in a gravel streambe d created by salmonids to deposit eggs.Assessment of Water Quality Impairments Related to Forest Roads Page 37 Contract # EP-C-05-066, TO # 0002 December 4, 2008

erosion. Studies in British Columbia, for instan ce, showed that pool habitat was reduced by an average of 79% in streams affected by debris to rrents and suitable wint er cover was reduced by an average of 75%. Coho salmon winter survival averaged 1.8% in stream reaches affected by debris torrents compared to su rvival rates of 24.5% in unaffected streams. The authors discussed studies showing salmonid abundan ce initially increasing after clea rcutting. They note that these increases were documented only over the short term and that over the longer term (after 10 to 15 years), other research had indica ted that populations could eventu ally decline to levels lower than those in old-growth forest.

Several other investigations in the Pacific Northwest have also shown that timber harvest can

result in increased salmonid productivity, chiefly by enhancin g autotrophic production within

streams ( Bisson et al., 1992 ) . Loss of complexity, if accompanied by increased light and dissolved nutrients, is likely to result in productivity increases concentrated in only a few taxa that directly benefit from the changes. A simila r pattern has been observe d in the structure of aquatic invertebrate communities after logging ( Bisson et al., 1992 ) . The pattern of increased production of a few taxa accompanied by a reduction in overall biodiversity may be common to all consumer trophic levels in streams where ha bitat has been simplified but light and nutrients are more plentiful. Suspended sediment is not al ways detrimental to fish, and indexes based on duration and concentration are unrealistically simplistic (Gregory et al., 1993). Turbidity, can, for example, provide cover from predators (Gre gory, 1993). However, in the overall context of research conducted on the effects of sedimentation on salmonids, other fish, invertebrates, and amphibians in stream ecosystems, the impacts are overwhelmingly negative.

The effects of roads are not limited to those associ ated with increases in sediment delivery to streams; they can include alterations to stream flow regimes, barriers to migration, and water temperature changes (Gucinski et al., 2001).

2.2.2.2 FlowsAssessment of Water Quality Impairments Related to Forest Roads Page 38 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Road-related alterations in the timing and magnitude of peak flows and changes in base stream discharge and sub-surface flows affect the pred ictability and stability of streamflow, factors found to strongly influence salmonid densities by influencing overwintering survival and reproductive success (McFadden, 1969; Seegrist and Gard, 1972). For example, post-spawning high flows can wash out eggs, displace fry, a nd otherwise increase mo rtality (Latta, 1962; Shetter, 1961). Montgomery et al. (1996) not ed research by other authors reporting that increases in scour depths were related to increases in str eam discharge and velocity and increases in fine sediment transport. Those auth ors therefore concluded th at increases in scour due to increased sedimentation from logging or roads could significantly increase the mortality of buried salmon eggs. Other authors state that th e effect of roads on peak flows is relatively modest and the issues of changing stability and pr edictability because of roads may be of little importance to aquatic habitat suit ability (Gucinski et al., 2001).

2.2.2.3 Temperature

Increases in temperature are co rrelated with construction of ro ads along valley bottoms next to

stream channels and the result ant removal of riparian vegeta tion and reduction in riparian canopy cover. Roads in riparian zones prevent grow th of dense stands of trees shading streams, and roads that travel long di stances along stream channels wo uld be more likely to yield a measurable effect on stream temperature (Lu ce et al., 2001). As noted above, increases in width/depth ratios in sensitive streams due to sediment delivery can also result in higher summer water temperatures even when shade is not lost. Such temperature increases can elevate stream temperatures beyond the range for rearing, increase susceptibility of fishes to disease, reduce metabolic efficiency, shift species assemblages, and inhibit upstream migrations (Beschta et al., 1987; Hicks et al., 1991). Filling of stream pools can also result in the in loss of low-temperature refuge.

2.3 Extent and Severity of Water Quality Impairme nts Due to Forest RoadsAssessment of Water Quality Impairments Related to Forest Roads Page 39 Contract # EP-C-05-066, TO # 0002 December 4, 2008

As noted above, sedimentation of streams is one of the most signi ficant nonpoint source pollution concerns in the United States. This is es pecially true in the Pacific Northwest (Sidle, 1980) owing to the potential for adverse effects on aquatic ecos ystems, critical fish habitat, stream morphology, reservoir capacity, quality of domestic water supplie s, and aesthetic and recreational values (Ander son, 1974; Bilby, 1985; Bisson an d Bilby, 1982; Meehan and Swanston, 1977). Increased sediment delivery to streams after road building has also been well

documented in the research literature in Calif ornia, Idaho and in the Eastern United States (Gucinski et al., 2001). However, since forest roads and stream crossings are recognized as major contributors of sediment to surface waters regardless of region, the potential effects of this pollution may be found wherever silvicultural ac tivity occurs.

Precise quantification of the imp acts of forest roads and other s ilvicultural practices on soil and water is not possible across the wide range of forest types an d regions nationwide (Swank et al., 1989). However, research is available to provide a scientific basis of general principles that indicate the relative magnitude of changes to expect in different forest types (see Figure 2-65 for a map of the major forest types in the Continental U.S.). Alt hough differences between regional forest types are noted below, similariti es in the descriptions of forest erosion and water quality impacts from forest roads should also be recognized: natural geologic erosion is quite low from most forested lands; roads and sk id trails are the primary sources of additional

sediment associated with harv esting practices; effective proce dures and methods are available for some regions of the country that minimi ze sediment from harves ting practices; and, many management goals for protecting water quality can be achieved by following BMP concepts.

2.3.1 Western Inland Conifers

The western inland conifer forest region is lo cated in the Rocky Mountains, where it extends

from Canada to the Mexican border. Forest types in this region range from the Rocky Mountain subalpine forests in Co lorado and Wyoming to southwes tern ponderosa pine stands

in Arizona and New Mexico. The northern Rocky Mountain provi nce comprises the

mountainous headwaters of the Columbia and Missouri drainages. The remaining portion of the central and southern Rocky Mountains are located mainly in the upper and lower ColoradoAssessment of Water Quality Impairments Related to Forest Roads Page 40 Contract # EP-C-05-066, TO # 0002 December 4, 2008

River basins. Geomorphology, geology, and soils vary widely throughout the western inland conifer type. Noteworthy is an area in th e northern Rocky Mountains called the Idaho Batholith. The geology of this area is granitic rocks and the soils derived from them are extremely erodible and present special management problems. Accelerated surface and mass erosion are often easily caused by silvicultura l practices in the inland conifer type.

The amounts of erosion and sedimentation vary widely within the inland conifer type. Landslides are a major concern in 10-12 % of national forest lands in Idaho and Montana; however, the risk and occurrence of landslides is considerably less than in Pacific Coast Range. Landslides associated with roads accounte d for 57-88% of tota l landslide occurrence (McCleland et al., 1997; Megahan et al., 1978).

2.3.2 Pacific Coast Conifers

The Pacific coast conifer forest region extends from southwestern Alaska through the Cascade

Mountains in western Washi ngton and Oregon and southward into the Sierra Nevada

Mountains in northern and central California. This forest type also includes the Pacific Coast

Mountains in northern and central California. Substantial increas es in sediment yields have been noted on watersheds during and following th e construction of forest roads in this region. Erosion rates on roads and landings in s outhwestern Oregon were 100 times those on undisturbed areas. Properly c onstructed roads on gentle to moderate slopes on stable topography present little hazard. However, constr uction difficulty and erosion hazard increase rapidly when roads are pushed into steep terrain, cut into erosive soils or unstable slopes, or encroached on stream channels (Stone, 1973). Sedi mentation of streams is one of the greatest nonpoint source pollution concerns in the Pacific Northwest (Sidle, 1980).

2.3.3 Northeastern Conifers

The northeastern conifer forest region supports sta nds of spruce, fir, and pine in the northern part of the United States between Minnesota and Maine. These species are intermingled withAssessment of Water Quality Impairments Related to Forest Roads Page 41 Contract # EP-C-05-066, TO # 0002 December 4, 2008

the maple-beech-birch forest type in New Engl and and aspen-birch type forests in the upper

Great Lakes states. Scattered is lands of red spruce and white pine stands extend into the Appalachian Mountains as far s outh as Georgia. The sparseness of streams, porous soils, and more than 760 mm (30 inches) of precipitati on create a hydrologically stable environment in the northeastern conifer region. Fo rest disturbances generally he al quickly. Cut slopes on roads and roads crossing streams have long been reco gnized as the primary sources of stream sedimentation. Some of the deep unconsolidated gravels and sands of glacial origin erode badly if disturbed by road construction. However, efforts have been made to better locate and design roads to minimize this impact (Stone , 1973). Less expensive roads, having lower standards, have been tested as a measure fo r reducing environmental impacts as well as construction costs (Kochenderfer et al., 1984). Su ch lower standard roads may be acceptable in this region when their location avoids erosion hazards and adequate riparian buffers are

maintained.

2.3.4 Eastern Hardwoods

The eastern hardwood forest region is considered to encompass hardwood forest types within the Appalachian Highlands physiographic divisi on, which extends from Maine to northern Georgia. A major concern in harvest and regenerati on practices is the impact on stream sedimentation. Natural geological erosion in th e moist climate of forested lands in the hardwood region averages about 0.1 ton/acre/year (Pat ric, 1980). The primary sources of

additional sediment associated with silvicultu ral practices are roads and skid trails as documented in many studies (Lull and Reinhart , 1972; Anderson et al., 1976). Some temporary increases in stream turbidity are an inevita ble consequence of any harvesting but can be minimized by careful layout, construction, and maintenance of roads. The most critical aspect of road construction occurs at stream crossings since soil eroded from cuts and fills has direct access to the stream. A key factor in erosion cont rol for roads is rapid establishment of surface protection such as a grass cover (Swift, 1984a). Immediately after c onstruction, the roadbed accounts for only 10-30 percent of the total soil loss from roads (Swift, 1984b), but after cut and fill stabilization, the roadbed may be a major source of stream sediment, particularly with continual use. Thus, the type and amount of road surfacing are important factors in controllingAssessment of Water Quality Impairments Related to Forest Roads Page 42 Contract # EP-C-05-066, TO # 0002 December 4, 2008

soil loss. In general, effectiv e procedures that minimize sediment from logging and road construction activities are well known (Kochende rfer, 1970; Hewlett and Douglass, 1968) and need only to be judiciously applied.

2.3.5 Southern Conifers

The Piedmont and Upper Coastal Plain regions of the southeastern US have much higher suspended sediment concentrations in undisturbed forest watersheds. A baseline value of about 60 mg/L has been suggested as the average annu al sediment concentration in stormflow from small, pine-covered watersheds in the s outh (Ursic, 1979). A more recent review of background-level data for all pine types by Ursi c (1986) indicates an av erage annual sediment concentration of 0.006 ton per he ctare-centimeter (0.007 ton per ac re-inch) of flow. Much of

the sediment comes from erosion of the minor channels developed during former land uses; therefore, natural sediment ation rates may vary substa ntially depending upon channel

characteristics. The increases in stormflow from harvesting and site prep aration accelerate the rates of baseline sediment losses to varyi ng degrees depending on the nature of the disturbance, characteristics of the soil, and c limatic factors. Erosion and sedimentation are noted as primary forest management concerns in 4 of 8 physiogra phic provinces in the southeast (Jackson et al., 2004). The duration of elevated sediment losses following road construction is related to how rapidly vegetati on becomes re-established. Some studies indicate that sediment losses return to near preharve st levels within a 4 to 5 year period after

disturbance.

2.3.6 How and why do Water Quality Impacts from Forest Roads Vary?

The impacts of forest road on water quality tend to be concentrated in certain regions of the country and specific locations in the forest landscape. Increased sediment delivery to streams after road building has been well documented in the research liter ature in the Pacific Northwest, California, Idaho and in the Eastern United States (G ucinski et al., 2001). In fact, most studies of roads have been conducted in only a few regions (the Pacific Northwest, Rocky Mountains, Appalachians, Interior Highlands, and Piedmont), so the ability to generalize toAssessment of Water Quality Impairments Related to Forest Roads Page 43 Contract # EP-C-05-066, TO # 0002 December 4, 2008

other regions is limited. Statements about the effects of roads on mass erosion are limited to those landscapes affected by such processes. This section will focus on forest roads in highly impacted locations, as these tend to be the most studied. Detrimental impacts from roads in these regions and locations can be inevitable, and the extent of such impacts is large as is the legacy of past road building (Williams, 1999). W ithin the range of the northern spotted owl, there are about 180,000 km (or 111,800 mi) of roads, including 250,000 stream crossings (about 1.25 per km or 2 per mile) and a significant number of culverts that are unlikely to be able to withstand a 25 year storm event (FEM AT, 1993). Within the Interior Columbia Basin Ecosystem Management Project (ICBEMP) area , there are at least 204,333 km (126,900 miles)

of inventoried roads and an additional 61,300 to 102,166 km (38,100 to 63,500 miles) of uninventoried roads (Lee et al., 1997).

Representatives of the forestry industry incl uding the NCASI contend that a few roads cause most of the problems, i.e., the so-called 80/20 rule ( 80% of the problems come from 20% of the roads; NCASI, 2001 ). Some regional studies s upport this view. For example, Rice and Lewis (1992) developed an objective methodology to estimate erosion risk on forest roads and in harvest areas on private land in northwestern California. It was based on 260 plots sampled

from the area harvested under 415 Timber Harv est Plans (THPs) completed between 1978 and 1979. Results confirmed previous findings that most erosion related to forest management occurs on a small fraction of the managed ar ea. Locations where the volume of eroded soil were larger than the minimum size inventoried in that study (> 13 cubic yards) occupied only 0.2 percent of the ar ea investigated.

However, earlier assessments have found the proble ms associated with forest roads to be more widespread. An example is the di rect connection of road drains to streams. Direct drainage connections signify likely impacts of roads on stream sedimentation, because sediment eroded from the roadway is delivered directly to the stream. A number of field studies have

documented the extent of direct drainage connections in forest road networks in the Pacific

Northwest. Reid and Dunne (1984) found that 75% of road drainage in a western Washington study area was discharging directly to stream s; Bilby et al. (1989) reported 34% direct discharge of road drainage in southwestern Washington; and Wemp le (1994) found 57% ofAssessment of Water Quality Impairments Related to Forest Roads Page 44 Contract # EP-C-05-066, TO # 0002 December 4, 2008

road drainage in the western Cascades of Or egon was discharging directly to streams. A 1997 ODF study of road-sediment in the Tillamook State Forest found that 25 to 39% of the road system was delivering sediment to streams from 459 different discharge points (live stream culverts, where stormwater ditches joined flowing stream that then flowed through culvert under the road) along 42 miles of road (ODF, 1997). Skaugset and Allen (1998) reported 31 percent of the surveyed road length in 5 Oregon regions was rated as cer tain (25%) or possible (6%) to deliver sediment to streams.

Even in the same region, road effects diffe r by landscape position (Gucinski et al., 2001). Ridgetop, midslope, and valley floor roads al l produce different effects, based on the topography they cross; the degree and type of interaction with stream networks; the stability and response to storms; and the effect s on fire, wildlife, and vegetation.

The geographic patterns of roads in forest la ndscapes differ substantially from place to place,

with commensurate differences in environm ental effects (Gucinsk i et al., 2001). In the glaciated terrain of southeaste rn Alaska, for example, main roads were built on the broad, major valley floors, and the high-value timber that grew on lower hi llslopes was brought downhill to them. In forests along the west side of the Sierra Nevada in California, on the other hand, major roads were built along broad ridges, with secondary roads leading down into

headwater areas. The main roads into western Oregon forests entered watersheds along narrow stream bottoms and then climbed the adjacen t steep, unstable hillslopes to access timber extending from ridge to valley fl oor. These configurations, co mbined with local geology and climate, resulted in very different effects of roads on stream and watershed processes.

Adverse environmental effects from logging roads change over time and vary with season of construction and use, age, weather, kinds and in tensity of maintenance, traffic level and other factors. Understanding how and why these effects vary is critical to appr eciate the extent and severity of forest road impacts on water qualit y, and sets the stage fo r considering how these impacts can be reduced using BMPs. Focusing on sediment impair ments, spatial and temporal factors to consider include the following:Assessment of Water Quality Impairments Related to Forest Roads Page 45 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Geology, geomorphic location, soils and terrain - Luce and Black (1999) showed that soil type makes an important difference in terms of road erosion and BMP performance. Soils vary in erodibility, depe nding on their properties. Landsides in Oregon’s Coast Range were concentrated in “soft sedimentary bedrock” that was geologically young, poorly consolidated, yet on steep slopes (Durgin et al., 1988). Percentage and le ngth of slope are the most significant topographic va riables affecting erosion.

Climate - Rainfall intensities are greatest along the coasts and genera lly decline to the

interior. Road erosion in west ern Montana was limited by low er odibility of dominant parent materials and low rainfall (Sugden and Woods, 2007). Alternate freezing and thawing of soils also exert strong forces for the detachment of soil particles. High summer temperatures desiccate bare soil, and a layer of loose, stru ctureless soil similar to that caused by frost heaving is produced. Thus, temperature extremes set the stage for high erosion losses from bare soils during rainstorms.

Age and density of road network - Road area distributed in “critical locations” may

be a better indicator of impacts and cumulative effects than road density.

Sensitivity of designated uses – The presence of salmonids and other sensitive and endangered species in a receiving water may be much more vulnerable to sedimentation.

Roads produce geomorphic responses ranging from the chronic, long-term contributions to streams of relatively small amounts of fine sedi ment to the catastrophic contributions of large amounts of sediment during mass failures (W illiams, 1999). Further, the results of these geomorphic changes produce cumulative conseque nces that can be manifest considerably

downstream.

2.3.6.1 Surface Erosion

Erosion occurs when the energy for detachment and transport of soil particles exceeds the

cohesive and adhesive forces which bind soil in place. The energy for erosion comesAssessment of Water Quality Impairments Related to Forest Roads Page 46 Contract # EP-C-05-066, TO # 0002 December 4, 2008

principally from rainfall and flowing water. The greatest source of energy is from falling raindrops. Rainfall intensities are greatest al ong the Pacific, Gulf and Atlantic Coasts and generally decline to the interior (Douglass, 1975). Rain which doe s not infiltrate the soil moves overland and possesses kinetic en ergy for detachment and transport of soils. Total energy is influenced mostly by velocity. In both detachme nt and transport of soil, velocity of flowing water is a key factor. Velocity of overland flow, if it occurs under forest stands, is slow. But

since overland flow is concentrated in rills and gullies, the veloci ty of flow, depth of flow, or both are increased, the energy is concentrat ed, and erosion losses increase sharply.

The major effect of forests on erosion is to reduce slightly the volum e of rainfall reaching mineral soil and to change greatly the energy av ailable for detachment and transport of soil particles (Douglass, 1975). Water temporarily stored in the fore st floor drains slowly, thus increasing the likelihood of infiltration. The forest floor also offers resist ance to overland flow and reduces the velocity of any water which may fail to infiltrate. Increases in erosion have been associated with cutting the forest, but if the forest floor is not removed or grossly disturbed by cutting the overstory, infiltration ra tes remain high and overland flow is virtually absent. When the forest floor is removed by th e building of roads, th e skidding of logs, or wildfire, raindrop energy is dissipated on mi neral soil. Infiltrati on rates are reduced by compaction and puddling of the so il. When infiltration rate fa lls below the rainfall rate,

overland flow and sheet and rill erosion occur.

Chronic surface erosion from road surfaces, cutbanks, and ditches is well documented (Bilby et al. 1989; Megahan and Kidd, 1972; Reid a nd Dunne, 1984), and is often the dominant source of road-related sediment input to streams. In the initial y ears after construction, rates of surface erosion appear highest (Megahan and Kidd, 1972) and, on unpaved roads, are closely correlated to traffic volume (Reid and Dunne , 1984). However, because of maintenance problems, roadbeds and road-related ditches and channels are continuing sources of sediment long after constructi on is complete (Miller et al ., 1985; Swift, 1984a and 1988).

Sediment erosion on forest roads in the Ore gon Coastal Range was correlated to the road length between culverts, the square of the road slope, soil erosivity, a nd ditch cleaning (Ice etAssessment of Water Quality Impairments Related to Forest Roads Page 47 Contract # EP-C-05-066, TO # 0002 December 4, 2008

al., 2004 ). Other factors related to surface erosion rates include vegetative cover and climate (amount of precipitation, occurr ence of freeze-thaw cycles). Ro ads account for 4% of the land area in Coast Range mountains, but 76% of measured erosion (Durgin et al., 1988). One third of the sediment production was from surface erosion. The most common source of sedimentation was from fillslopes immediately adjacent to watercourse crossings

Other literature shows that wet season road use can be a major source of fine sediment (Mills et al., 2003). Road surfacing and drainage prac tices can have a very large effect on both erosion and the delivery of sediment to stream s in this situation. The use of gravel-surfaced roads during wet periods has been documented as a major source of fine-grained sediment and associated stream turbidity (Reid and Dunne , 1984). Studies by Weyerhaeuser and others (Bilby, 1985; Duncan and War d, 1985; Bilby et al., 1989) found a good correlation between rock hardness and sediment delivery. They also found that most of the sediment delivered to streams from the road surface was very fine, clay-sized particles.

Extensive research has been conducted on road er osion and sediment trav el distances in highly erodible parent materials such as the grani tics of the Idaho bathol ith (Megahan and Kidd, 1972; Megahan et al., 2001; Burroughs and King, 1989), and the high precipitation and landslide prone climate of Oregon’s Coast Ra nge (Wemple et al., 1996; Luce et al., 2001; Brake et al., 1997). Less research has been conducted in other pa rent materials. Road erosion in western Montana is limited by both low erodibili ty of the dominant parent materials and low rainfall. Woods et al. (2007) inve stigated sediment travel distances below drivable drain dips along unpaved roads in the metasedimentary Belt Series and glacial till parent materials of western Montana. The generally low sediment trav el distances observed in that study indicate that most drivable dips along unpaved roads in western Montana did not deliver sediment to streams. The vast majority of the sediment in troduced to streams came from relatively few drainage outfalls.

2.3.6.2 Mass Movements of SoilAssessment of Water Quality Impairments Related to Forest Roads Page 48 Contract # EP-C-05-066, TO # 0002 December 4, 2008

In areas with steep slopes, landslides are the dominant erosional mechanism. Rates of mass movement (wasting) vary greatly across the landscape, depending on climatic, geologic, and topographic factors as well as factors associated with mana gement practices (NCASI, 2001). Landslide frequency can be greatly accelerated by road management practices (Sidle et al. 1985). According to Megahan et al. (1992), 88% of landslides within Idaho were associated

with roads. Roads have been associated with mo st failures and failure volume in most studies, but certainly not in all studies and all locations (NCASI, 200 1). In addition to the detrimental effects on vulnerable fish species and their ha bitat through increased se dimentation, landslides can result in serious personal inju ry and downstream property damage.

Mass movement can occur as shallow debris slides, deep-seated slumps, and rapid debris flows (Williams, 1999). In areas ranging from the Pacific Northwest to New Zealand, mass movements were 30 to 300 times greater in roaded than in unroaded watersheds (Sidle et al., 1985). Erosion rates on roads and landings in the Klamath mountains of southwest Oregon were 100 times greater than those on the undi sturbed area (Amaranthus et al., 1985). Total sediment production from logging roads in the Idaho batholith was 770 times higher than in undisturbed areas; approximately 71 % of the in creased sediment production was due to mass erosion and 27% to surface erosion (Megahan and Kidd, 1972). Ninety-one percent of the annual sediment production by land use activities in the South Fork of the Salmon River has

been attributed to roads and skid trails (Arnold and Lundeen, 1968). Increased rates of landsliding in roaded areas as compared to unroa ded forested areas also have been documented in Washington (Reid, 1981) and northern Califor nia (Hagans et al., 1986 ). The majority of landslides associated with managed forests cam e from road Right-of-Ways and were often associated with specific practices such as sidecast road constr uction, poor location and inadequate drainage (Ice et al ., 2004). Stream diversion at road crossings and landslides initiated by culvert failures are tw o other related road impacts.

In addition to the reported correlation be tween mass movement and roads, a number of geomorphic locations within a watershed are more susceptible to lands liding than are others (Williams, 1999). Most of the landslides observed in Idaho by Weaver et al. (1998) were most likely to occur in the inner gorge, swale, or break-in-slope (93%, 86%, and 68% respectivelyAssessment of Water Quality Impairments Related to Forest Roads Page 49 Contract # EP-C-05-066, TO # 0002 December 4, 2008

for the North Fork Clearwater, Lochsa River, and Boise River basins). These three locations

also have been identified as being at higher risk of landslide during infrequent, high intensity, or long duration storm events in northwestern California by LaHusen (1984) and in Oregon and southern Washington by Weaver and Hagan ( 1996). The risk of landslid e in these areas is even greater when these hillslope loca tions are roaded (Weaver et al., 1998).

2.3.6.3 Road Drainage and Sediment Delivery

Historically, logging roads were intentionally de signed to discharge stormwater directly into streams. This practice also directly delivered sediment eroded from roads into the streams. More recent design standards acknowledge that di rect discharges are eco logically undesirable and seek to direct drainage ont o porous forest soils for infiltration. However, direct discharge into streams is still commonly reported. Runoff from roads generally follows one of several potential pathways: infiltration back into the hillslope below the road with no delivery to streams; direct delivery at ch annel crossings; direct delive ry through gullies formed below relief drains; or indi rect delivery via overla nd flow below the road (NCASI, 2001). Direct delivery at channel crossings is the most common and most rapid form of delivery, and occurs

where roadside ditches and/or road surface runoff run directly to the stream crossing structure. The prominence of direct delivery and gullyi ng is documented by research done in western Washington and Oregon. These studies found th at 42 to 66% of road drainage points discharged to hillslopes with no delivery to stream s, 28 to 35% of drains delivered directly to streams, and 17 to 28% delivered via gullies (Bilby et al., 1989; Bowling and Lettenmaier, 1997; Wemple et al., 1996). More importantly, however, these sa me or similar studies have

found that 17 to 35% of the total road mileage contributes sediment to the stream system (Bowling and Lettenmaier, 1997; McGreer et al., 1997), or conversely, 65 to 83% of the road mileage did not contribute sediment to str eams. Monitoring conducted in the mid-1990s shows that about one-third (29-39 %) of active and inactive roads on st ate and private lands in Oregon can deliver sediment to streams by ditc h delivery (Skaugset and Allen, 1998). An inventory of road drainage sites in three watersheds in southwestern Washington found two thousand drainage points along 730 km of road; 34% of th e drainage points directly entered streams rather than draining into the forest floor (Bilby et al., 1989).Assessment of Water Quality Impairments Related to Forest Roads Page 50 Contract # EP-C-05-066, TO # 0002 December 4, 2008

2.3.6.4 Road Maintenance

Forest roads require significan t ongoing maintenance to prevent deterioration of the roadway by grading, ditch cleaning, unplugging culverts, etc. Poorly mainta ined roads are subject to periodic blockage or failure as transporta tion systems due to both surface erosion and mass wasting events, primarily during floods. Erosion and sediment delivery associated with such failures can be extreme. In addition, road s produce chronic surface erosion impacts, particularly where poorly located and mainta ined. Although sediment problems are sometimes worsened by too much maintenance, it is usua lly the neglect of maintenance that leads to problems with road erosion and mass wasting. Road maintenanace is an ongoing expense, and economics is the primary reason that forest roads are poorly maintained.

This is well illustrated by statistics for th e National Forests. The NFS road system is considerably more extensive th an the Interstate Highway Sy stem (Grace and Clinton, 2006) and consists of over 600,000 km of roads of va rying classes and an estimated 7,600 bridges (TetraTech, 1999). There are a variety of road standards and road juri sdictions within the National Forests. Figure 2-3 summarizes the lega l basis and definitions relative to forest roads in National Forests (Coghlan and Sowa, 1998). Most of these roads were initially constructed for management activities such as harvesting and fire prevention. In recent years, road maintenance has been sharply reduced because funds for maintenance as well as maintenance by timber purchasers have declined (Williams, 1 999). This has resulted in chronically poor road maintenance. In the southern Appalachians, forest roads often are not maintained at all, are subjected to maintenance that is inadequate for the level of road use, or are scheduled for maintenance in such a way that the work is poorly timed relative to storm patterns (Swift, 1984b and 1988). This pattern is not unique to the East. There has been a progressive degradation of road drainage st ructures and function in the Colu mbia River Basin (Lee et al., 1997), and about 60% of all NFS roads are not fu lly maintained to the planned safety and environmental standards for which they were designed (USFS, 1999). It is not clear whether the same trends are taking place for forest road s in timberland owned by the commercial forest industry and other private timberland owners, but this may be a reasonable assumption.Assessment of Water Quality Impairments Related to Forest Roads Page 51 Contract # EP-C-05-066, TO # 0002 December 4, 2008

During the early 1970’s through the 1980’s the valu e of timber started to fluctuate (Coghlan and Sowa, 1998). A dramatic increase in the deve lopment of forest road miles also occurred between 1977 and 1987. In an attempt to reduce roading costs, access was frequently provided through temporary roads rather than the more co stly permanent roads. Temporary roads have lower initial development costs than perman ent roads, but their long-term management implications are more significant. The reliance on temporary as opposed to permanent roads created some unwanted impacts. These lower sta ndard roads were also not intended to serve the purposes that they have evolved to serve, namely increased recreational use in the National

Forests. There has been an eleven-fold increase in traffic in National Forests in comparison to

the 1950’s. Increased use and traffic has re sulted in the need fo r significantly more maintenance, and has resulted in more erosion and sedimentation.

Revisions in the USFS timber management pr actices during the 1990’s limited the harvest activity for which the existing roads were desi gned. Consequently, timber harvesting presently accounts for only 0.5% of all forest road use. Co mmercial users, such as timber haulers, are responsible for traffic-generated maintenance co mmensurate with their use, so commercial use maintenance has decreased in proportion to the d ecrease in timber harvest. Current funding is sufficient to maintain about 40 percent of the ro ads to planned service levels. The balance of the roads are maintained according to priority safety and environmental needs. Appropriated annual maintenance ranges from $300 to $600/m ile for maintenance level 3–5 roads, $60 to $100/mile for maintenance level 2 roads, and $20 to $40/mile for maintenance level 1 roads. It is practically impossible to maintain roads to designed standards based on these funding levels. For comparison, in 1994, the average annual costs of maintaining a mile of gravel or loose aggregate road was $7,986 for all counties, a nd $1,995 for all townships (Coghlan and Sowa, 1998). The backlog of deferred maintenance on roads in the National Forests has been estimated to be $4.1 billion (Bellingham Herald, 2007). The cost to remove barriers to fish passage at 25,500 stream crossings w ould cost an additional $1.9 billion.

2.3.6.5 Age of Roads and Road NetworkAssessment of Water Quality Impairments Related to Forest Roads Page 52 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Much of the potential watershed-scale effects of roads are likely related to roads designed and constructed under older administrative rules (FPA C, 2001). These make up the majority of the roads on the landscape, often constructed with practices presenting greater risk of adverse effects to aquatic habitat. The result of over 100 y ears of forest access is that most of the roads needed today for management of private la nds have already been built (NCASI, 2001). However, much of today’s existing road system was designed and built to standards and in

locations that would not be used if the system were built “from scratch” today. Road networks differ greatly in development through time and la yout over terrain, and carry this history into their present performance (Gucin ski et al., 2001). The geographic patterns of roads in forest landscapes also differ substantially from place to place, with commensurate differences in environmental effects (Gucinski et al., 2001). Ro ad effects, when aggregated at the landscape scale, are dependent on road design and road location, and assessment of these effects must consider the proportion of old roads to new roads that incorporate improved engineering design (Gucinski et al., 2001).

Cederholm et al. (1981) reporte d that large amounts of the sediment embedded in spawning gravels in the Clearwater Rive r of Jefferson County, Washington came from roads built before1972. In Oregon, “old” roads are considered to be those built before 1983 (i.e., before endhauling was introduced to eliminate the hazardou s side-casting of excavated soil). Current methods of road construction and erosion prev ention have vastly reduc ed erosion problems.

Numerous large landslides associated with the ro ad system in the South Fork of Caspar Creek occurred in early 1998, indicating that “legacy” roads continue to be significant sources of sediment decades after they were constructed (Cafferata and Spittler, 1998). Old roads built with practices prevalent in the 1950’s, 1960’s, and early to mid-1970’s are still significant sources of erosion. In virtually all of the studies of road failu res due to mass wasting reviewed by NCASI (2001), the majority of failures observe d are from roads built years ago in locations

and with construction methods which later became unacceptable and/or illegal, and thus road systems pose significant potential for legacy effects.Assessment of Water Quality Impairments Related to Forest Roads Page 53 Contract # EP-C-05-066, TO # 0002 December 4, 2008

In addition, however, it is important to note that increases in sedimentation from new roads and landings are unavoidable even using the most cautious logging and roading methods (Williams, 1999). Few studies have systematically and quantitatively evaluated the extent to which new road design, siting, cons truction and engineering practi ces have resulted in lower

mass erosion rates and reduced the ecological impacts of roads (McCashion and Rice, 1983). An analysis of the effects of new road constr uction and siting practices in the Oregon Coast Range suggested some reduction in slide frequenc ies over those resulting from the old roading practices (Sessions et al., 1987). However, the new practices were not "put to the test" as no large storms occurred during the study period. McClelland et al. (1997) also reported that following intense rain-on-snow pr ecipitation during the 1996 floods the rate of failure of roads built in the 1970s through the 1990s was approximate ly half the rate of failures of roads built in the 1950s and 1960s. Examination of the improved road design practiced by the Boise

National Forest indicated that while the new practices were an improvement over the old roading practices, total accelerated sediment yields still were 51 % greater than natural (undisturbed) levels (Megahan et al., 1992).

2.3.6.6 Road Density and “Critical” Locations

The density and location of roads have been corre lated to impairments of forested watersheds. The Interior Columbia Basin Ecosystem Ma nagement Project (ICBEMP) Assessment of Ecosystem Components in the Interior Colu mbia Basin of Idaho, Oregon and Washington (Quigley and Arbelbide, 1997) was one of the few examples of landscape-scale analysis of

road influences. The evaluation of road densit y and forest and range integrity in that study serve to illustrate landscape-sc ale interaction of road s with their surroundings (Gucinski et al., 2001). Forest and range indices of integrity were developed that showed sub-basins having the highest forest-integrity index we re largely unroaded. Of the five indicator variables used, the proportion of a subbasin composed of wilderne ss or roadless areas seemed most closely associated with subbasins having high integrity indices; 81 percent of the subbasins classified as having the highest integrity had relatively large proportions of wilderness and roadless areas (>50 percent). Conversely, of subbasins with the lowest integrity, 89 percent had low proportions of roadless and wild erness areas; 83 per cent had relatively high proportions of atAssessment of Water Quality Impairments Related to Forest Roads Page 54 Contract # EP-C-05-066, TO # 0002 December 4, 2008

least moderate road density (0.27 miles/square mile). None of the seven subbasins having high rangeland integrity had areas of moderate or high road densities. This assessment found that increasing road densities (combined with the acti vities associated with roads) are correlated with declines in anadromous salmonid specie s (NCASI, 2001). In other words, road density and fish populations are inversely correlated across a larg e area in the interior Columbia basin. Linkages show that strong fish populations were more frequently found in areas with low rather than high road densities (Gucinski et al., 2001). Supplemental analysis "clearly show that increasing road densities a nd their attendant effects are asso ciated with declines in the status of four nonanadromous salmonid species .... they are less likely to use highly roaded areas for spawning and rearing, and, where found, are less likely to be at strong populations levels." (Lee et al., 1997). However, the I CBEMP report also noted that the component contributions (causes) of effects associated w ith roads could not be identified, and that they

were therefore “forced to use roads as a cat ch-all indicator of human disturbance.” The

correlation of basin or subbasin in tegrity is not total, thereby suggesting that other variables and mechanisms are complex and non-uniform.

The degree of connectivity between roads and streams (that is , the number of stream crossings

and areas where roads and streams are near enou gh to strongly interact ) is recognized as a good general indicator of the interactions betw een the two and of the potential effects roads can exert (Wemple, 1994). Where both stream a nd road densities are high, the incidence of

connections between roads and streams can be e xpected to also be high, resulting in more common and pronounced effects of roads on st reams than in areas where road-stream connections are less common and dense (Gucinsk i et al., 2001). Eaglin and Hubert (1993) studied the effects of logging and associated road construction on streams and on trout populations in the Medicine Bow National Forest of Wyoming. The amount of fine sediment in a stream reach increased, and the embeddedness of fine sediment (its coverage of large particles) in the substrate increased as the pr oportion of logged area increased and as the extent

to which roads crossed watercourses increased. Tr out standing stocks also decreased as the density of road culverts increased. Cederholm et al. (1981) found that the percent fine sediment in spawning gravel increased above natural levels when more than 2.5% of the drainage basinAssessment of Water Quality Impairments Related to Forest Roads Page 55 Contract # EP-C-05-066, TO # 0002 December 4, 2008

was covered by roads. King and Tennyson (1984) found that the hydrologic behavior of small

forested watersheds was altered when as little as 3.9% of the watershed was occupied by roads.

Other scientists looking at larg e scale physical variab les relating to fish abundance have also noted that increased road density yields lowe r fish abundance (Lee et al., 1997) or occurrence (Dunham and Rieman, 1999). Luce et al. (2001) applied a predicti ve watershed erosion model to estimate the average annual sediment yiel d from surface erosion in 18 small basins. The results suggested that road density correlates poorly to sediment yield from surface erosion (Luce et al., 2001). They conclude d that a strategy aimed at re ducing road miles alone may not

reduce sedimentation in streams.

Road area distributed in “critic al locations” has been suggested as a better indicator of cumulative watershed effects than road density alone. The Critical Site Erosion Study (CSES) was a study of the occurrence of critical sites, defined as sites where more than 189 m 3 /ha of soil were eroded, in harvest areas and forest roads (Lewis and Rice, 1989). The sampled site population came from areas covered by Timber Ha rvest Plans completed in California between

November 1978 and October 1979. Because of high landowner cooperation, CSES came close to obtaining a truly random sample of the targ et population. The results largely confirmed previous findings (Rice, 1992). Critical sites contained 65% of the erosion but occupied only 2% of road length and 0.5% of harvested ar ea. The CSES also confirmed the dominance of

road-related erosion over harves t area erosion, which has been not ed in studies since at least 1954 (Anderson, 1954). Roads yielded 70% of the to tal erosion volume. The erosion rate on roads was 21.5 times that in harvest areas, clos e to the ratio of 17 reported by McCashion and Rice (1983). These findings confirm the ubiquitous “80-20 rule,” in this case, 80% of the problems come from 20% of the roads.

2.3.6.7 Cumulative Impacts and Effects

Logging is generally conducted in large areas (t racts or parcels) that often comprise major portions of catchments or watersheds. A road network develops in forested watersheds,Assessment of Water Quality Impairments Related to Forest Roads Page 56 Contract # EP-C-05-066, TO # 0002 December 4, 2008

resulting in numerous chronic se diment sources, landslides and/or obstacles to fish passage. If a large number of such sources (possibly hundred s or thousands) deliver sediment into the streams in a watershed, they will have a cumu lative impact on the sediment budget of the streams, rivers and other downstream water bodies, resulting in significant accumulation of sediment in deposition locations. Cumulative im pacts from these numerous sediment sources tend to be greater downstream of larger watershe ds; watersheds with more forestry activity, higher road density and/or problem roads, crossi ngs, etc.; watersheds with older road networks and a greater percentage of legacy roads; and watersheds where the rates of chronic sediment delivery and/or mass wasting are higher due to regional and site-specifi c factors. Again, much of the potential for the watershed-scale effects of roads is likely related to roads designed and constructed under older administrative rules (FPA C, 2001). These make up the majority of the roads on the landscape, often constructed with practices presenting greater risk of adverse effects to aquatic habitat.

In the Caspar Creek watershed, much of the se diment measured in th e tributaries has been trapped behind woody debris or othe rwise stored in the channels, so that much of it has not yet been measured downstream (Lewis, 1998). Suspe nded sediment transport per unit watershed

area tends to increase downstream in the absenc e of disturbance. This tendency was apparent in the pretreatment data analyses and could be reflecting the greater availability of fine sediment stored in these lower gradient channe ls. The relevance to cumulative effects is that downstream locations might reach water quality le vels of concern with a smaller proportion of watershed disturbance than upstream locations. To the extent that larger watersheds reflect average disturbance rates and th erefore have smaller proporti ons of disturbance than the smallest disturbed watersheds upstream, one might expect sediment loads downstream to increase by less than those in the logged tr ibutaries, reducing the overall variability among watersheds. In addition, as mentioned before, some of the sediment may be stored for several years before reaching the lower stations. In Casp ar Creek, the effects of multiple disturbances in a watershed were approximately additive. Downstream suspended load increases were no greater than would be expected from the pr oportion of area disturbe d (Lewis, 1998). To the contrary, most of the increased sediment produced in the tributaries was apparently stored in the main stem and has not yet been measured at the main-stem stations.Assessment of Water Quality Impairments Related to Forest Roads Page 57 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Cumulative impacts are those influenced by multiple activities, as are most environmental impacts (Reid, 1999). In reality, then, almost all off-site environmental impacts are cumulative impacts. When impacts involve the transport of water, sediment, or woody debris through a watershed, they are referred to as "cumula tive watershed impacts." Cumulative watershed impacts are of considerable concern because they are responsible for much of the damage to property and to public-trust resources that occu rs away from the site of land-use activity.

Cumulative watershed impact influe nces, or is influenced by, the flow of wa ter through a watershed (Reid 1998). Cumulative watershed e ffects, a phrase which has widely replaced reference to “impacts,” can be additive or s ynergistic and involve modification of water, sediment, nutrients, pollutants, and other watershed system components (Swanson et al., 2000). An example of such effects would be wher e forest roads and timber cutting contributes to increased peak streamflows and sediment loads, leading to aggr adation of downstream areas, which in turn results in lateral ch annel migration causing streambank and floodplain erosion, which entrains additional sediment.

Reid (1993) provides a broad and detailed summary of cumulative watershed effects of diverse land-use activities, such as grazing, roads, loggi ng, recreation, and wate r extraction. She also addresses alternative approaches for a ssessing cumulative effects (Reid 1993, 1998). Cumulative effects can be addressed by examini ng the changes triggered by a particular landuse activity and how these changes interact w ith effects of other land uses and natural processes. Such an approach is best undertaken as a long-term study with substantial focus on mechanisms of transport, transformati on, and storage within the watershed.

An important development in anticipating and hopefully minimizing cumulative watershed effects has been the watershed analysis deve loped for use by federal (e.g., Regional Ecosystem Office, 1995) and state (WFPB, 1995) agencies in the Pacifi c Northwest (Swanson et al., 2000). The general objective of the federal wate rshed analysis procedure is to gain an understanding of present and prospective future mechanisms affecting watershed conditions.Assessment of Water Quality Impairments Related to Forest Roads Page 58 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Thus, watershed analysis provi des a useful starting point fo r assessments of cumulative watershed effects. However, Reid (1998) asserted that neither of these “widely used watershed analysis methods provides an adequate assessm ent of likely cumulativ e effects of planned projects.”

The term “cumulative effects” is intuitively appealing, as it suggests that environmental impacts of specific management activities cannot properly be viewed in isolation from a broad perspective of land management at large spatia l scales and long time scales (Bisson et al., 1992). An underlying assumption has been that although individual management actions by themselves may not cause undue harm, taken coll ectively, such land use activities may result in unacceptable stream habitat degradation and long-term declines in fish abundance. As seemingly logical as this concept is, clear examples of cumulative effects of forest management on stream habitat have been difficult to demonstrate in all but the most severely degraded river systems. Establishing unambi guous relationships betw een abundance of fish populations and cumulative environmental change ha s been equally difficult, if not more so.

Specific changes in stream environment caused by past forest practices in the Pacific Northwest (PNW) vary according to logging and reforestation history, watershed geology, regional climate, and the degree of protection given to riparian zones during management activities (Bisson et al., 1992). The one change that appears to be consis tent over all areas in which the effects of forest management on st reams have been studied is a trend towards simplification of stream channe ls and a loss of habitat comple xity (Bisson and Sedell, 1984). Simplification of stream channels involves loss of hydraulic comple xity (i.e., variation in depth and velocity and obstructions), elimination of physical and bi ological interact ions between stream and floodplain, reduction of structures that serve as cover from predators, increase in dominance of one particular subs trate type, and the loss of sedime nt and organic matter storage capacity. This is most evident in the changes in frequency, size, and location of different types

of habitat units within the channel. The most pervasive change has been a reduction in the frequency and size of pools that constitute preferre d habitat of certain species and age classes. There have been two principal causes of pool reduction in PNW streams: filling of pools by sediment (Megahan, 1983) and th e loss of pool-forming structures such as boulders and largeAssessment of Water Quality Impairments Related to Forest Roads Page 59 Contract # EP-C-05-066, TO # 0002 December 4, 2008

woody debris. Bisson et al. (1987) cited numerous studies that ha ve associated declines in fish abundance with the loss of pools and woody debris in PNW streams. In addition to reductions in the number and size of large scour and plunge pools, forestry and ot her land use practices have led to stream channel simplification by e liminating edge habitat along stream margins, although this is not necessari ly an effect of roads.

2.4 How are the Water Quality Impacts Fr om Forest Roads Quantified and Documented?

National level assessments of water quality are based on state lists of impaired waters, the socalled 305(b) and 303(d) lists. These assessments represent the only ava ilable National data on the extent and causes of impairment to rive rs and streams, lakes, wetlands, and other waterbodies. Section 305(b) of the CWA requires th e states to describe the quality of their surface waters including the extent to whic h water quality standards are being met. USEPA is also to biennially provide a prioritized list of waters that are impair ed and develop pollution controls; this data is discussed separately in Section 2.5 (below). Fourteen National Water Quality Inventory (NWQI) reports have been published since 1975; the most recent reports were published in 2000 and 2002. For the 2000 report, states assessed 19% (699,946 of 3,692,830 miles) of the nation’s to tal river and stream miles; 43% of its lake, pond and reservoir acres; 36% of its estuarine square m iles; and 92% of Great Lakes shoreline miles. This report will focus on the assessment results for rivers and streams, as these are the waterbodies most likely to reflect impairments due to forest roads. The states assessed 142,480

fewer river and stream miles in 2000 than in 1998. This 17% decr ease was primarily a result of changes in assessment and reporting methods in a few states, for the most part reflecting a

move toward the use of more reliable monito ring data and a greater reluctance to include qualitative information or older data in water qu ality assessments. The states reported that 61% of the 699,946 assessed river and str eam miles fully supported all of their uses. As reported in earlier assessments, sedimentation remained one of the most widespread pollutants affecting

assessed rivers and streams. Se dimentation impaired 84,503 river a nd stream miles (12% of the assessed river and stream and stream miles). Sources of sedimentation included agriculture, urban runoff, construction, and forestry. Alteration to river and stream habitats was reported by the states to cause impairment to 58,807 miles (8 % of the assessed river and stream miles andAssessment of Water Quality Impairments Related to Forest Roads Page 60 Contract # EP-C-05-066, TO # 0002 December 4, 2008

22% of the impaired river and stream miles). In th is case, only habitat al terations that did not

affect water flow were considered because stat es and tribes reported st ream flow alterations (such as dams and irrigation) under a different ca tegory. Examples of habitat alterations that do not directly affect stream flow include th e removal of woody debris or stream bottom

cobblestones. Habitat modificati ons result from human activiti es such as flow regulation, logging, and land-clearing practi ces. The 2000 report listed nonpoi nt sources – agriculture, hydrologic modification, habitat modification, urban runoff, and silviculture - as leading sources of river and stream impairment. Silvicu lture was the 5th ranked source, responsible for impairment of 28,156 river miles; this represents 10% of impaired rive r miles and 4% of all

assessed river miles. Ten states listed silviculture as a major source of impairment to assessed rivers and streams: Arizona, California, Kent ucky, Louisiana, Maine, New Mexico, Oregon, Tennessee, Vermont and West Virg inia. North Carolina listed silviculture as a major source of impairment to assessed wetlands, and Utah listed silviculture as a major source of impairment

to assessed lakes.

For the 2002 NWQI, states assessed 695,540 mile s (19%) of the nation’ s 3.7 million miles of rivers and streams. Three states (Alabama, No rth Carolina, and Washington), Puerto Rico, the tribal nations, and the island territories of the Pacific did not provide data electronically in 2002. This lack of data may account, at least in pa rt, for the fewer number of river miles, lake acres, and estuarine square miles reported as assessed in 2002 compared to 2000. Of these waterbodies, 45% were reported as impaired or not clean enough to support their designated uses. States found the remaining 55% to be full y supporting of all designated uses. Sediment, pathogens, and habitat alterations were again cited as the lead ing causes of impairment in rivers and streams, and top sources of impairments included agricultural activities, unknown/unspecified sources, and hydrologic modi fications. The 2002 report lists silviculture

as the 9 th leading source, responsible for impairment of 18,463 river miles. Of the nine states that listed silviculture as a major source of im pairment to assessed rivers and streams in 2000, in 2002 only California listed silviculture as a major source of impairment. California and Montana reported 9,713 forest road-related impa ired miles of streams. Oregon did not report probable sources for impairments in 2002. As noted in the 2002 report:Assessment of Water Quality Impairments Related to Forest Roads Page 61 Contract # EP-C-05-066, TO # 0002 December 4, 2008

“...it is important to note that the information about specific sources and causes of impairment is incomplete. States do not always report the pollutant or source of pollutants affecting every impaired river and stream.”

In previous NWQI reports, unknown or unspecifi ed causes and sources were included only as footnoted material to summary statistics. For the first tim e, the 2002 NWQI report includes unspecified causes and sources in all summary sta tistics to more clearly represent what states are reporting to USEPA. The ranking of “ unknown or unspecified sources” as the secondleading source of river mile impairment illustrates the uncertainty inherent in the assessment data. In the 2002 NWQI report, th ere is additional breakdown of the silviculture source group: forest roads, forest management, silviculture, etc. , in terms of affected river and stream miles. However, these sources are not defined well enough to interpret the information, and the impairments attributed to the different sour ces may substantially ove rlap. Review of the complete data presented in the current NWQI report suggests that this detailed breakdown of the silviculture source group may be misleading or even meaningless.

The most recent national summary of state in formation available on the USEPA Watershed Assessment, Tracking & Environmental Results (WATERS) web site is based upon data reported between 2002 and 2006. For this summar y, the states assessed 822,721 river and stream miles (23% of the nation’s total of 3,533,205 river and stream miles); this assessment reflected an increase of over 100,000 river and stream miles from th e previous 2 reporting cycles. Of the assessed waterbodies, 47% were reported as impaired or not clean enough to support their designated uses. St ates found 52% to be fully su pporting of all designated uses. The remaining 1% (9,793 miles) we re categorized as “threatened”. Pathogens, sediment, nutrients and habitat alterations were cited as the leading causes of impairment in rivers and streams, and the top sources of impairment s included agriculture, unknown/sources, and hydromodification. The 2002 report lis ts silviculture as the 12 th leading source, responsible for impairment of 19,071 river miles; this re presents 5% of impaired river miles.

USEPA characterizes the information contained in the NWQI reports and the associated National Assessment Database (NAD) as useful “snapshot views” of water quality assessed by the states during each reporting cycle. Although the information in the NAD provides a pictureAssessment of Water Quality Impairments Related to Forest Roads Page 62 Contract # EP-C-05-066, TO # 0002 December 4, 2008

of state assessment results, these data cannot be used to compare water quality conditions between states or to identify trends in stat ewide or national water quality. According to USEPA the following are reasons for this lack of comparability:



### y The methods states use to monitor and asse ss their waters, including what and how they monitor and how they report th eir findings to USEPA, vary from state to state and within individual states over time.



### y The science of monitoring and assessment varies over time, and many states are better able to identify problems as their mo nitoring and analytical methods improve.



### y 2002 was a transition period between traditio nal 305(b) reporting and integrated 305(b)/303(d) reporting.



### y Under the CWA, each state has the authority to set its own water quality standards; therefore, each state’s defi nition of its designated uses (e.g., Warm Water Fishery or Livestock Watering) may diffe r from definitions used by other states, along with the criteria against which states determine impairments.

As discussed above, the 305(b) list s cannot be considered to be re liable, representative data to assess and quantify the water quality impacts from forest roads at the National level. In general, the rigorous scientific documentation of water quality impairments due to forest roads comes from site-specific studies of impacted water bodies and threaten ed aquatic resources,

and these tend to be focused on water bodies where impairments are known or suspected. Many studies have been conducted which show the adverse impacts of soil erosion and stream sedimentation on the nation’s water quality (A uthor et al., 1998; Binkley and Brown, 1993). A number of different scientific approaches have been used in these stud ies to quantify the water quality impacts from forest roads, including water quality monitoring and bioassessment approaches, stream morphology and substrate anal ysis, as well as watershed-scale research. The problems associated with detecting water qual ity impacts and attributing them to specific sources are common to all of these approaches. Results from many of these studies have been presented previously in Sections 2.2 and 2.3.

USEPA, other federal agencies, and the states have embarked on a more cost-effective approach to track trends in the quality of th e Nation’s waters: statistically valid, probabilitybased studies that complement existing monito ring and assessment programs and add to ourAssessment of Water Quality Impairments Related to Forest Roads Page 63 Contract # EP-C-05-066, TO # 0002 December 4, 2008

understanding of national, regional, and loca l water quality conditions. Probability-based studies select a specific number of sites at random to repres ent the condition of waters in regions that share similar ecological characteristic s. Scientists can then draw inferences for all waters with a known degree of confidence. Probability-based studies are generally characterized by standard sampling methodologies, a defined set of relevant indicators, and stringent quality assurance (QA) requirements . The Wadeable Streams Assessment, a survey of the biological health of the nation’s wadeable streams, was launched in 2004 by USEPA and the states to provide a scientific baseline of stream water quality data based on conditions at approximately 500 randomly selected site s across the central and eastern United States. With support from USEPA, state water quality agenci es sampled streams between June and October 2004 using the same types of methods at all sites. Crews collected macroinvertebrates, sampled water quality conditions , and evaluated physical habita t (i.e., the condition of the streambed, streambanks, and vegetation surrounding th e stream site) at each site. Data from

these sites were combined with data collected by USEPA and western states in the Western Streams Pilot Study to draw conclusions about the condition of 100% of streams throughout each major ecological region of the contiguous Un ited States. Further assessments of rivers and streams, which will include fish collection, are planned for 2008 and 2009.

2.5 What Total Maximum Daily Loads (TMDLs ) Have Been Developed for Sediment Associated with Forest Roads?

The need to develop Total Maximum Daily Loads (TMDLs) for impaired waters was established by Section 303(d) of the Clean Water Act to assist in the implementation of state water quality standards to protect the designa ted beneficial uses (e.g. fishing, swimming, drinking water, fish habitat, aesthetics) of i ndividual water bodies. TMDLs are developed for waters that fail to meet state water quality standards despite the application of technologybased effluent limitations. A TMDL is a calculation of the maximum quantity of a pollutant that may be added to a water body from all sour ces, including point sources, nonpoint sources, and natural background sources, without exceeding th e applicable water quality criteria for that pollutant. A TMDL has three components: a Wa steload Allocation (WLA), a Load Allocation (LA), and a margin of safety. The WLA is the portion of a TMDL allo cated to existing and future point sources, whereas the LA is the po rtion attributed to existing and future nonpointAssessment of Water Quality Impairments Related to Forest Roads Page 64 Contract # EP-C-05-066, TO # 0002 December 4, 2008

sources, including natural backgr ound levels of the pollutant. Where possible, the LA must distinguish between loadings from natural sources and those from nonpoint sources. The TMDL must allow a margin of safety to account fo r scientific uncertainty, and it must take into

consideration seasonal variati ons in water quality conditions. A simple formula summarizes the components of a TMDL:

WLA + LA + margin of safety = TMDL

Determining the source of a particular type of non point source pollution (e.g., sedimentation) is difficult. Sediment in a water body or waters hed is typically derived from a number of both natural and man made sources. The type and am ount of sediment will also fluctuate depending on short-term climatic changes. Nevertheless, the “Sources of Impairment” statistics on the 303(d) list clearly shows th e significance of nonpoint sour ce pollution. Only 10% of the impaired watersheds in the United States are im paired solely because of point source pollution

alone. An estimated 43% of the nation’s wate rways are impaired by nonpoint source pollution only, with the remaining 47% impaired from a combination of both point source and nonpoint source pollution. Sedimentation is a leading impairment in 6,427 water bodies (9.9% of reported impairments). This picture loses so me of its coherence, however, when the consistency of the state lists of impaired waters is examined. States with very similar land use patterns and environment paint a very different pi cture of the impairment level of their waters. For example, the State of Washington shows little impairment of their watersheds while neighboring Oregon reports a high le vel of impairment for their watersheds. States are required to disclose the data, modeling and assumptions used in developing th eir list of impaired waters. The ranking depends on the best availabl e information, and the quality and reliability will tend to vary from state to state. Thus , TMDL tracking can be plagued by the same inconsistencies and incomp lete reporting noted above for the 305(d) lists.

As mentioned in Section 2.4 above, TMDLs lis ted under Section 303(d) provide another way to evaluate the significance of forest roads in contributing to water qua lity impairments in the US. Beginning in 1992, states, territor ies and authorized tribes were to submit lists of impaired waters (i.e., waters that do not meet water qua lity standards) to USEP A every two years. TheAssessment of Water Quality Impairments Related to Forest Roads Page 65 Contract # EP-C-05-066, TO # 0002 December 4, 2008

current National Section 303(d) li st, which includes state electr onic data submissions from 1998 through 2006, lists pathogens, mercury, othe r metals, sediment, nutrients, and oxygen depletion as the leading causes of impairment of all water bodies. Sediment, as well as other causes of impairment (e.g., Cause Unknown - Biological Integrit y, Turbidity, Habitat Alteration), suggest that forestry and forest roads may be sources of impairment in some of these water bodies. However, the source(s) of the impairment are not identified in the current National Section 303(d) List and the asso ciated TMDL Tracking System database 7

. Oregon lists 1,512 sedimentation-impaired water bodies (i ncluding 5,600 miles of forest streams) in the 2004/06 Integrated Report Database; Washi ngton lists 1,110 impairments in stream and creek segments. Unfortunately, neither state repo rts the sources of water quality impairment.

Many impaired waters that require a TMDL bud get for sediment include roads as a primary source. In Idaho, for example, nearly every TMDL created for sediment in a forested setting identifies roads as a primary source of se diment problems. TMDLs written for seven waterbodies in Idaho specifically address fo rest roads as a source of sediment, while implementation strategies for general sediment reduction often focus on road improvement and road removal as critical steps for reducing loads.

The involvement of the National Forest Service in developing TMDLs illustrates the possible extent of forest roads as sources of impairm ents. The 303(d) lists for 2005 include more than 4,300 water quality impairments in 2,600 water b odies on National Forest Service lands in 41 states. The Forest Service has supported develo pment of more than 300 TMDLs in more than 30 National Forests. As another example, the Washington State Forest and Fish Agreement addresses Endangered Species Act listings for 660 streams included on the 303(d) list of water quality limited water bodies (NCASI, 2001b).

In California, many Northern Coas tal rivers have been listed as "water quality limited" due to sediment and/or temperature impacts to fish. In the settlement of a lawsuit brought against

7 In the future, it may be possible to identify the source of impairment in a TMDL as forestry-related in EPA’s new TMDL data system (expected to be online in the spring of 2008), but only for Integrat ed states and within that subset, only those states that actually identify their cause of impairment s ources (N. Abdelmajid, EPA; personal communication 12/13/07).Assessment of Water Quality Impairments Related to Forest Roads Page 66 Contract # EP-C-05-066, TO # 0002 December 4, 2008

USEPA stating that the agency was not enforc ing the Clean Water Act, USEPA made a legal commitment guaranteeing that TMDLs would be established by either USEPA or the State Regional Water Quality Control Board for 18 river basins by 2007, including 10 where silviculture is a potential source of sedimentation a nd/or siltation:



### y Garcia River (TMDL completion date: 1997)



### y Redwood Creek (1998)



### y Noyo River (1999)



### y Eel River South Fork-above a nd below Garberville (1999)



### y Navarro River (2000)



### y Gualala River (2001)



### y Mattole River (2002)



### y Eel River -North Fork (2002) and Upper Main Fork (2004)



### y Mad River (2007)

The state of California did not complete a doption of a TMDL for the Mad River by the deadline of December 2007, so USEPA established sediment and temperature TMDLs for the river. USEPA expects the state Regional Board to develop an implementation strategy that meets the requirements of 40 CFR 130.6.

More than 30 rivers where silviculture is a po tential source of sedimentation and/or siltation are listed on California’s 2006 303(d) lis t. These include the following rivers:

Navarro River - Increased sediment and summer temperat ures are detrimental to native cold water fish, such as coho salmon and steelhead tr out. Both populations of these species are listed as threatened under the federal Endangere d Species Act. Road-related sources dominate other anthropogenic sources, reflecting the domin ant land uses in the watershed, specifically timber production and ranching, which use a vast network of roads.

Garcia River - Sedimentation has contribu ted to the reduction and loss of habitat necessary to support cold water fish such as these salmonids. An analysis of the road density indicates that

road densities in the Garcia River watershed are well above the desire d density to protect instream habitat, also indicat ing that erosion from roads is a probable source of concern.Assessment of Water Quality Impairments Related to Forest Roads Page 67 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Redwood Creek - Accelerated er osion and other causes of se dimentation are adversely affecting the migration, sp awning, reproduction, and early development of coho salmon, chinook salmon, and steelhead trout. Specific in -stream problems in Redwood Creek include fine sediment in spawning gravels, channel aggradation, lack of su itable pools for rearing habitats, stream channel instability, and physic al barriers to migrati on. Specific hillslope problems in the watershed include improperly de signed or maintained roads, sediment from unstable areas, removal of riparian trees, and loss of large woody debris.

Noyo River - The primary beneficial use of conc ern in the Noyo Rive r watershed is the salmonid fishery, particularly the coho salmon fi shery. Several factors have contributed to the increased sediment delivery a bove natural rates th roughout the watershed. They include: high rates of timber harvest, a strong reliance on gr ound-based yarding methods (particularly in the Headwaters and North Fork Noyo River Assessm ent Areas), and high road densities. These

factors have led to an increase in the rates of sediment delivery due to landsliding, fluvial erosion, and surface erosion relate d to land management activities.

Elk River – The Elk River is listed by California as a high TMDL priority water body, and is classified as impaired for sediment under sec tion 303(d). Less than 20 years ago, the Elk River supported domestic water uses and relatively healthy populations of chinook and coho salmon, steelhead, and cutthroat trout (EPIC, 2002). Approximately 5,000 forest acres the North Fork drainage were clearcut or similarly ha rvested between 1990 and 1997. Following logging, sediment pollution increased drastically in the North Fork of the Elk River. Native species declined significantly in number within the No rth Fork during this time frame, and domestic water uses were completely eliminated in downstream areas. There was extensive evidence that the large acreage and rapid rate of timber operations in the watershed on the North Fork Elk River have had major adverse effects on the beneficial uses of water. Although its conditions today are far from pristine, the Sout h Fork Elk River contains some of the best habitat remaining in California for anadromous salmonid species and other native aquatic life. As summarized by the State Water Resources Co ntrol Board, the record establishes that the waters of the South Fork Elk River serve a larg e number of beneficial uses, several of which could be adversely impacted by increased se diment. In 2002, logging plans were pending thatAssessment of Water Quality Impairments Related to Forest Roads Page 68 Contract # EP-C-05-066, TO # 0002 December 4, 2008

covered more than 1,400 acres in the South Fo rk. Combined with existing problems from past logging operations, this has put the South Fork at great risk of further degradation. The Regional Board found that logging in the “Hole in Headwaters” si te would increase the amount of sediment delivery to the South Fork and a dversely impact its impor tant beneficial uses. Despite these warnings, the California Departme nt of Forestry and Fire Protection (CAL FIRE) allowed logging to commence in the Hole in Headwaters and stood poised to approve six additional logging plans in th e watershed. This would put more than half of the watershed under logging plans within a 10 year time period.

Bear Creek – The Bear Creek drainage was firs t intensively logged in the 1950s, when approximately 50% of the watershed was cut (EPIC, 2002). Subsequent to the logging, large landslides swept the creek, causing extensive damage to the stream channel. Restoration efforts followed in the 1990s at a cost of nearly $100,000. By the summer of 1996, Bear Creek once again supported coho salmon and steelhead. Simu ltaneous with these restoration efforts, however, logging in the watershed resumed at an unprecedented rate. Between 1987 and 1996, more than half of the land draining to B ear Creek was logged. In the winter of 1996-97, massive landslides again took place in Bear Cree k, turning a confined ch annel with deep pools and high-quality salmon habitat to one that is wide, shallow and filled with sediment. All of the habitat structures that were put into place during restoration were either buried or eliminated by the landslides. The stream is now severely degraded by high temperatures, sediment pollution and sedimentation. Upon inspecting Bear Creek, CAL FIRE, Water Quality, the California Department of Fish and Game, and the California Department of Mines and Geology all declared that landslides in Be ar Creek had resulted in significant adverse cumulative effects to the drainage. Reports from these inspections indicated that the drainage had been impacted “beyond reasonable limits ” and would take years to recover.

Logging plans comprising over 900 acres have been approved since 1999 or are currently pending approval for Bear Creek, threatening to bring more than 15% of the watershed under the footprint of a logging plan in the span of less than 5 years. All of these plan s include evenaged management prescriptions and winter operations, and many incl ude extensive road construction. Staff of the Regional Board conclu ded that the current a nd projected rates ofAssessment of Water Quality Impairments Related to Forest Roads Page 69 Contract # EP-C-05-066, TO # 0002 December 4, 2008

logging presented a clear threat to beneficial uses (D. Kuszmar, “Comments on Bear Creek Harvest Area Analysis” submitted by CAL FIRE on July 6, 2000).

It should also be recognized th at not all impaired waters will be included on Section 303(d) lists. USEPA regulations recognize that alterna tive pollution control re quirements may obviate the need for a TMDL. Specifically, segments are not required to be included on the Section 303(d) list if "other pollu tion control requirements ( e.g. , BMPs) required by local, State, or Federal authority" are st ringent enough to implement applicable water quality standards within a reasonable period of time (40 C.F.R. secti on 130.7(b)(1)(iii)). These alternatives to TMDLs are commonly referred to as Category 4b waters. Over the past three listing cycles, USEPA has provided additional clarity and flexibility with respect to the use of Category 4b. As a result, use of Category 4b is increasing.

As of November 28, 2007, the TMDL Tracking System database 8 included data for 2,235 TMDLs, which is an incomplete list. As mentioned above, the source of the impairment to a water body is not identified in the current TMDL Tracking System database. However, the database can be searched by keyword and the resu lts interpreted to infer the possible sources of water quality impairment for the included TM DLs. Table 2-1 summarizes the number of TMDLs matching search criteria for a number of forestry-related pollutants (sediment, turbidity siltation, habitat alte ration), type of TMDL (poi nt/nonpoint or nonpoint), and keywords (e.g., silviculture, forest, timber, forest ry, roads). The search results in Table 2-1 are listed (in descending order) by the number of TMDLs matching each combination of search criteria. At the most, these results suggest that 6 to 7% of the TMDLs included in the Tracking System database may include silviculture as a potential source of impairment.

8 http://iaspub.epa.gov/waters /text_search.tmdl_search_formAssessment of Water Quality Impairments Related to Forest Roads Page 70 Contract # EP-C-05-066, TO # 0002 December 4, 2008

3. DESCRIPTION, EFFECTIVENESS AND COSTS OF FOREST ROAD BMPS

BMPs are activities and practices to prevent or reduce pollution to waters of the U.S. They include treatment requirements, operating procedures, and practices to control runoff, spillage,

or leaks. Silvicultural BMPs are intended to reduce nonpoint source pollution and maintain stream channel integrity so that state water quality standards are met (Prud’homme and Greis, 2002). Most forest practice regulations have been designed to address ch anges in temperature

and fine sediment concentrations in water bodies, two parameters shown to have been increased by logging activities. By far the largest issue of concern for forest roads is controlling erosion and the re sulting sedimentation. BMPs on private lands are almost exclusively prescriptions of pr actices to be employed in resp onse to site conditions (Rice, 1992), and usually include a practice and some way of determining when and where the practice should be applied. The focus of regulatory activity on the development and implementation of BMPs reflects the failure of scientists and land managers to provide practical in-stream criteria for regulation of se dimentation from forestry activities (Corner et al., 1996). In the national forests, USFS BMPs are instead largely pro cedural, describing the steps to be taken in determining how a site will be managed (Rice, 1992).

There are many different BMPs for controlling wa ter quality impairments due to forest roads, as will be presented in Section 3.1. However, these many practices are actually based on relatively few guiding principles (Megahan and King, 2004; Olzewski and Jackson, 2006) and are grounded in science or based on sc ientific principles. These include:



### y Recognize and avoid high-erosion hazard areas;



### y Minimize the total amount of landscape disturbed by roads, bare ground and soil compaction;



### y Engineer stable road surfaces, drainage featur es and stream crossings to reduce erosion;



### y Separate bare ground from surface waters and minimize delivery of road-derived sediments to streams;



### y Provide a forested buffer around streams wh ich exclude roads and minimize crossings;Assessment of Water Quality Impairments Related to Forest Roads Page 71 Contract # EP-C-05-066, TO # 0002 December 4, 2008



### y Design and install stream crossings to allow passage of fish, other aquatic biota, and large wood;



### y Put BMPs in place to anticipate triggering events;



### y Unless obliterated/removed, all forest roads, crossings and associated BMPs must be maintained.

Ideally, BMPs are selected and applied based up on site-specific needs. These include specific concerns and treatments for highly-erosive or landslide-prone locations, roads and crossings on steep slopes, or wetlands. Usually a collection of BMPs or BMP system will be used at a site, as this will be more effective and provid e some redundancy in case of BMP failure. For example, combining BMPs for road construction and surface treatments significantly reduces the erosion and transport of so il away from forest roads (Swift and Burns, 1999). Relatively little information is available on the integrated effects of mitigation measures applied to separate components of the road prism (Bu rroughs and King, 1989). Se lecting the individual BMPs to combine as a BMP system at a site is a combination of science, art, judgment and experience.

Disagreements about which BMP is “best” arise from a variety of factors. First and foremost, site conditions affect impacts and mitigati on measures, and site conditions can vary tremendously. As discussed in Section 2.3.6, variati ons in site-specific an d regional factors can result in highly variable erosi on rates, risks of mass failure, etc. Depending on the proximity to and sensitivity of the receiving water, different degrees of erosion re duction and/or sediment delivery reduction efficiency may be required to prevent adverse impacts. Again, differences in effective BMP prescriptions depend on the nature and characterist ics of the site. Different and evolving performance measures have also chan ged perceptions about BMP selection. As a result of findings in the Alsea watershed of Or egon and elsewhere, most western states enacted forest practices regulations by the early 1970s (Bisson et al., 1992) to address changes in temperature and fine sediment. New concerns about the effects of logging on peak flows and on the abundance of large woody debris in st reams began to take shape in the 1970s and

resulted in renewed research ac tivity in the 1980s. Mo re recently, there has been a research

focus on the function of small headwater stream s in storing and processing sediment andAssessment of Water Quality Impairments Related to Forest Roads Page 72 Contract # EP-C-05-066, TO # 0002 December 4, 2008

organic matter (Bisson et al, 1992). BMP regulat ions have changed gr eatly within a single decade (Bisson et al., 1992). Changes in loggi ng systems, reforestation techniques, and environmental protection requirements have meant th at the concepts of BMPs for forestry have always been evolving.

Most of the factors leading to increased surface erosion from roads are manageable by adjusting road design features, employing eros ion control practices, and performing proper road maintenance (NCASI, 2001). However, th ese improvements are not accomplished easily or cheaply. Ultimately, forest managers and the regulatory agencies must determine how much change in existing road systems is sufficient to meet aquatic goals and how to achieve those changes most efficiently. This raises the issue of how environmental effectiveness is balanced with practicality, because BMPs are defined as what is practicable in view of “technological, economic, and institutional c onsiderations” (CEQ, 1971).

The individual land manager’s value system will affect how they perceive both the benefits and the costs of operations. For example, th e management practice of minimizing stream crossings is often ignored as “impractical”. This was also illustrated by the results of a small survey that was conducted to gain insight into the effect of a manager’s value system on clearcutting in steep inner gorge s and the resulting landslide er osion (Rice, 1992). Statistical treatment of the survey results was not appropriate because the questionnaire respondents were self-selected (i.e., voluntary). Both public and private respondents gave high ratings to the management objectives of harvesting timber on stable land and mitigating high risk sites.

Industrial foresters were more concerned about be ing able to harvest timber, while their Forest Service counterparts expressed about equal concern for timber harvest and landslide prevention. Private foresters’ appraisals of the loss from failing to cut timber on stable terrain was nearly twice that of Forest Service people, and they also attached a smaller penalty to causing a landslide. Rice conclude d that if forest managers be came accustomed to rigorously evaluating competing values and site conditions , improvements in erosion control could be obtained without reducing harvests.Assessment of Water Quality Impairments Related to Forest Roads Page 73 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Another example of the tradeoff between enviro nmental protection and practicality that is implicit with BMPs is the prescription for the wi dth of filter strips. Sw ift (1986) measured the distance that sediment traveled downslope be low newly constructed forest roads in the southern Appalachian Mountains , and found they were less th an previously reported. He concluded that filter strip sta ndards currently applied to forest roads in that region specified greater widths than were necessa ry with prevailing c onstruction practices. Swift noted that any guidelines for filter strip width should be based on extreme sediment flow distances rather than an average distance. However, a guideline that pr otects against all possible cases would require impractically wide filter strips. Swift also note that the distances he measured represent only the downslope extent of coarse particles of sediment (>0.05 mm), and that storm waters muddied by fine particles reached farther downs lope. If the soil material exposed and eroded from a road contained a high percentage of silt and clay, then the transport of fine particles downslope could have an important impact beyond the distances used as guidelines.

Reductions in soil erosion losses achieved thr ough runoff control and soil stabilization BMP techniques may not always be acceptable environmentally (e.g., areas that may contain sensitive terrestrial or aquatic species; Grace and Clinton, 2006). In those situations, sediment and storm water control practices are essential to reducing the quantity of sediment introduced into forest stands and available for transport directly to stream systems. Sediment control practices are installed in the path of sedime nt-laden storm runoff and are used to capture sediment as close to the source (e.g., the road prism) as possible.

3.1 What are the Types of BMPs and how are they Maintained?

There are a number of comprehensive sources of information regarding BMPs for forest roads (USEPA, 2005; Gallagher et al., 2000), and many references di scussing specific BMPs. Table 3-1 is a comprehensive list of BMP control a nd mitigation measures for: road construction; operations and maintenance; closure, decomm issioning and obliterati on; wetland operations; and mitigation for fish habitat based on Gallagher et al. (2000). The table includes descriptions of each BMP, qualitative or quantitative measures of their effectiveness in terms of reducing erosion, and estimated costs when available. Th ese BMPs are discussed below (Section 3.1) inAssessment of Water Quality Impairments Related to Forest Roads Page 74 Contract # EP-C-05-066, TO # 0002 December 4, 2008

the following categories: road planning a nd design; construction and reconstruction; management (maintenance, upgrading and clos ure); and decommissioni ng, obliteration and removal. Section 3.2 presents information on how well BMPs work, and Section 3.3 addresses

the costs of BMP installation and maintenance.

3.1.1 Road Planning and Design

The planning and design of roads includes re connaissance and route selection, determining road grade and terrain, the con centration of roads, future management, new road construction versus improvement of existing roads, and selection of construction methods. The road planning philosophy should be to fit the road to the landscape. Site conditions are often more important than management practices in determ ining the erosional cons equences of logging or road construction (Rice and Lewis, 1992). The mo st important step in minimizing the impacts of roads on streams, including both surface and mass erosion, usually occurs during

reconnaissance and route selection. This is the step where various measures to control potential adverse effects of roads on watershed pro cesses are considered. Road design involves translation of field location survey and other da ta into specific plans to guide construction. Roads are now designed to minimize cut and fi ll volume by constructing roads no wider than necessary and by fitting them as closely as pos sible to the natural topography (Gardner et al., 1978). Many landslides can be avoided by iden tifying hazardous slopes and avoiding them, and much stream sedimentation can be preven ted by constructing roads in locations where

eroded sediment will not reach streams. For se diment from surface erosion, practices that regulate road runoff amount and distribution or th at trap runoff prior to it reaching streams are particularly effective, in a ddition to practices that reduce the eroded volume. Fundamentally, this includes locating the road farther from the stream (Megahan and Ketcheson, 1996).

The mechanisms of mass failure point to design solutions to reduce the likelihood of

landslides:



### y Avoid slopes and locations with a landslide history.



### y Avoid headwall and bedrock hollow locations.



### y Avoid inner valley gorges (the overst eepened slopes adjacent to streams).Assessment of Water Quality Impairments Related to Forest Roads Page 75 Contract # EP-C-05-066, TO # 0002 December 4, 2008



### y Avoid large cuts and fills; minimize volume.



### y Don’t incorporate wood y debris in fills.

Any effort to apply BMPs should be governed by an estimate of the erosion hazard. The key to reducing adverse environmental effects lies in developing a way to identify high risk sites (Peters and Litwin, 1983). Unfortuna tely, past attempts at identif ying high-risk sites, such as the erosion hazard rating that was made part of the FPRs for the Coast Forest Practice District in California, have been considered failures due to the lack of a sound sc ientific basis (Rice, 1992).

New roads tend to be located in mid-sl ope and ridgetop locations where channel encroachment, riparian impacts, and delivery of fine sediments are minimized (NCASI, 2001). Managers must identify inherently unstable slopes and either avoi d these locations entirely, or construct roads using design and construction techniques that have been demonstrated to be effective at preventing landslides or the specific circumstance s encountered (Miller et al., 2001).

A watershed analysis completed for the LeCler c Creek watershed in northeastern Washington provides an example of mass wasting assessmen t, development and implementation of mass wasting hazard management prescriptions, and adjustment (adaptive management) of prescriptions with improved information following major runoff events in 1998 and 1999 (NCASI, 2001b). Forty-six landslides were loca ted and several moderate to high hazard mass wasting management units were identified and mapped in 1996 as part of the LeClerc Creek Watershed Assessment (McGreer et al., 1997). Subs equent detailed assessment of the area resulted in a new prescription th at required total oblit eration of all roads and no construction of new roads that lay within the area of pa rticular hazard, as id entified by geomorphic characteristics. No subsequent failu res have occurred in the watershed.

Proper road design can also improve drainage issues. Roads can often be fit more closely to the topography, with rolling grades pr oviding natural drainage, rather than the long uniform road grades used in the past. Roads should be purposef ully designed to discharge water frequently, to minimize length of direct delivery, to discharg e at locations chosen to minimize delivery ofAssessment of Water Quality Impairments Related to Forest Roads Page 76 Contract # EP-C-05-066, TO # 0002 December 4, 2008

water and sediment to streams, and to minimize concentration of water that could contribute to slope gullying or landslides (NCASI, 2001). Draina ge of existing road systems can also be redesigned to substantially reduce sediment de livery, often to only a fraction of the original amount, by increasing the frequency of relief drains or other techniques.

Another major improvement in road design and drai nage involves the size and configuration of culverts placed in streams at road crossings. Today, the mini mum design requirement of most state forest practices rules is 50 to 100 years (IDL, 2000a; ODF, 1994; WFPB, 2000).

3.1.2 Construction/Reconstruction

Many states have established BM Ps to address construction pract ices to reduce surface erosion from the road prism, avoid landslides associated with roads, reduce sedime nt delivery to water bodies, construct stable stream crossings that do not block passage of fish and other materials, and special construction practices for roads in wetlands and bottomland sites. These BMP construction categories are discussed in the following sections; additional details for specific BMPs are provided in Table 3-1.

In addition to construction BMPs, methods of forest road constructi on have also changed. Hydraulic excavators, which can precisely excavate and place materials (Bechman, 1980), have almost universally replaced bulldozers fo r road construction on mountain slopes. Soil disturbances are usually a ddressed immediately following, or even during, construction activities. Important erosion c ontrol practices to c onsider during construc tion include (NCASI, 2001):



### y Keep slope stabilization work as curren t as possible with road construction.



### y Use at least a six to ten inch minimum depth of aggregate produced from sound igneous or metamorphic rock.



### y Thoroughly clear and grub brush, timber, stumps, and other woody debris from roadbed and fill areas to prevent potentially serious surface and mass erosion problems.Assessment of Water Quality Impairments Related to Forest Roads Page 77 Contract # EP-C-05-066, TO # 0002 December 4, 2008



### y Spread cleared vegetation and woody materi als over the soil surface below fills to enhance the sediment trapping and “buffer” characteristics of the slope below the road.



### y Keep stream disturbance to an absolute minimum and avoid it altogether during high flows.



### y Limit the work area during construction to sm all sections to limit exposure of disturbed area to erosion forces in the event of adve rse weather, and keep installation of relief drains current with sub-grade construction.

The best planning and design is useless unless it is incorporated into the finished product (Megahan, 1977). Competent supe rvision of the construction pha se is required (NCASI, 2001).

3.1.2.1 Surface Erosion Control

Practices are available for effective treatment of erosion hazards for all major road prism components: cutslopes, running surfaces, road ditc hes, fillslopes, and ev en the area downslope from roads (NCASI, 2001b). An excellent summary of road erosion control effectiveness is provided by Burroughs and King (1989), who calcula ted that erosion from the entire road prism could be reduced by over 90%. Table 3-1 in cludes descriptions for a variety of BMPs for surface erosion control, including slope stabiliza tion practices, road surfacing and daylighting, and cutslope and fillslope stabilization. Table 3-2 includes data for the effectiveness of various surface erosion controls on different component s of the road prism. The erosion reduction efficiency of these treatments vary widely. With increasing application rates and percent ground cover achieved, treatment of cut and fillslopes with straw, wood chips, rock, hydromulching, or erosion mats can reduce eros ion by 80 to 100%, depending on the treatment applied. For instance, straw applied to fillslopes at a rate of 1 ton/acre reduces fillslope erosion by approximately 60%. In the southern Appalachian Mountains, Swif t (1986) reported that overwinter mulch of straw and aspha lt, at the rate applied, was a ve ry poor substitute for grass. The majority of road construction sites relied on natural revegetati on or dry grass seeding without mulching, and this was generally not effective in preventing chronic sediment delivery

to streams.Assessment of Water Quality Impairments Related to Forest Roads Page 78 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Roadway surfacing can be a particularly importa nt treatment, because tread erosion usually comprises 50% or more of tota l delivered road prism erosion, with increasing importance as road traffic increases. Development of wheel ru ts in roads approximately doubles erosion; surfacing and/or traffic control prevents the formation of ruts (Foltz and Burroughs, 1990; Foltz et al., 2000). Treating ro ad travel surfaces reduces tread erosion by 43 to 77% (Burroughs and King, 1985; Foltz and Truebe, 1995). Moreover, sediment reduction due to rock surfacing can vary by several-fold dependi ng on hardness and quality of the rock (Foltz and Burroughs, 1990). Erosion from ditches can be eliminated with rock, and Burroughs and King (1989) summarize design pr inciples and criteria.

Burroughs and King (1989) discusse d the potential for erosion re duction by various treatments on each component of the road prism. Their research was based on sediment production experiments on 100 feet of roadway in northern Idaho at the Intermountain Research Station. They found that graveling the travelway redu ced sediment production by an average 33%. Graveling both the travelway and roadside ditc h was estimated to reduce sediment production by 57%. If graveling of the travelway and ditc h were combined with cutslope protection, sediment production was reduced by an estimated 91%.

An Oregon wet season road use monitoring proj ect made specific BMP recommendations for controlling road surface erosion under crit ical conditions, when conventional BMP prescriptions would not adequately c ontrol erosion (Mills et al., 2003):



### y Use aggregate containing the minimum percen tage of fines needed to bind and pack and seal the surfacing. Where there are exce ss fines; screen aggregate to reduce the percentage of fines in the rock and lower sediment delivery.



### y Use at least a six to ten inch minimum depth of aggregate produced from sound igneous or metamorphic rock (use more where the subgrade is soft).



### y Reduce the length of road segments that de liver to streams to less than 250 feet by adding cross drain culverts or other drainage structures.



### y Prioritize inspection of wet w eather active operations during th e first moderate rainfalls (3 day total rainfall of 1.5- 3 inches) to determine if immedi ate repairs are needed or if ceasing road use is necessary.Assessment of Water Quality Impairments Related to Forest Roads Page 79 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Drainage control BMPs include road outsloping broad- based dips, waterbars, relief culverts, cross-drains, ditches and turnout s, and belt diverters (Table 3- 1). Drivable br oad-based dips

divert runoff from the road tread onto the hi llslope below the road, reducing overland flow

distances and the resultant er osion (Logan, 2001). Drivable dips are popular because they are relatively inexpensive to install, and because they can be retrofitted to existing roads. However, these and other road BMPs such as di tch relief culverts, ope n top culverts, and belt diverters are only effective if they are located so that the sediment travel distance below the drainage outfall is less than th e distance to the nearest stream (Woods et al., 2007). Research conducted at the Coweeta Hydrologic Laborator y demonstrated how a number of these drainage and erosion control BMPs (outsloped roads with no insi de ditches; broad-based dips to divert road drainage; outside berms and brush barriers; gravel and/or grass cover; minimized road width and curve radius; and stream buffer s) could be combined to construct low-cost, lower-standard forest roads that still reduced erosion and sediment generation

. The Coweeta

research is reflected in ma ny state BMP programs, especially in the southeast region (Prud’homme and Greis, 2002).

Analyses of the effectiveness of erosion control BMPs suggests that they should be effective in controlling sedimentation at th e watershed scale, if correctly and fully implemented. Watershed assessment conducted for the Plum Creek Timber Company Habitat Conservation Plan (HCP) indicated that construction of additional drainage structures near stream crossings

would eliminate 25 to 85% of road sediment delive red to streams in the eleven watersheds that were evaluated (NCASI, 2001b). An extensive road system in the Spruce Creek watershed of northern Idaho was assessed using the Washingt on watershed assessment procedures (NCASI, 2001b). Analysis of site-specific conditions in th is watershed revealed that the addition of drainage relief structures near streams would reduce sediment delivery from this existing road system from 257 tons to 108 t ons (McGreer et al., 1998).Assessment of Water Quality Impairments Related to Forest Roads Page 80 Contract # EP-C-05-066, TO # 0002 December 4, 2008

3.1.2.2 Landslide Avoidance

Aside from design precautions (Section 3.1.1), other BMPs that can significantly reduce likelihood of mass failure include minimizing sid ecast, full-bench end-haul construction, and avoiding organic matter in fill (Table 3-1). In addition, the following guidance is offered for landslide avoidance (NCASI, 2001c):



### y Carefully size culverts and install trash r acks to prevent plugging, particularly where fill failure could lead to downstream debris flow.



### y Drain water frequently to a void concentration on or belo w fills and to help avoid further concentration in the event of cutslope failure.



### y Outslope roads where practical, and consid er reshaping insloped roads to outsloped prisms with surface drains when they become inactive.



### y Eliminate sidecast on steep slopes (those over 50%).

3.1.2.3 Sediment Delivery Reduction

Table 3-1 also includes descri ptions for a variety of BMPs to reduce sediment delivery to streams: removal of direct-entry culverts, co ntrol drain outlet erosi on, and application of sedimentation basins and filter windrows. Reducing the length of road that drains directly to

streams via ditches at road cr ossings can substantially reduce total road system sediment delivery (ODF, 2000; McGreer et al., 1998). Reducing the length of road segment contributing to a relief drain also reduces sediment delivery to streams, because the distance the water and sediment travel downslope before being trappe d and infiltrated decreases due to decreasing source area for water supplied to the road segm ent in question (i.e., th e volume of water and sediment discharged is smaller and is theref ore trapped or infiltrated sooner; Megahan and Ketcheson, 1996; Packer, 1967; Elliot et al ., 1997). BMPs should specify the maximum spacing of relief culverts for road segments within about 500 feet of any stream channel.

Where relief culverts or water bars discharge within about 300 feet of any stream channel, adequately-sized sediment traps and energy diss ipation and/or flow spreading measures should be applied to the discharge to prevent the road drainage from integr ating with the naturalAssessment of Water Quality Impairments Related to Forest Roads Page 81 Contract # EP-C-05-066, TO # 0002 December 4, 2008

stream network. Increasing obstructions (e.g., rocks, logs, stumps, slash, etc.) on the hillslope below a drain reduces sediment delivery becau se of increased opportunity for sediment deposition and reduced sediment travel distan ce (Brake et al., 1997; Megahan and Ketcheson, 1996). However, relying solely on slash berms or piles is not adequate to prevent channel development from concentrated discharges, such as relief culverts. Filter windrows constructed at the toe of fillslopes reduce sediment leavi ng the fillslope by approximately 85% (Burroughs and King, 1989).

3.1.2.4 Stream Crossings

The stream crossing is the most critical section of road influencing water quality (Taylor et al., 1999). The midwestern state forestry BMP manual s suggest that the be st way to maintain water quality during forest management is to avoid crossing a stream (NCASI, 2007). Location, number, type and size of crossing stru cture, and timing and location of construction are all important factors. Table 3-1 includes BMPs for both temporary and permanent crossings. Portable bridges, log crossings, pole fords, and tempor ary culverts are examples of temporary crossings. Permanent crossing BMPs in clude fords (low water crossings), bridges, increased-capacity and arched culverts, and dive rsion proof (fail-safe or fail-soft) crossings.

Culverts are the most prevalent kind of stream crossing on forest roads, and usually cause the most problems in terms of blocking fish passa ge, plugging and subsequent failure, and chronic erosion and sediment delivery. Scouring at culvert outlets should be controlled with energy dissipaters. Although trash racks are prescribed to prevent cu lvert plugging by trees and other debris, their use may contribute to fish passage problems. Installation of round culverts should be avoided where fish passage is necessary; brid ges and arch culverts are preferred for streams with migrating fish.

Washington State FPRs require that new and replacement culverts be installed to ensure free and unimpeded passage for fish, and that road maintenance and abandonment plans specifically address removing artificial barriers to passage of fish by adhering to specific culvert design guidelines (Cupp et al., 1999). For culvert fills at stream crossings, armoringAssessment of Water Quality Impairments Related to Forest Roads Page 82 Contract # EP-C-05-066, TO # 0002 December 4, 2008

(e.g., rock riprap) should be requi red on both the inflow and outflow side of the road (Rashin et al., 1999). Construction phase erosion control measures should be a pplied to all culvert tills at stream crossings. Special attenti on to armoring and revegetation is needed on tills greater than ten feet high. The extent to which stream cr ossing culverts become migration barriers to resident fish and other aquatic lif e, and the implications of such barriers to ecosystem integrity, should be fully evaluated. If subsequent evalua tions determine that adverse ecosystem effects are occurring, measures to mitigate such effect s should be developed. Alternatives to using culverts for crossings of steep streams, such as temporary or permanent bridges or other temporary crossings, should be prom oted as a preventative measure.

3.1.2.5 Wetlands and Bottomlands

The CWA regulates road constr uction activities in wetland areas because of the potential for environmental impacts. If the road is constr ucted and maintained in accordance with 15 specific BMPs the USEPA provides an exemption to permitting requirements. The wetland BMPs are stated in performance language (i .e., required outcomes) rather than specific guidance, and provide no information on how to pr operly stabilize fill mate rial in wetland road construction (Rummer, 1999). Most of the resear ch studies on forest road construction and erosion control have been conducted in upl and topography where erosion processes are significantly different from floodpl ain conditions. There is little scientific knowledge about the water quality effects of forest roads in bottomland stands.

The available research suggests that erosion with floodwater is a transport-limited process (Rummer, 1999). To minimize water quality imp acts of forest roads in bottomland stands, BMPs should focus on reducing water velocity (i.e ., brush barriers, vegetative stabilization) or appropriately anchoring soil in higher-velocity areas. Reducing the amount of exposed soil is not necessarily the best approach to avoiding water quality impacts, because water quality impacts in wetlands and bottomlands are transp ort-limited, not source-limited. Results of one long-term study (Rummer, 1999) suggest that forest roads in bottomland stands are unlikely to significantly impact the suspended sediment tr ansport of passing floodwater. The key factor affecting sediment generation and transport in bottomlands is flow velocity and direction.Assessment of Water Quality Impairments Related to Forest Roads Page 83 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 3-1 includes several BMPs specifically for wetlands. These include runoff diversion, minimizing rutting, the use of temporar y roads and fill removal, and berms.

3.1.3 Road Management

Road management includes inspection and maintenance activities, upgrading, temporary closure, putting to bed (decommissioning) , and road obliteration (Table 3-1).

3.1.3.1 Maintenance

Maintenance is recognized as a critical component of both the transportation and environmental performances of roads. Road ma intenance is critical in order to provide

continued access and control environmental impacts (NCASI, 2001). Properly maintained roads have a stable surface and an operating drai nage system that drains water from roads as quickly as possible onto the forest floor instead of directly to str eams. Road maintenance

BMPs executed to minimize surface erosion a nd mass wasting include: surface grading and maintenance of road gravel to prevent rutting; ditch cleaning to insure that water remains in

ditches and does not erode the ditch or th e running surface; monitoring, cleaning, and replacement of relief and stream crossing culver ts; monitoring and grading of rolling dips; and treatment of cut and fillslopes to encourage and retain protec tive vegetation (NCASI, 2001). Roads should be inspected at regular intervals, especially during or fo llowing large rainfall or snowmelt events and can include an inventory of existing and potenti al erosion and slope

failures on all roads.

Traffic access control through the use of gates is commonly practiced to minimize road surface damage during wet periods, to reduce erosion and sediment delivery. The results are often substantial; preventing ruts in road surfaces alone can reduce erosion by approximately 50% (Burroughs and King, 1989). Lowering the pressure of truck tires is another BMP that has been shown to be effective in preventing rutting and reducing erosion. Traffic control BMPs include road closure, access restriction, wet weather tr affic restriction, and seasonal use roads.Assessment of Water Quality Impairments Related to Forest Roads Page 84 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Traffic and road maintenance are two interrelate d components in road management that have the potential to influence sediment movement from forest roads (Grace and Clinton, 2006).

Increased soil erosion has been at tributed to traffic in previous research conducted on roads in mountainous regions (Bilby et al., 1989; Burroughs and Ki ng, 1989; Foltz, 1999; Reid and Dunne, 1984). Increased erosion losses can re quire increased maintenance to maintain drainage patterns and prevent (or minimize) the impact on downslope resources. However, in an investigation of the influe nce of traffic and road mainte nance on sediment production from forest roads in the Oregon Coast Range (Lu ce and Black, 2001), ditch grading had a greater

effect on increased soil erosion than traffic. Ma intenance operations can increase soil erosion by removing armoring layers on the road surface a nd in the ditch that develop over time (Black and Luce, 1999). Road segments where vegetati on was cleared from the cutslope and ditch produced seven times as much sediment as ro ad segments where vegetation was retained, showing the potential reduction in erosion by revegetation follow ing construction and potential impact of ditch cleaning during ma intenance (Luce and Black, 1999).

In a study of road surfacing types on sediment yi eld in the Pacific Northwest, Reid and Dunne (1984) found that over a one year period, graveled road segments receiving heavy traffic produced 130 times more sediment than road segments receiving no traffic. In this study, traffic intensity greatly influenced (7.5 times the rate measured during periods of no traffic) soil loss and suspended sediment concentrations in runoff. It was hypothesized that soil loss from the road segments was influenced by the frequency of road maintenance and grading.

3.1.3.2 Upgrading

Upgrading activities are similar to maintenan ce, as they also i nvolve ongoing inspection, assessment of problems, and control action to avoid or remedy the pr oblems. With upgrading,

old roads built to lower standards with lower se nsitivity to environmental issues can be brought up to current standards as forest harvesting occurs in adjacent areas or where priority environmental concerns are identified (ODF , 2000; WFPB, 2000). In many cases, major reductions in environmental impacts are possi ble through relocation and improvement of oldAssessment of Water Quality Impairments Related to Forest Roads Page 85 Contract # EP-C-05-066, TO # 0002 December 4, 2008

roads (NCASI, 2001). General recommendations ar e provided for improving ineffective and partially effective BMPs (Rashi n et al., 1999). These recommendati ons are intended to attain a high confidence of achieving water quality st andards by preventing or minimizing chronic sediment delivery from surface erosion and avoiding physical disturbances and habitat degradation in streams:



### y For culvert fills at stream crossings, armoring (e.g., rock riprap) should be required on both the inflow and outflow side of the road.



### y Alternatives to using culverts for crossings of steep streams, such as temporary or permanent bridges or other temporary crossi ngs, should be promot ed as a preventative

measure.



### y Road location practices should minimize new ro ads within about 500 feet of streams in order to minimize the integration of ro ad drainage with the stream system.



### y The maximum spacing of relief culverts should be reduced for road segments within about 500 feet of any stream channel.



### y Where relief culverts or water bars discha rge within about 300 feet of any stream channel, adequately-sized sediment traps a nd energy dissipation a nd/or flow spreading measures should be applied to the discha rge to prevent the road drainage from integrating with the natural stream network.



### y Relying solely on slash berms or piles is not adequate to preven t channel development from concentrated discharges, such as relief culverts.

Perhaps the most acceptable altern ative to manage forest roads for soil and water protection is upgrading the most critical road s (Grace and Clinton, 2006). In many watersheds, specific road segments are responsible for a disproportionately high share of total road sediment delivery (NCASI, 2001). If the major stream impacts in a watershed are associated with sediment discharged from roads, the mean s of control is to identify a nd treat the specific roads that contribute the sediment, not merely to redu ce road density. Where land managers recognize higher hazards for road erosion they can modi fy road design and maintenance practices to minimize impacts (Bourgeois, 1978).Assessment of Water Quality Impairments Related to Forest Roads Page 86 Contract # EP-C-05-066, TO # 0002 December 4, 2008

3.1.3.3 Closure

Roads that will not be used again in the near future are often closed. This is a management BMP that temporarily removes th e road from use and retains it for future use. This is an extremely cost-effective measure in cases wh ere environmental conc erns do not require obliteration (described below). With no traffic, closed roads can reduce soil loss and suspended sediment concentrations in runoff by an order of magnitude compared to roads with traffic (Reid and Dunne, 1984). At some time in the fu ture, the road may be reconstructed with

minimal disturbance. Roads that are closed ma y require periodic inspection and maintenance. A key to road closure is achieving self-maint aining drainage and, as part of the closing process, roads may be upgraded according to potential impact to riparian and aquatic

resources.

3.1.4 Decommissioning/Putting-To-Bed and Obliteration/Removal

There is a continuum of BMPs for temporarily decommissioning roads (also known as “putting to bed”) to completely obliterating roads th at can be used to decrease the costs and environmental impact of forest roads (Tab le 3-1). Decommissioni ng can involve closing access, reseeding the road surface, removing temporary stream crossings, and opening drainage structures that may fail. A decommissioned road is put into an erosion-resistant condition but can be re-opened at a later da te when access again might be needed. Road obliteration, on the other hand, is the partial or complete re moval of the road from the landscape. Obliteration goes farther than deco mmissioning in restoring hillslopes, natural drainageways, and vegetation. Obl iteration is intended to eliminat e future road maintenance. The road prism is obliterated and returned to a naturally functi oning component of the landscape. Road removal involves the physical trea tment of a roadbed to restore the form and integrity of associated hillslopes, channels , and flood plains and their related hydrologic, geomorphic and ecological processes and properties (Switalski et al., 2004).

Long-term road treatments such as deco mmissioning and obliteration are becoming more common. Road decommissioning can lead to improve ments in fisheries habitat where sedimentAssessment of Water Quality Impairments Related to Forest Roads Page 87 Contract # EP-C-05-066, TO # 0002 December 4, 2008

runoff from old forest roads en ters streams (TetraTech, 1999). Reduction of sediment delivery to streams can be particularly significant where roads in highly erosive materials are located adjacent to streams. The practice was used in a watershed in northwest Washington as part of a watershed rehabilitation to impr ove fisheries habitats and water quality and to reduce flooding hazards. On unused, 30- to 40-year-old, largel y impassable roads and landings, fills were stabilized, stream crossings were removed, sl opes were recontoured, and drainage patterns

were reestablished at an average cost of $5,600 per km (range: $2,100 to $10,600; TetraTech, 1999). Luce et al. (2001) outline funda mental principles for strategies to prioritize road closure and decommissioning. The most common priority is the ‘problem’ roads th at yield substantial mass wasting or severe surface erosion. Such ro ads represent a small fraction of most road systems, and many such roads have already b een decommissioned. In some cases, sediment modeling has been used to suppor t prioritization for road closures and decommissioning. This is often in response to the goal of managing basin- wide sediment yields to be within prescribed limits (Luce et al., 2001).

Where there is significant landslide hazard, old roads may be obliterated. Full road recontouring has been used effectively to reduce landslides in northern California, western Washington, coastal Oregon, and northern Idaho (Switalski et al., 2004). In Redwood National Park, a 12-year storm produced ve ry little sediment from treated roads. In Clearwater National Forest, a 50-year storm resulted in no landslides on treated roads. Although road removal treatments do not completely eliminate erosion associated with forest roads, they do substantially reduce sediment yields from abandoned logging roads (Madej, 2001). Removing abandoned forest roads and restoring the natural characteristics of slopes and stream channels

in the Redwood National Park and State Parks in northern California have substantially reduced the delivery of sediment to salmon-bear ing streams. However, it has also been noted that no form of road removal was able to pr event chronic erosion co mpletely on steep lower slope roads (Switalski et al., 2004).

Methods to remove roads continue to evolve. Useful experience with this BMP has come from major federal road removal efforts as part of watershed rehabilitation in Redwood National Park, and other locations in Oregon, Washi ngton and Montana (Gallagher et al., 2000). AAssessment of Water Quality Impairments Related to Forest Roads Page 88 Contract # EP-C-05-066, TO # 0002 December 4, 2008

critical issue in decisions about road d ecommissioning is whether disrupting the new environmental balance created by the presence and aging of the road is desirable (Gucinski et al., 2001). Road removal can cause accelerated eros ion losses in the short-term (Switalski et al., 2004), and the risk of mass failure may still exist (Luce et al., 2001). Recontouring, the highest level of obliteration, involves removi ng embankments and replacing cuts, removing drainage structures, reestabl ishing soil permeability and subsurface flows, fixing gullies, reestablishing vegetations and controlling surf ace erosion (Moll et al., 1997). Hickenbottom (2000) reported that recently recontoured road segments produced signif icantly more sediment than roads recontoured 12 months previousl y. Although sediment yield was greatly reduced one year after recontouring, the recontoured roads were susceptible to erosion immediately

after treatment. Given that there is little contro l or ability to maintain areas after recontouring or ripping, a well-designed, open, and maintained road may someti mes represent less risk for mass wasting (Luce et al., 2001).

The effectiveness of restoring natural stream and flood plai n function by decommissioning and

obliteration still needs to be a ddressed. No studies have examined influence of road removal on the recovery of aquatic, ri parian and/or terrestrial ecosy stems (Switalski et al., 2004).

3.2 How Well do Forest Road BMPs Work?

The key measure of nonpoint source pollution co ntrol success, laid out by USEPA guidance and the overall goals of the CWA, was whether the NPS control program could achieve desired water quality goals (Madej, 2001). It was assume d that BMP practices including forest road BMPs could successfully mitigate sedimentation impacts and BMP implementation would protect water quality from nonpoint source pol lution. To some degree, it is unknown whether current forest practice rules have or will resu lt in achieving PL 92-500’s specific water quality targets (Rice, 1992). The need to monitor and ev aluate the relative e fficacy of BMPs still exists. Although a substantial amount of research has been conducted on BMP performance at the site level, relatively little work has been undert aken to investigate the effect of forest road BMPs on erosion and water quality (Grace, 2002). There is a lack of info on how modern (post 1980s) road building technologies (including incorporation of BMPs) may reduce massAssessment of Water Quality Impairments Related to Forest Roads Page 89 Contract # EP-C-05-066, TO # 0002 December 4, 2008

wasting and water quality impacts (USEPA, 2005). There is some evidence that modern road building practices are reducing the amount of sediment delivered to streams from forest roads. Binkley and MacDonald (1994), for example, c ite many studies showing reduced impact of forestry practices with BMPs, although some degree of impact is usually detected. State agencies consistently report th ere is insufficient monitoring da ta to make sound assessments (Corner et al., 1996).

Studies of the effectiveness of silviculture BMPs in preventing water quality impairments have

been undertaken at several differe nt scales (Ice, 2000). For this re port, effectiveness studies are categorized according to studies of individual site s (which also address smaller road networks and associated stream segments), and waters hed scale studies. Although site-level research usually differentiates BMPs for forest roads from others (e.g., RMZs or harvest activities), the effectiveness of forestry BMPs are generally cons idered together at the watershed scale. Water quality impacts observed at this scale therefore reflect the integration of many individual sites and practices. However, these impacts are often related to roads and stream crossings, which are acknowledged to be predominant sources of sediment to forest streams.

Initial assessments of BMP effectiveness involv ed research plots, fi eld evaluations, small paired watershed studies, and application of ag ricultural models like the Universal Soil Loss Equation (USLE) to forest conditions (Ice and Whittemore, 1998). These all provided valuable information, but they were also limited. Most we re designed to provide only a local assessment of impacts, often to an indi vidual operation. The assumption wa s that if impacts could be minimized at the site, they would be diluted downstream. However, conc erns about cumulative effects caused forest managers to explor e alternative assessment approaches. Early assumptions about downstream dilution, transport of impacts, and stream response were challenged. With maturation of CWE assessments , watershed specialists began to recognize both the dynamic nature of watersheds and stream s, and the potential for and need to address operational fall-down of BMPs (Callaham and De Vries, 1987). This led to development of BMPs such as "diversion proof road designs " (Hagans and Weaver, 1987) and "debris torrentresistant road crossings" designe d to minimize impacts to waters heds during extreme events. In recent years, watershed-scale assessments were further stimulated by legal requirements toAssessment of Water Quality Impairments Related to Forest Roads Page 90 Contract # EP-C-05-066, TO # 0002 December 4, 2008

develop TMDLs and the growth of Geographic Information System (GIS) technology and landscape ecology methods capable of addressi ng spatially complex watershed problems.

3.2.1 Site Level Forest R oad BMPs Effectiveness

Site level studies of forest road BMP effectiveness examine how well BMPs work in specific sections of roadway, crossings, a nd other features at a specific site or sites. The study methods include visual observations (e.g., eroded soil vo lumes, sediment plume travel distances), sediment traps, and monitoring of water quality parameters (TSS and/ or turbidity) in runoff. Site

level studies focus on how well BMPs control the sources of sedimentation (erosion, mass wasting and delivery), and are usua lly able to compare sites with BMPs to control sites lacking

BMPs.

A number of methodologies ha ve been developed for mon itoring erosion and sediment production at sites based on upslope or on-site evaluations (Corne r et al., 1992). Corner et al. (1996) compared the use of sediment traps, a relatively inexpensive upslope monitoring technique, with weekly instream monitoring of TSS. Upslope m onitoring, using sediment traps

above and below disturbed fore st areas, has several advantages over instream monitoring. Instream monitoring is more time-consuming and expensive compared to the upslope approach. Careful observation of on-site processes, such as the formation of sediment trails, can document sedimentation processes unaccounted for by either instream or upslope monitoring procedures. Qualitative walk-in-the rain monitoring may help identify key problem areas and processes and considerably augment quantitative data (MacDonald and Smart, 1993).

Sediment traps were used by Sugden and Woods (2007) to measure rates of sediment production from forest roads in western Montana. They found that rates of road eros ion in this region were relatively small and were limited by low erodibil ity of the dominant parent materials and low

rainfall. The efficiency of five, 0.8 m 3 sediment traps in measuring road erosion ranged from 21 to 84%, with a mean of 56%, which compares favorably with those reported by other researchers. Sediment trap effi ciency was inversely correlated w ith the fraction of clay in the roadbed. At the site where trap efficiency wa s 21%, the measured sediment yield had to beAssessment of Water Quality Impairments Related to Forest Roads Page 91 Contract # EP-C-05-066, TO # 0002 December 4, 2008

increased by a factor of 2.3. It is importan t to consider how the accuracy of erosion measurements made by different methods depend on factors such as the efficiency of sediment traps, as they can substantially affect the qua lity and comparability of erosion as well as sedimentation data. Likewise, methods based on dr y-weather observation of sediment plumes are subject to possible bias.

BMP effectiveness studies, taken together, demons trate that modern BMPs substantially mitigate nonpoint pollution from forestry activities at the site scale, although the BMPs are not 100% effective (Jackson et al., 2004). The exception to th is generalization is uns table locations in key problem areas of the PNW (Idaho, northwest California, western Oregon and Washington, and southeast Alaska) where conventional BMPs for road construction may not be sufficient to prevent adverse effects on stream channels a nd fish habitat (Binkley and MacDonald, 1994). Table 3-2 is a compilation of nu merous site level BMP effectiveness studies. Operations complying with BMPs led to stream sedimentat ion problems in fewer than 10% of 40 projects studied in Idaho (Harvey et al ., 1988). Robinson et al. (1999) i ndicated that Oregon FPRs were likely reducing the size and number of road-a ssociated landslides. Other site-level BMP effectiveness studies include the McGreer (1981 ) Potlatch skid trail erosion study, the North Carolina Flatwoods sites (Appelbloom et al., 1998), and the Megahan and Ketcheson (1996) study of sediment travel distances.

Swift (1984b) studied erosion on newly constructe d timber sale access roads in the southern Appalachian Mountains. After seeding and grading the road surfaces with gravel, soil loss rates were greatly reduced, especially from the grass-covered cut and fill slopes. However, some erosion from the roadbed continued. Despite the reduced erosion rates after these mitigation measures, soil loss from the entire roadway was calculated to be about 20 times the normal rate for undisturbed forest. Improving roads for all-weat her use by installation of adequate culverts and gravel surfaces can have short-term negativ e effects such as the generation of sediment.

A number of states have deve loped programs to monitor water quality and stream habitat condition in the proximity of sites (Ice et al., 1997). In the early 1990s, the North Carolina Division of Water Quality and the USFS examined th e effectiveness of BMPs on a forest road inAssessment of Water Quality Impairments Related to Forest Roads Page 92 Contract # EP-C-05-066, TO # 0002 December 4, 2008

the Appalachians (North Carolina Division of Water Quality, 1994). A long-existing road, which closely paralleled Timbered Branch and its tributaries for about 2 miles and had been a chronic source of road sediments to the stream, was retr ofitted with a number of measures designed to reduce sediment loading. They included ditch outle ts, sediment traps, berms, weeps, outslopes, humps, and relief culverts. Sediment reducti on was assessed qualitati vely, and biological monitoring was conducted on the affected stream s to determine effects on aquatic species. Improvements in taxa richness and diversity in the aquatic community were attributed to the sediment reduction practices (Prud’homme and Greis, 2002).

The South Carolina Forestry Commission, in co operation with Clemson University and the South Carolina Department of Health and Enviro nmental Control, evaluated the effectiveness of silviculture BMPs in protecting water quality in all physiographic regi ons in South Carolina (Adams et al., 1995). Twenty-seven harvested sites from the Coastal Plain to the mountains were selected. BMP compliance on the sites ranged from inadequate to excellent , thus bracketing the full range of potential effects. BMP effectiven ess was determined by Stream Habitat Assessment (SHA) and benthic macroinvertebrate monitori ng. Poor logging practices were linked to impaired benthic invertebrate condition and aquatic habitat (D issmeyer, 1994). Ten sites that rated inadequate for BMP compliance experience d negative SHA impacts. On sites where BMP compliance was rated as adequate or excellent, SHA indicated that str eams were not impacted. Sites that passed BMP compliance inspection sc ored well on the bioassessment. The authors concluded that BMP compliance inspections appear ed to be a reliable and economical surrogate for monitoring BMP effectiveness in Sout h Carolina (Prud’homme and Greis, 2002).

Seven and one-half miles of Three Forks Road were reconstructed in the Conasauga River Watershed in northern Georgia and southeastern Tennessee (Riedel and Vose, 2003). The gravel road was reconstructed to reduce slope and br eak up long grades; center crowns, ditches and culverts were removed; cut-and-fill slopes were vegetated; brush barriers were installed on fill slopes; settling areas were contained with hay bales, brush ba rriers and silt fences; and coarse run aggregate was added to roads to reduce surf ace erodibility (Swift and Burns, 1999; Swift, 1988). Sediment yields post-treatment were ini tially very high (though less than average pre-Assessment of Water Quality Impairments Related to Forest Roads Page 93 Contract # EP-C-05-066, TO # 0002 December 4, 2008

treatment) and rapidly declined to levels well below that of pre-treatment. Road reconstruction reduced sediment yield by 70% within 4 months, despite greater precipitation.

Woods et al. (2007) measured sedi ment travel distances below dr ivable drain dips along unpaved roads in the metasedimentary Belt Series and gl acial till parent material s of western Montana. Drivable dips and other road BMPs such as ditc h relief culverts, open top culverts, and flapper water bars are only effective if they are located so that the sediment travel distance below the drainage outfall is less than the distance to the nearest stream. The travel distances measured by Woods are lower than those measured in graniti c parent material. Due to the limited sediment travel distances, most drainage outfalls in thes e parent materials do not contribute sediment to streams. However, the researchers note that dry weather determinati on of sediment travel distances are subject to error, and that fine sediment moves farther.

Studies of stream crossings and wetlands have been summarized by Rehder and Stednick (2006). Thompson et al. (1996) reported sediment producti on from fords, and sediment production from temporary culverts and bridges was investig ated by Whitewater (1997) and the USFS (USFS, 1981). Thompson and Kyker-Snowman (1989) measur ed the short and long-term impacts of “mitigated” and unmitigated stream crossings. Wetland crossing studies reported generally minimal water quality impacts, but noted that sedimentation effects were most effectively controlled by keeping runoff on the roadway (as opposed to roads in upslope landscapes, where BMPs are applied to remove runoff from the road).

Although silviculture BMPs are grounded in science or are based on scientif ic principles, a lack

of science to validate BMP effectiveness has been noted as a shortcoming of many BMPs related to forest roads (Grace, 2002). For example, routi ng runoff onto the forest floor is often presented as a trapping mechanism and means to reduce sediment delivery to streams. Through proper design, filtering of runoff from forest roads can be induced by directing flow onto the natural litter layer of the forest floor. However, in steep terrain, this filtering may not be sufficient to arrest sediment-laden flows. In addition, the f iltering capacity of forest floor is limited and

diminishes over time.Assessment of Water Quality Impairments Related to Forest Roads Page 94 Contract # EP-C-05-066, TO # 0002 December 4, 2008

BMP performance is usually defined in terms of a constant pollution reduction efficiency, as presented in Table 3-2. In real ity, the performance of BMPs and associated impacts vary considerably with geology, terrai n, other watershed characteristics, site locations and weather. This, combined with various intensities of fore stry practices and traffic levels, can lead to localized water quality problems th at may not be fully controllable by BMPs, especially at the

cumulative scale of watersheds.

The difficulty with rating BMP efficiency is that the same practice on different sites, in different watersheds, or even with different weather patt erns can result in differe nt impacts (Ice et al., 2004). In order to maximize the performance of BM Ps at a site, the BMP prescription must be customized to the setting. Specific examples related to site conditions include the following (Olszewski and Jackson, 2006):



### y Avoid sidecast road construction in steep, landslide prone regions;



### y Diversion-proof or storm proof roads where gully formation is a significant risk (e.g., steep forest roads);



### y Provide adequate rocking or use geotext ile reinforcement where surface fines are generated by traffic;



### y Remove runoff concentrated by interception of subsurface flow or precipitation from the road (using cross drain distance, outsloping, rol ling dips, road runoff diversion structures) before concentration and excessive rutting occur;



### y Avoid direct delivery of sediment from road s by limiting the road distance draining to stream crossings, by applying effective buffe r distances and slash/debris/grass buffers;



### y Use energy dissipaters where road runoff energy is high;



### y Apply mitigation measures such as road d ecommissioning or removal, or upgrading with additional BMPs, to reduce risks in legacy watershed situations.

Customizing the BMPs for forest roads is a popul ar solution to “problem” roads and roads and crossings in highly erosive and high risk locations. However, cu stomized BMPs require greater skill and effort on the part of the forest ma nager and knowledge of where the problems are located, both of which increase th e difficulty for states to dete rmine whether BMPs have beenAssessment of Water Quality Impairments Related to Forest Roads Page 95 Contract # EP-C-05-066, TO # 0002 December 4, 2008

properly implemented. In this situation, performan ce standards that are re alistically achievable should be used to set goals for the BMPs (Rashin et al., 1999).

Major storms are the design condi tion for many BMPs. Some BMPs will function in a 5-10 year storm; more on-slope BMPs will fail in a 25 year storm; and, all BMPs may fail in a greater than 25 year storm (Dissmeyer, 1994). At the level of rare events, natural impacts and processes may overwhelm management decisions, and their impacts may be obscured. Assessments of BMP effectiveness must therefore wait for “testing st orms”, like the severe 1996 floods in Oregon and

southern Maine.

3.2.2 Watershed Scale Forest Road BMPs Effectiveness

A number of large studies have focused on how forestry practices including BMP implementation has contributed to changes in sedimentation and other water quality impairments. Because such impairments are usually a cumulative response to many sediment sources and can occur considerably downstream , these studies are generally conducted at the watershed scale. These studies test the hypot hesis that forestry practices, including the application of BMPs, will be effective at mini mizing cumulative water quality impairments to

maintain and restore beneficial uses. A number of these studies have examined how water quality impairments due to forest roads are mitigated by BMP implementation.

Watershed-scale research is much more complex, da ta-intensive and expensiv e than site studies. Interpreting the results of wa tershed studies can also be difficult and contentious. Large watershed-scale studies have a number of importa nt advantages for monitoring effectiveness of BMPs (Ice and Whittemore, 1998). These include:



### y Watershed-scale assessment allows for an integrated or cumulative measure of BMP and program effectiveness.



### y It allows BMP effectiveness to be placed in the context of realisti c variations in water quality throughout a watershed and over time;Assessment of Water Quality Impairments Related to Forest Roads Page 96 Contract # EP-C-05-066, TO # 0002 December 4, 2008



### y It allows for assessment of the conservati ve/non-conservative nature of water quality parameters;



### y It connects upslope hazards with dow nslope aquatic resource risks; and



### y It allows for assessment of unanticipated conseq uences that might not be identified at the site scale.

Several methods are used to compare the water qua lity response with BMPs to either undisturbed (i.e., no roads) or untreated (no BMPs) refe rence watersheds. The most common methods involve using paired watersheds or before/after comp arisons of past and current measures of impacts from forest operations. Paired watershed studies may be superior in that they can be used to explain the important fact or of weather variations (Loftis et al. 2001), although there are limits. In the Mica Creek Watershed Study a small thunderstorm cell perched nearly directly over one experimental watershed, causing significant runoff, while completely skipping a nearby paired watershed (Ice, 2000). Another method that is seeing more widespread use by states is trend monitoring of stream habitat conditions, su ch as the Aquatic Inventory Project in Oregon.

A possible measure of effectivene ss is achieving state water qualit y standards or stream habitat goals (Ice, 2004). Under the CWA, states are requ ired to establish water quality standards to protect beneficial uses of wate r. One trouble with wate r quality standards is that they have not adequately characterized what is achievable a nd even desirable. Furthermore, states have different standards for suspended sediment, tu rbidity and sedimentation. Turbidity standards capture suspended sediment, but not the degradation of stream substrates by fine sediment, and

there are no criteria that m easure hydrologic change (Scurlock, 2007). Efforts by USEPA to develop water quality criteria for suspended and bedded sediments (SABS) are noteworthy in this regard. SABS are defined by USEPA as pa rticulate organic and inorganic matter that suspend in or are carried by the water, and/or accumulate in a loose, unconsolidated form on the bottom of natural water bodies (Swietlik, 2003). SABS are a unique water quality problem when compared to toxic chemicals, for example, because suspended solids and bedded sediments (including the organic fraction) occur naturally in water bodies in natural or background amounts and are essential to the ecologi cal function of a water body. Howeve r, as documented in Section 2.2, SABS in excessive amounts constitute a majo r ecosystem stressor. Impairment of theAssessment of Water Quality Impairments Related to Forest Roads Page 97 Contract # EP-C-05-066, TO # 0002 December 4, 2008

movement of large wood in stream systems by road crossings is also poor ly reflected by water quality criteria. Use of ecologica lly-based water quality criteria to designated impaired waters has been stopped by industry groups on legal gro unds in several states: Oregon no longer lists streams under Section 303(d) on the basis of low instream flow or “habitat modification” because these are not “pollutants”.

In addition, traditional water quality monitoring ha s proven to be inadequate for detection of impairment caused by stormwater runoff (FDEP, 1997). Numerous studies have demonstrated that the biotic and chemical “noise” in larger st reams renders the water quality effects of forestry activities using BMPs undetectable (Jackson et al., 2004). Accura te suspended sediment load estimation in small, rain-dominated watershe ds like Caspar Creek depends upon frequent sampling when sediment transport is high. Sedi ment concentrations ar e highly variable and inconsistently or poorly correlated with water discharge. Errors of 50-100 percent are probably typical when sampling is base d on convenience (Lewis, 1998).

Major watershed-scale studies that have investigated the effectiv eness of forestry BMPs include the following:



### y Caspar Creek, California



### y Mica Creek, northern Idaho



### y Hinkle Creek, southwest Oregon



### y Alsea watershed, Oregon



### y Six Rivers National Forest, California



### y Alto watershed, east Texas



### y Fernow Experimental Forest, West Virginia



### y Coweeta Hydrologic Research Labo ratory, Appalachian Mountains

These watershed studies are briefly introduced be low. Since a number of the studies have been ongoing for as long as 50 years, there is no way to present or even summarize all of their findings. A number of books a nd research summaries have been published for the watershedscale projects (Ice and Ste dnick, 2004; Ziemer, 1998).Assessment of Water Quality Impairments Related to Forest Roads Page 98 Contract # EP-C-05-066, TO # 0002 December 4, 2008

The Caspar Creek Watershed Study is an importa nt ongoing project to assess BMP effectiveness being conducted by the CAL FIRE and the USFS P acific Southwest Research Station. This study provides research level data on how forest practice operations prior to and after the implementation of California’s 1973 Z’Berg Nejedly Forest Practice Act ( FPA ) have affected water quality (Cafferata and Sp ittler, 1998; Lewis, 1998; Lewi s et al., 2001; Ziemer, 1998; Ziemer, 2001). Streamflow and suspended sedime nt have been gauged continuously since 1962

at both the North and South Fork weirs of Ca spar Creek in northwest ern California since 1963, and at 13 tributary locations in the North Fork since 1986. The North Fork gauging station (NFC) was used as a control to evaluate the effects of logging in the South Fork on annual sediment loads in the 1970’s. In summer 1967, a main-haul logging road and main spurs were built in the South Fork. The road right-of-way occ upied 19 ha adjacent to the stream, from which

993 m3ha-1 of timber was removed. The first of th ree stages of logging be gan in the South Fork in 1971, during which 59% of the stand volume wa s selectively cut from 101 ha. In 1972, 69% of the stand volume was selectively cut and tr actor yarded from an additional 128 ha. In 1973, 65% of the stand volume was selectively cut fr om the remaining 176 ha (Rice et al., 1979). Aerial photos of the South Fork Caspar take n in 1975 portray 66 recently active landslides (Keppeler et al., 2003). Of these, a ll but 3 were associated with road s, landings or skid trails. Of

the 38 South Fork landslides documented betwee n 1994 and 2003, 89% are road, landing, or skid trail related. An ageing system of logging roads a nd skid trails continues to deliver sediment to

the stream channel. In the most conservative tr eatment of the data, susp ended loads increased by 212 percent over the tota l predicted for a 6-yr period comm encing with the onset of logging (Lewis, 1998). Sediment load increases were correlated with flow increases after logging. Field evidence suggested that the increased flows, accompanied by soil disruption and intense burning,

accelerated erosion of unbuffered stream banks and channel headward expansion.

When the roles of the watersheds were reversed and the same analysis repeated to evaluate harvesting in the North Fork under California Fore st Practice Rules in th e 1990’s, no significant increase was found at NFC in either annual susp ended or bed load. Logging began in the main study portion of the North Fork in 1989 and ended in 1991. The timber volume removed from the North Fork was intended to approximate the volume cut from the South Fork in the early 1970's, but clearcutting with cable yarding was used in the North Fork rather than the selectiveAssessment of Water Quality Impairments Related to Forest Roads Page 99 Contract # EP-C-05-066, TO # 0002 December 4, 2008

harvest with tractor yarding that had been used earlier in the S outh Fork. Upstream of the North Fork gauging station, 48% of the area was clearcut and 4% of the streamside protection zone was selectively cut. The size of clear cut blocks in the North Fork ra nged from 9 to 60 hectares (ha) and occupied 35% to 100% of individual tributar ies. New roads, landings, and skid trails occupy from 2.1% to 7.0% of individual logged watersheds. Three tributaries in the North Fork were left

in an untreated control conditi on. Post-logging measurements con tinue in the North Fork and South Fork watersheds to the present.

It is probable that the sampling methods in the 1960’s and 1970’s resulted in overestimation of sediment loads in the South Fork analysis by a factor of 2 or 3 (L ewis, 1998). Therefore, comparisons between relative incr eases are more appropriate. Ex cess suspended load was 212 to 331 % (depending on whether an adjustment is made for a North Fork landslide in 1974) after logging the South Fork, and 89 % af ter logging the North Fork, s uggesting that the effect of logging on suspended sediment load was 2.4 to 3.7 tim es greater in the South Fork than in the

North Fork. Flow increases accoun ted for only part of the variability in sediment production. Road systems would typically be expected to acc ount for much of the sediment. However, in this case, roads were relatively unimportant as a se diment source because of their generally stable locations on upper hills lopes far from the stream channels.

The effectiveness of Idaho’s fo rest practice rules is being te sted by Potlatch Corporation and cooperators at Mica Creek in northern Idaho. In 1990, Potlatch Corporation initiated research at the Mica Creek Experimental Watershed to eval uate the cumulative effects of contemporary timber harvest practices on water flow, quality, and aquatic ecosystem health. The study consists of paired and nested experimental watersheds at three scales. Forest treatments include a 50% clearcut watershed and a 50% partial cut wate rshed (50% canopy removal). Watersheds were monitored for a pre-treatment calib ration period of six years, a f our year post-road period, and a five year post harvest + road phase to separate the effects of road construction from harvest practices. Monitoring includes basic hydrometeo rological variables, streamflow, stream temperature, sediment, channel characteristics, aquatic macroinvertebrates, and fish. Results from Mica Creek are just beginning to be repo rted (Ice et al., 2004b). More recently, the MicaAssessment of Water Quality Impairments Related to Forest Roads Page 100 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Creek watershed has been transitioning into a wo rking forest, with roads installed in 2006 and harvesting beginning in 2007.

The Alsea Watershed Study in Oregon began in 1957 as a cooperative effort between Oregon State University and federal and state agencies to address the effects of timber harvesting on the stream environment (Moring and Lantz, 1975; Ri ngler and Hall, 1975). The Alsea study also examined the response of salmon, trout, and other fi sh species to forest pr actices, often the most basic factor when the public considers the eff ectiveness of forestry BMPs. Coho salmon biomass and net productivity increased af ter logging, but cutthroat trout populations declined (Ringler and Hall, 1975; Moring and Lantz, 1975). This is not unexpected, because cutthroat trout are a stream-resident species that re quires clean gravel for spaw ning. Coho salmon, on the other hand, are anadromous and can spawn in fine sedime nts. Although coho biomass and net productivity increased in the intensively clearcut watershed, some sub tle measures of coho salmon performance were negatively affected (reduced cond ition factor of fingerlings and fry in streams at the time of logging, and fec undity of these coho when they returned to spawn). Macroinvertebrates may increa se in abundance with some tim ber harvesting practices near streams, but the diversity may shift or light - and sediment-intolerant species may decline (Newbold et al., 1980). More recen t studies in the clearcut wa tershed (Needlebranch Creek) show that coho are relatively unaffected by ex treme harvesting practices, but cutthroat trout populations show persistent decr eases in older age classes (Gre gory et al., 2008). It has been hypothesized that the reason for th e cutthroat response is that habitat qual ity (pool depth and complexity) was reduced during the initi al harvest and ha s not recovered.

The forestry practices that took place during th e Alsea study, extensive clearcutting and lack of stream protection, are no longer permitted under Oregon’s FPA, in large part because of the

lessons learned in this waters hed study. Results of the Alsea st udy were used to develop BMPs for timber harvesting in the temperate coniferous forests.

Since 1990, the Oregon Department of Fish and W ildlife (ODFW) has been working with forest

landowners to collect information on stream habitat conditions as part of the Aquatic Inventory Project. This project has cr eated a database representing 4,000 stream reaches throughoutAssessment of Water Quality Impairments Related to Forest Roads Page 101 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Oregon. With resurveys of the stream reaches, it is possible to assess trends in stream habitat

conditions. The information has be en organized by Oregon State Univ ersity scientists into a GIS database with nearly 100 variables describing st ream and habitat attributes (Wing and Skaugset, 1998). One additional program of note is the He adwater Research Cooperative that is supporting research on mostly non-fish-bearing forest headwa ter streams to assess how they function and to determine what are appropriate management practices.

At the Fernow Experimental Fore st in West Virginia, turbidity in runoff was compared between a watershed treated with BMPs, an unrestricted harvest watershed where road construction was not managed to control water pollution, and an undisturbed control watershed (Reinhart and Eschner, 1962). While the BMP watershed showed an increase in the maximum turbidity measured from 15 JTUs (Jackson Turbidity Un its) for the control to 25 JTUs, the maximum turbidity measured for the runoff from the unr estricted harvest watershed was 56,000 JTUs (Ice, 2004).

Williams et al. (1999) evaluated BMP effectivene ss in the South Carolina Piedmont, which they considered the most sensitive physiographic prov ince in the state. The authors studied three harvest, site preparation, and regeneration alterna tives (with BMPs) for changes in flow, sediment, and nutrients, and compared results to a control watershed. They observed statisticallysignificant increases in observed parameters in all alternatives, but all waters met state waterquality standards. Further, they demonstrated th at forestry BMPs reduced sediment yield to onetenth of that occurring without BMPs (Prud’homme and Greis, 2002).

A number of watershed studies ha ve compared past and current measures of impacts from forest operations. A before/after wate rshed study in the Six Rivers National Forest in California (Knopp et al., 1987) documented a 85% reduction in landslides associated with roads over a 10 year period, while fine material in stream bottoms was reduc ed from 22 to 15%. Ice (2004) compared the results of watershed studies in the South Carolina Piedmont by Williams et al. (1999) and Hewlett (1979). BMPs reduced sediment yield increases tenfold compared to yields observed prior to BMPs.Assessment of Water Quality Impairments Related to Forest Roads Page 102 Contract # EP-C-05-066, TO # 0002 December 4, 2008

The majority of watershed scale studies reviewed for this report suggest that the use of BMPs at the site level to maintain water quality are eff ective at reducing cumulative effects with a basin, although more research is clearly needed. The pa ired watershed and before/after comparisons show that forest BMPs can reduce water qual ity impacts from 80 to >99% (Ice, 2004), although the continuing presence and use of unpaved ro ads typically precludes recovery to predisturbance levels (NCASI, 1994). Negative imp acts of forest practic es should be uncommon except in cases where: unstable areas and area s with highly erodible so ils, when management activities coincide with extreme storm events, and possibly for cumulativ e effects in downstream deposition areas (Binkley and MacDonald, 1994). Extreme storm events can have unavoidable effects on both managed and unmanaged landscapes a nd streams. At level of rare events, natural impacts and processes may overwhelm management decisions, and impacts may be obscured (Dissmeyer, 1994). Assessments of BMP effectiveness must wait for “testing storms” like the 1996 floods in Oregon and southern Maine, or the December 2007 flood in Washington.

The effectiveness of BMPs in the California co astal region may be an exception to the findings summarized above. According to Harris et al. (2 005), there are no quant itative data indicating that road BMPs have substantially improved instream water quality or salmonid habitat conditions in that region. These au thors report that it is not known how site-l evel effects translate into benefits to water quality and stream habitat at the stream reach or wate rshed scales. Little is known about the temporal scale at which improve ments may occur. Recent studies show that restoration of upper watershed locations or non- fish-bearing streams causes short-term impacts on local water quality due to post-construction adjustments (Klein, 2003).

3.3 What are the Costs of Installing and Maintaining These BMPs?

The costs of installing and maintaining BMPs is a major concern to the forestry industry, since

BMPs increase the cost of timber harvesti ng and reduce harvesting revenues. Some cost information for forest practice implementation is based on the average increased cost of conducting a harvest when management measures, i.e ., a suite of practices, are used versus when they are not used. The difficulty in separati ng the costs of implemen ting individual forest practices are emphasized when costs are provided in this way. This difficulty is due toAssessment of Water Quality Impairments Related to Forest Roads Page 103 Contract # EP-C-05-066, TO # 0002 December 4, 2008

incorporating the cost of using numerous BMPs into the accomplishment of a single harvesting

or road construction activit y, and spreading the cost for individual practices across the accomplishment of multiple activities. For example, the cost of adhering to a state regulation for stream crossings might be spread among the cost s of planning a harvest to minimize the number of stream crossings, designing and constructi ng forest roads to accommodate the plan and minimize instream effect to water quality and fi sh, and the actual construction of the stream crossings. Furthermore, these costs differ with ea ch harvest because the terrain, soils, location of

harvest site relative to stream s, and hydrology are different at each harvest site. Therefore, all costs presented here are best regarded as r ough estimates. The BMP cost estimates presented here have all been updated to 2008 dollars, using the Bureau of Labor Statistics Consumer Price Index. Much of the summary of BMP costs pres ented below was taken from the USEPA report, National Management Measures to Control Nonpoint Source Pollution from Forestry (USEPA, 2005).

Estimates of the per acre cost of implementing BM Ps for timber harvests were arrived at based on information obtained from published reports on regional studies of the cost of BMP implementation and cost estimates based on th e regulatory structure of forestry practice programs. Studies have been conducted on the cost of implementing forestry practices for water quality and soil protection in the Southeast and some western stat es (Aust et al., 1996; Dissmeyer and Foster, 1987; Dubois et al., 1991; Henly, 1992; Lickwar, 1989; Olsen et al., 1987). Table 3-3 presents costs asso ciated with complying with fore st practices in states where their implementation is either voluntary or regulated, with differing numbers and types of requirements depending on the state (Ellefson et al., 1995).

The costs of implementing state forest practi ces arise from various activities including conducting timber surveys, preparing management plans, constructing roads, and implementing practices specifically designed to protect water quality. Many of th ese costs are borne whether or

not a stream or other surface wate r is located on or near a harves t site, though additional costs (e.g., designing and flagging a Streamside Ma nagement Area (SMA), constructing stream crossings) are incurred where streams are present. Costs also take the form of lost revenue from trees that are not harvested to ensure complia nce with forest practices. Revenue might beAssessment of Water Quality Impairments Related to Forest Roads Page 104 Contract # EP-C-05-066, TO # 0002 December 4, 2008

reduced if merchantable trees are left standing in SMAs or when selective cutting is called for rather than clear-cutting. An example of this is presented in a comparison of BMP cost estimates made by the Texas Institute for Applied Enviro nmental Research (TIAER; Tanter, 2003). BMP cost estimates provided by Haney (1998) are much higher ($131 per acre) than cost estimates from other sources ($24 to $30 per acre); the difference was due to the greater value Haney attributed to timber in streamside management z ones, which is not a cost ordinarily associated with forest road BMPs. Although the loss of revenue is a real “cost” to landowners, it is very market- and species-dependent and is generally no t included in the cost estimates provided here. The overall costs of complying with regulatory forestry BMP pr ograms might be borne by forest landowners alone or shared among landowners, ti mber operators, and others. Of course, BMP costs in this context ignore the very r eal benefits of prot ecting water quality.

Factors that typically affect the cost of implementing forest practi ces include the type of terrain on which a harvest occurs (with costs for harvesting on steeper terrain typically being higher than costs for harvesting on flatte r terrain) and the regulatory stru cture of forest practice rules. Compliance in states that have numerous and st ringent forest practice regulatory requirements generally costs more than compliance in states where regulatory requirements are fewer or less stringent, or are voluntary. Some states have single regulations that can add significantly to the cost of forest harvesting. An ex ample is the requirement for a detailed forest harvest plan in California. This alone places compliance with fo rest practices in California in a category by

itself.

Table 3-3 summarizes estimations of the overall per-harvest cost of complying with forest practice regulations in different regions and states. Table 3-4 provides cost estimates for implementation of individual management measur es in the Southeast and Midwest. The costs

have been verified with state and federal forest management agencies and have been found to be representative of actual expend itures. Although most of the cost information came from case

studies in the southeastern Unite d States, they are representative of costs incurred nationwide. Costs vary depending on the site-specific natu re of the timber harvesting area. Table 3-5 provides estimates of costs for installing individu al road construction and erosion control BMPs. Costs are provided by region, demonstrating that the costs for installing BMPs can varyAssessment of Water Quality Impairments Related to Forest Roads Page 105 Contract # EP-C-05-066, TO # 0002 December 4, 2008

considerably in different parts of the country. Specific factors that affect implementation costs

are mentioned in the Comments column of the table.

Costs of installing BMPs are available from a variety of other sources (USEPA, 2005; Blinn et al., 1998; Gallagher et al., 2000; Kochenderfer and Helvey, 1987). Unfortunately, many of the available cost estimates are provided on differe nt bases (cost by area, road length, individual treatment or site feature) making it difficult to compare costs for different BMPs as well as estimating the total cost of BMPs for a part icular location and level of treatment. For implementation of standard BMPs, TIAER (2003) summarized four independent estimates of total costs that ranged from $24 to $131 per acre; for enhanced BMPs, total cost estimates range from $42 to $199 per acre. As previously note d, the BMP cost estimates provided by Haney (1998) were much higher than the other sources; this difference is due to the greater value Haney attributed to timber in streamside management zone s, which is not a cost associated with forest

road BMPs.

Road construction costs can vary widely on th e National scale, depe nding on both the road

standard and site conditions (NCASI, 2001). Road construction costs range from less than $12,800 per mile on gentle terrain remote from streams, to over $265,000 per mile on steep slopes where the design requires BM Ps that prevent landslides a nd delivery of sediment to streams (Scherer, 2000; Clark et al., 2000). The costs of temp orary roads cu rrently being constructed range from $9,450 to $14,800 per mile in gentle to mountaino us terrain (Coghlan and Sowa, 1998). Cost of constructing eight unsur faced minimum standard roads in central West Virginia averaged $15,700 per mile (Kochenderf er and Helvey, 1987). Surfacing these roads with a 4 inch depth of limestone gravel would add about $19,400 per mile, more than doubling

the road construction cost.

Where road BMPs are revised to better achieve wa ter quality standards, it should be kept in mind that certain more costly erosion control practices ar e specifically needed in the vicinity of stream crossings and for road segments th at drain to streams either direc tly via ditches or potentially via drainage relief discharges (Ras hin et al., 1999). Therefore, the a dditional costs of such practicesAssessment of Water Quality Impairments Related to Forest Roads Page 106 Contract # EP-C-05-066, TO # 0002 December 4, 2008

do not apply to the entire length of constructed roads, and such costs can be minimized through

careful road location and drainage design.

Costs for road removal are prov ided in Switalski et al. ( 2004). Most common forms include roadbed “ripping” ($745-$2,264/mile), restori ng stream crossings ($582-$175,000), and fully recontouring hillslopes ($5,660-$377,300/mile). The wi de variation in the estimates for these costs is related to the complexity and variab ility of stream crossing restoration and full recontour. These factors make it easier to compar e project costs on a per-cubic meter basis. The cost of excavating in Redwood National Park wa s reported to range from $1 to $3.50 per cubic meter (Bagley, 1998).

No costs estimates were found specifically for BMP maintenance. Broadly, appropriated annual

maintenance for forest roads in the Nati onal Forests ranges from $405 to $810/mile for maintenance level 3-5 roads, $81 to $135/mile for maintenance level 2 roads, and $27 to $54/mile for maintenance level 1 roads (Coghl an and Sowa, 1998). For comparison, a survey conducted by the Illinois Institute for Rural A ffairs in 1994 identified average annual costs of maintaining a mile of gravel or loose aggreg ate road at $11,853 for all counties, and $2,961 for all townships. Comparison of these expenditures indicates that roads in the National Forests

receive much less maintenance than other roads.

3.4 What are the Recent Promising I nnovations in Forest Road BMPs?

The forest road research literature points to stre am crossings, including feat ures such as bridges, fords, and culverts as causing the most si gnificant sediment problems. Recent innovative technologies include portable bri dges, mats, pipe bundles, and altered logging equipment (wider tires, low tire pressure, dual tires). Portable br idges have been gaining popularity because they

can be installed with minimal site disturban ce and water quality impacts, when compared to other types of crossings (Taylor et al., 1999). Studies have shown that these portable bridges are a cost effective way to reduce the environmental impacts of stream crossings. The Forest Service supports the use of portable bridges to temporaril y cross streams. Several states have programsAssessment of Water Quality Impairments Related to Forest Roads Page 107 Contract # EP-C-05-066, TO # 0002 December 4, 2008

that loan these portable bridges to loggers such as the North Carolina Fo rest Service’s Bridgemat Loan and Education Program, funded pa rtially through USEPA’s 319(h) grants.

An emerging focus of the post-flood studies in the Pacific Northwest is the importance of designing roads to accomm odate disturbances, particularly in the area of road-stream crossings, which are implicated in most documented road failures (Gucinski et al., 2001). Road re-design that anticipates and accommodate s movement of water, sediment , and debris during infrequent but major storms should substantially reduce road failures and minimize er osional consequences

when failures occur.

Other innovations involve the development of methods to optimize BMPs. One example is customized cross drain placement based upon sedi ment flow analysis, which can reduce both sediment production and road construction cost in comparison to the prescriptive approach to cross drain placement. CulSed is a computer decision support tool developed by the Rural Technology Initiative for cross drain culvert desi gn, that enables users w ith little technical training to find near optimal cross drain locations (Damian, 2003). CulSed is simple to use but requires accurate road geometry, stream and di gital terrain data for a successful analysis.

Optimization strategies are also being applied fo r sediment reduction practices on roads in steep forested terrain (Madej et al., 2006). Applied optimization methods can be used to determine the most efficient way of minimizing sediment input to streams through road decommissioning. Roads can be decommissioned through a variety of techniques, each of which has its own cost and sediment savings. The optimization tool can formulate the most cost-efficient strategy for restoration across a watershed. Optimized restorati on strategies have been shown to save more sediment under constrained budgets than the currently used approaches.

Some innovative BMPs might be effective, but the technology has not yet been developed to apply them (Ice, 2004). For example, a BMP for landslide-prone forest lands might be very effective if slope positions where the factor of safety for slope failure approaches 1.0 (i.e., no safety factor) during extreme pr ecipitation and runoff events coul d be accurately defined. While general guidelines can be provided for these high risk sites, the technology to accurately mapAssessment of Water Quality Impairments Related to Forest Roads Page 108 Contract # EP-C-05-066, TO # 0002 December 4, 2008

variations in soil depths and s ubsurface water transmissivity, as well as the spatial resolution needed for accurate prediction of critical slope angles, is not yet available (Robinson et al., 1999).

Another area of innovation related to forest road BMPs is the evolution of management systems, which address the question of how to tailor BMPs in watersheds to prevent cumulative impacts. One means of building on the reference stream approach is to couple stream indices with measures that index road system inputs (in this example, sediment) to the stream (NCASI, 2001). Such systems are being implemented by various states and companies. In these systems,

instream measures of stream hea lth (physical and/or biological) a nd evaluations of road sediment input are coupled in a management system that es tablishes levels or indi ces of sediment input

that in turn indicate whether th e input is acceptable or not. This is actually an evolution of implementation and effectiveness monitoring, in wh ich the two resulting measures are compared

and assessed to determin e how much additional control is ne cessary. The target sediment input

level must be decreased until the stream cond ition, as indicated by indices such as percent surface fines, channel stability, channel geomorphi c type, or similar measures, is judged to be acceptable. The advantage of the target/index appr oach is that it is both adaptive and objective, providing feedback to the manager about the suc cess of the BMPs in mitigating impairments. There are disadvantages as well. The approach essentially relies upon tria l-and-error to obtain the desired water quality outcome a nd is highly reliant on the quali ty of the data for sediment input and instream measures; other scientific methods incorporating forecasting or modeling may be more efficient. The target/index approa ch can also delay remediation and recovery, because management action (e.g., improving BMP implementation or upgrading BMPs) to reduce sediment inputs will not necessarily occur fa ster than the response time of the water body to the sedimentation stressor. Finally, the approa ch assumes that the relationship between cause (sediment inputs) and effect (s tream condition indices) can be di scerned. This depends on factors

such as natural variabil ity and the magnitude of road-related sediment loading relative to other sources, which have already been discussed.

The promise of such management systems is that by understanding erosion and sedimentation processes as they apply to the specific circumstances of a wate rshed, as established by watershedAssessment of Water Quality Impairments Related to Forest Roads Page 109 Contract # EP-C-05-066, TO # 0002 December 4, 2008

assessment and road inventory procedures, manage rs can effectively reduce and control impacts to levels established as acceptable by current standards. Uncertainty exists regarding these standards and the targets and indices that reflect them, and future research will be needed to refine them through time (NCASI, 2001).

3.5 Why do Forest Road BMPs Fail to Protect Water Quality?

In general, the literature on forest road BMP e ffectiveness fails to addr ess a seeming paradox: if

BMPs are available to address erosion and sedi mentation problems at most sites and rates of implementation are high, then why are there still water quality impairments from forest roads? Based upon state data for BMP implementation a nd effectiveness (Sections 4.2 and 4.3), BMPs appear to be highly effective: the BMP implemen tation rate is nearly 90% nationwide (Ice and Stuart, 2001). However, BMPs are apparently not effective enough to prevent documented impairments of sensitive aquatic resources. In discu ssing the results of an audit of forest practice rules for Idaho, Zaroban et al. ( 1997) reported, “On an individual ru le basis, we found that when properly implemented and maintain ed, the practices described in the forest practice rules were effective 99% of the time”, but also stated, “We also found that half of the timber sales we audited had sediment being delivered to streams or stream channels as a result of forest practice activity”. Forest roads are commonly cited as pr oblematic by western states. According to the 2002 USEPA National Assessment Database, Calif ornia and Montana reported 9,713 forest road-related impaired miles of streams. Furthermore, Califor nia accounts for approximately 93% of all forest road related impaired miles of streams reported in the NAD (Beebe and Ice, 2007). Montana also reported forest road related im pairments to waterbodies, but this number is considerably lower (439-mi, 707- km or 4%). These states demonstrate the same paradox regarding the effectiveness of BMPs, because bo th California and Montana report high rates of BMP implementation and compliance with state FPA s. In the most recent surveys, rates of compliance with forest road requirements in California and Montana averaged 95.8% and 89%, respectively.

In this regard, it should be ac knowledged that the majority of studies documenting water quality impairments from forest roads were conducted prior to 2000. As previously mentioned, BMPAssessment of Water Quality Impairments Related to Forest Roads Page 110 Contract # EP-C-05-066, TO # 0002 December 4, 2008

programs for forestry in many states are dynamic. The extent to which conditions have changed

since then is difficult to evalua te, but is an important source of uncertainty th at should be

addressed.

Based upon the information available for this report , there appear to be a number of reasons why BMPs fail to protect the water qua lity and other beneficial uses of aquatic resources. Most of these have already been discussed, and will only be summarized here.

3.5.1 Lack of Effective Implementation

In general, water quality problems may be due more to the failure to implement BMPs appropriately (Pardo, 1980; Whitman, 1989) than the ineffectiveness of the BMPs themselves (TetraTech, 1999). Rates of implementation for fo restry BMPs are almost always less than 100%. This is especially true for road and cr ossing BMPs; state data consistently show the implementation rates for road and crossing BMPs to be among the lowest among all forest practice categories. Furthermore, just because BM Ps have been implemented does not mean they are effective. Monitoring implementation can be straightforward, but BMP effectiveness is difficult to judge especially unde r dry weather conditions. Effective monitoring to detect sources of erosion, sediment delivery and obstacles to fish passage is a large and labor-intensive process, so may not be emphasized in many manageme nt systems. If problems are found and not corrected, they will continue and possibly grow worse.

3.5.2 Erosion Rates and Mass Failures can Exceed Capacity of BMPs to Prevent Generation, Transport and/or Delivery of Sediment to Water Bodies

BMPs, like any pollution contro l method, are effective up to a limit beyond which treatment effectiveness declines and may ultimately fail. In the case of BMPs for forest roads, the limits are related to the level of disturbance created by the road, the untreated ra tes of erosion, drainage connection and proximity to the surface water, and other regional and site-specific factors: unstable and/or highly erodible s ites/locations, “Problem” roads, and excessive harvest rates and associated high road use. Erosion and sedimentation control may be ineffective because the BMPs in place are inadequate to control the runoff, erosion from the various components of theAssessment of Water Quality Impairments Related to Forest Roads Page 111 Contract # EP-C-05-066, TO # 0002 December 4, 2008

road prism, stability of cut and fillslopes, dow nslope sediment travel, plugging and washout of culverts, etc. In many cases, control of these pr oblems is technically feasible if the BMPs are upgraded to a higher level of pr otection and performance or ar e enhanced by adding additional BMPs. In some cases, however, control of the pr oblem may not be feasible: location “trumps” management practice. Downstream deposition areas involving cumulative effects are particularly vulnerable to the negative impacts of forest pract ices. Rare events are a special case (discussed below).

3.5.3 Legacy Roads and Crossings: Lack of Maintena nce, Failure to Upgrade and/or Remove

How to address and remedy the legacy of past road-building, use and cr ossings is a serious problem. Old roads built with practices preval ent in the 1950’s, 1960’s, and early to mid-1970’s are still significant sources of erosion (Caffe rata and Spittler, 1998). Perched fill and poor watercourse crossings associated with old roads are often referred to as “loaded guns” waiting to fail with strong stressing storm events. It is im perative that forest managers develop long-term road management plans that inventory these so urce areas and quickly reduce their numbers with an organized schedule based on watershed sensitiv ity and vulnerability of downstream beneficial uses. In general, roads built under older standards are “grandfathered”, or not required to be brought up to current design standards until either a segment needs to be reconstructed or the road shows immediate signs of failure that woul d damage waters of the state (Scurlock, 2007). Given that “old” roads and crossings make up most of the road network in many forested watersheds, it may take decades for the sediment delivery associated with these practices to be addressed. Lack of sufficient money for mainte nance makes this problem worse. Large-scale road removal/obliteration is prohibitively expensive, so only the worst “problem” roads can be

addressed.

3.5.4 Cumulative Impacts

Chronic erosion from many indi vidual sites may impair a water body, even though relatively

little sediment is delivered from each site. Fine grained sediment (usually the most significant pollutant from roads) is source limited, so once delivered to the water body it can be transportedAssessment of Water Quality Impairments Related to Forest Roads Page 112 Contract # EP-C-05-066, TO # 0002 December 4, 2008

relatively far downstream to a deposition location. It is possible for many sites to deliver sediment to such a location. Cumulative impact s tend to be greater downstream of larger watersheds; watersheds with more forestry activ ity, higher road density and/or problem roads, crossings, etc.; watersheds with older road networks and a greater percentage of legacy roads;

and watersheds where the rates of chronic sedime nt delivery and/or ma ss wasting are higher due to regional and site-specific factors.

3.5.5 Highly Sensitive Aquatic Resources

In several regions of the country forest streams and rivers downstream from forested watersheds, serve as habitat for aquatic species that are often highly sensitive to adverse effects of sedimentation. Endangered anadromous salmonids have very specific habitat requirements, which have become spatially limited in the Pacifi c Northwest due to anth ropogenic activities not

limited to silviculture. These include dam construc tion, fishing pressure, e xotic species, resource extraction, increased water temperature resulting from climate change (see Poff et al., 2002), and loss of riparian vegetation. Subs trate requirements for reproduc tion and other life stages are highly sensitive to sediment.

3.5.6 Rare events

Extreme storm events can have unavoidable e ffects on both managed an d unmanaged forests, watersheds and streams (Binkley and MacDona ld, 1994). The likelihood of failure of BMPs increases with the magnitude of rare events (Fur niss et al., 1991). For exam ple, a culvert sized to accommodate flow from a 50-year flood has a 33 % chance of failure during it’s 20 year design

life. In watersheds where culverts and other st ream crossings are sized for a 5 or 10 year flood, essentially all the crossings may be subject to catastrophic “d ambreak” failure in a 50 or 100 year storm. The likelihood of mass failures on roaded steep, unsta ble slopes likewise increase with the magnitude of rare events, although the pr obabilities of failure are less well understood. Robinson et al. (1999) indicated that Oregon’s FPRs are likely reducing the size of roadassociated landslides as well as the number.Assessment of Water Quality Impairments Related to Forest Roads Page 113 Contract # EP-C-05-066, TO # 0002 December 4, 2008

3.6 How Can Failing BMPs be Improved?

There are many possible ways to improve failing BMPs, depending on the specific circumstances. The descriptions of BMPs for fo rest roads (Table 3-1) include recommendations to address failing BMPs, including recons truction and upgrading (Section 3.1.3.2). Adding components to BMP systems can help address BM P failure by increasing the overall treatment efficiency. Improving inspection and maintenance practices may also improve failing BMPs by anticipating and preventing failu res. BMPs must be designed to anticipate and accommodate events (proactive) in order to be effective. For stream encroachment and culvert problems, removal of the road and offending culverts is e ffective (Luce et al., 2001 ). Regulatory and other management responses to BMP failu re are addressed in Section 4.

In many cases, identifying the location of failure s may be the greatest challenge. Although road inventories are usually based on dry weather observations, it woul d be much more effective to conduct them during wet weather. Qualitative walk -in-the rain monitoring may help identify key problem areas. In fact, public reporting of stream sedimentati on, such as local observation of highly-turbid streams (Corner, 1992; Juul et al., 1990), is curren tly one of the most important means of learning of problems or poten tial violations (Irland and Connors, 1994).

One of the most important components of a comprehensive road management plan is the determination of which high-risk roads s hould be properly abandone d. Under the current California Forest Practice Rules, this means leaving a logging ro ad in a condition that provides for long-term functioning of erosio n controls with little or no continuing maintenance. Proper road abandonment usually involves removing wate rcourse crossing fills, removing unstable road and landing fills, and providing for erosion re sistant drainage (Weaver and Hagans, 1996).Assessment of Water Quality Impairments Related to Forest Roads Page 114 Contract # EP-C-05-066, TO # 0002 December 4, 2008

4. STATE FOREST ROAD BMP PROGRAMS

Nearly all BMP programs part of state forest practices, including state Forest Practices Acts, were initially developed in res ponse to the requirements of Sec tion 208 of the CWA. Each state’s BMP program shares the basic objective of m eeting the state’s water quality standards and maintaining the beneficial uses. State forest prac tice rules and BMPs are generally considered to be minimum standards needed to protect pub lic resources (NCASI, 2001). State BMPs are generally prescriptive (as opposed to procedural BMPs used in the NFS) because it is easier to assess BMP implementation than to measure complia nce with water quality standards (Ice et al., 1997). Three considerations make the prescriptiv e approach to BMPs appropriate (Rice, 1992): (1) because most forestry-related pollutants are natural substances, their origin may be difficult to determine, (2) the practice that results in pollution may be difficult or impossible to correct once the pollution has occurred, and (3) the level of pollution is the result of the interaction of a practice and the subsequent weather.

When the 1972 legislation was enacted, only Oreg on had passed a FPA that directly addressed water quality concerns. In 1974, the USEPA proposed that states adopt nonpoint source pollution control programs for forestry ac tivities that were modeled after the FPAs of the Pacific Coast states (Rey, 1980). By 1982 most states had developed some type of N PS control program for silviculture. All states with significant timberlan ds now have NPS control programs, and several

continue to evolve more refined BMPs and implementation elements. Measuring the success of BMP programs requires regular and credible su rveying of BMP implementation (Prud’homme and Greis, 2002). Repeated assessments have sh own that compliance with state BMPs and FPRs prevents major water quality impacts under most circumstances (Ethri dge and Heffernan, 2000). There is some controversy about this conclusion , as will be discussed in Sections 4.3 and 4.5. State BMPs can also be inefficient (NCASI, 2001), because they are designed to protect resources under the general circumstances encoun tered in the area regulated. The result is that state BMPs over-protect in some cases (wasting resources that could be applied to higher priorities) and under-protect in others (allowing undesired impacts).Assessment of Water Quality Impairments Related to Forest Roads Page 115 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Although there are many similarities in FPRs and BMPs, there are also substantial differences between the state forest practice management sy stems designed to implement these rules. Some states have customized BMPs to regions within the state. States with diverse geographies and complex terrain, such as Washington, Oregon, and Idaho, have promoted various forms of

watershed assessment to tailor BMPs more closel y to the watershed and site conditions (NCASI, 2001). The Scientific Review Panel on Californi a Forest Practice Rules and Salmonid Habitat also recommended a watershed analysis approach capable of assessing cumulative effects attributable to timber harvesting (Ligon et al., 1999). In some cases, management systems evolve around a specific issue or certain species of concern.

4.1 What are the State Programs that Address Forest Roads?

As of November 1999, thirty-six states have fo rest land management laws regulating all aspects of forest and timber resources and products derive d from these resources (D efenders of Wildlife, 2000). Alabama, Alaska, California, Idaho, Minnesota, and New Jersey have the most laws, with

five or more statutes on the books , whereas all other states have four or fewer laws. There are currently at least 105 state forest management la ws which can be categor ized into nine basic types of regulatory legislation: forest management laws, polic y and purpose laws, powers and duties laws or administrative legislation, land acquisition laws, private landowner laws regulating privately owned forest areas, educational and forest research laws, timber laws regulating the cutting, harvesting and conservation of timber on st ate lands, prescribed burning and fire prevention laws, and di sease and insect control laws. In many states there can be a complex legal framework of forestry regulations, and this framework varies considerably from

one state to another.

For this report, the most releva nt category of forestry laws is the forest management category. There are at least twenty of these types of laws dealing specifi cally with the need to manage state forest lands according to “multiple use” or sustai nability principles (D efenders of Wildlife, 2000). There are relatively new sc ientific management methods designed to yield the most economic, recreational and social benefits from forest resources for generations of people.Assessment of Water Quality Impairments Related to Forest Roads Page 116 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Benefits from forest resources include soil and water quality, incr eased and diverse use of timber resources, and conservation of wildlife habitats.

The primary regulations applicable to the imp acts of roads on freshwater ecosystems are the individual states’ forest practi ces policies, which generally esta blish standards for the design of

forest roads and also serve as the BMPs called for under Section 208 of the CWA. These programs vary in their substantiv e level of protection, their specificity and their enforceability. The programs generally fall into four categories: regulatory, nonregulator y without enforcement, nonregulatory with enforcement, and combin ation programs. Though BMP implementation is not mandatory under the CWA, states have the option of developing and implementing regulatory approaches for that purpose. Regulatory programs exist mostly in western and

northeastern states such as California and Massachusetts or mountainous states with large timber industries such as Kentucky and North Carolina. BMPs are mandatory under regulatory forest practice programs. Nonregulatory BMP program w ithout enforcement include states without a large timber industry or steep terrain such as Il linois, Oklahoma and Uta h. Eighteen states have nonregulatory programs with enforcement, where use of BMPs are not mandatory but

enforcement action can be taken against polluters or landowners who refuse to implement proper BMPs (e.g., Montana, Arkansas, and Michigan). Eight states have combination programs that mix aspects of regulatory and nonregulatory programs; Georgia is an ex ample of a state having a mixed regulatory/nonregulatory program.

Regional trends in forestry BMP program s are also evident (NCASI, 2007). BMP implementation is largely voluntary in southern states (Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, Oklahoma, Sout h Carolina, Tennessee, Texas, and Virginia), but three states (Florida, No rth Carolina, and Virginia) have linked BMP implementation to other state regulatory pr ograms, making them quasi-regulatory in some circumstances, and BMP implementation became mandatory in Kentucky in July 2000.

While forestry BMPs have become the founda tion of NPS water prot ection programs in the south, forest management programs in the west are overwhelmingly regulatory. Furthermore, most states in the western region have devel oped extensive guidelines for implementation ofAssessment of Water Quality Impairments Related to Forest Roads Page 117 Contract # EP-C-05-066, TO # 0002 December 4, 2008

forest practices rules (FPRs) related to water qu ality as well as protoc ols to monitor compliance and effectiveness. These regulatory programs fall under either a FPA (Alaska, California, Idaho, New Mexico, Nevada, Oregon, Wa shington) or a streamside management act (Montana). Conversely, the states of Arizona, Colorado, Utah , and Wyoming do not have established forest practices acts. Even though Utah relies on vol untary BMP implementation, the Utah Forest Practice Act of 2001 requires registra tion of forest operators and no tification of intent to conduct forest practices.

In the northeastern states (M aine, Maryland, Massachusetts, Ne w Hampshire, New Jersey, New York, Ohio, Pennsylvania, Vermont , and West Virginia) all states have developed forestry BMP recommendations. However, in general, many states have not put strong, consistent efforts into monitoring programs (except Maine and West Vi rginia). While the use of BMPs may be voluntary for some of the northeast states, ther e still exist legal requirements for forest management. Because of these various requirements, characterizing the use of forestry BMPs in this region as voluntary or require d under law is difficult. In the northeast there is a strong focus by states and the forest products industry on edu cation and training, strong ‘regulatory’ or legal programs, and, when compared to other regions (i .e., south and west) cons iderably lower levels of harvesting.

In the Midwest, only Minnesota has enacted a FPA. All states in this region (Illinois, Indiana, Iowa, Michigan, Minnesota, Missouri, North Dakota, South Dakota, and Wisconsin) have developed recommendations for implementing ma jor BMP elements which generally cover the areas of timber harvesting, ripa rian forest management, stream crossings, and forest roads.

Summaries of the state programs for forest road management are provided in Tables 4-1 and 4-2.

The 35 states in which BMPs for forest roads are voluntary are presente d in Table 4-1, while Table 4-2 summarizes the programs in the 15 st ates in which BMPs for forest roads are mandatory. These tables are updated and expanded from ones reported by TetraTech 9 (2004).

9 TetraTech noted a number of limitations associated with the tables upon which Tables 4-1 and 4-2 were based. The tabulated information did not necessarily constitute a complete picture of all of the regulatory mechanisms available for protecting water quality from the impacts of forest roads. The tables presented only readily available informationAssessment of Water Quality Impairments Related to Forest Roads Page 118 Contract # EP-C-05-066, TO # 0002 December 4, 2008

The tables identify which of ten BMP categories are addressed in each state’s forest practice rules, and whether the state engages in training and technical assistance, implementation/effectiveness monitoring, and/or compliance and enforcement activities in conjunction with the BMP programs. Implementati on/effectiveness monitoring in each state is

covered in Section 4.3. The most recent revision da te of each state’s BMPs is identified (dates ranging from 1993 to 2003 were found), and other relevant state BMP information (e.g., the statutory or administrative rule citation for the forest roads program and the state agency(s) administering the forest roads program) is incl uded in the tables. Compliance and enforcement mechanisms are identified, which normally o ccur through referral to state environmental protection agency and water pollu tion control laws. The tables include information on formal agreements between state agencies for handli ng suspected incidents of water pollution from forestry operations.

Based on Tables 4-1 and 4-2, 44 states had some form of BMPs which addressed road construction; 40 had BMPs for crossings and road maintenance; 24 had BMPs for road closure; and 23 states provided training and technical assistance as part of their forest roads program. Many states do not address some of the most cr itical aspects of reducing water quality impacts

from roads. A review of state BMPs found that 40% of state BMPs do not address maintenance of roads, 80% do not address use of roads in we t weather, and 72% do not address road closure (TetraTech, 2004). There are some discrepancie s between different sources of information regarding state forest practices, and some BMP categories may be under-represented due to limited data. Table 4-3 provides a more detailed revi ew of forest practices in five western states and selected Habitat Conservation Plan (HCP ) provisions for roads (Scurlock, 2007). Only Washington addresses “orphan” roads and has a timeline to br ing old roads up to current standards. Not all of the states use 100-year storms for crossi ng design, or allow passage of fish, bedload and debris. There are only limited applications of tools such as watershed analysis or cumulative watershed effects (CWE) evaluations.

regarding the extent of state BMP programs. Some of the information was obtained from state forestry Web sites which provide an overview of each state’ s activities, but the full extent of thei r efforts might not be presented.Assessment of Water Quality Impairments Related to Forest Roads Page 119 Contract # EP-C-05-066, TO # 0002 December 4, 2008

In the documents reviewed for this report, we found no examples of states where water quality agency review, concurrence, or approval of BM Ps was required. We also found little information

about the existence of st ate program for addressing water qualit y problems related to forest roads including legacy issues. In many states, roads bu ilt under older standards are “grandfathered”, or not required to be brought up to current design standa rds until either a segment needs to be

reconstructed or the road shows immediate signs of failure that would dama ge waters of the state (Scurlock, 2007). In his commentary on the Northw est Forest Plan, Scurlock (2007) points to other weaknesses in roads policy on non-federal lands. Common limitations on the effectiveness of state forest practices ru les to address road-related issues include the following:



### y Although new roads are uniformly discouraged, and are subject to improved design and standards, they are not prohibited, even on steep, unstable or otherwise sensitive sites.



### y There is limited enforcement and enforceability of rules/guidance relevant to direct road discharges to channels, cross-drain spaci ng, road surfacing, tire pressure, wet season operation, revegetation of exposed surfaces and roadside vegetation remediation.



### y Decommissioning is deemphasized.



### y Most rules have no requirement that roads be brought up to standards on any set timeline, and improvements are conducted according to operations convenience (except Washington).



### y Lack of general performance standards for road design, rehabilitation and maintenance limits effectiveness of implementation (as on federal lands).



### y FPRs do not recognize ecological importance of maintaining low road density where it exists, and reducing road dens ity in high density watersheds is not a rational resource prioritization.

When problem areas in state BMP programs ar e identified, the overwhelming response by the various regulatory agencies is to strengthen education and traini ng programs in the specific area identified (NCASI, 2007). Many state agencies have developed programs in cooperation with university extension programs to improve educ ation and training of l oggers. States in the northeast region rely heavily on BMP implementation as well as logger education and training programs to control NPS pollution during fo rest management. Increasing education opportunities, particularly for loggers and non-in dustrial private forest landowners, shouldAssessment of Water Quality Impairments Related to Forest Roads Page 120 Contract # EP-C-05-066, TO # 0002 December 4, 2008

increase rates of BMP implementation and comp liance across the southeast and other regions. Implementation of effective BMPs, once designe d, requires continuous education of an everchanging population of forestry practitioners and landowners (Prud’ homme and Greis, 2002).

The voluntary nature of the majority of st ate BMP programs preclud es establishing permit conditions. Lacking this mechanis m, states have employed logge r, forester, forest practice purveyor, and landowner education as the prim ary tool to achieve BMP implementation. Training has traditionally been conducted in co operation with forest industries, forestry associations, and state agencies.

States that report high rates of BMP implementation often at tribute this to outreach and education programs (NCASI, 2007). On industr ial forestlands, the high rates of BMP implementation can also be attributed to i ndustrial involvement in sustainable forestry certification programs. The Sustainable Forestry Initiative (SFI) of the American Forest and Paper Association requires that member comp anies adhere to BMPs on company land. Member companies of the American Forest and Paper As sociation are required by the SFI guidelines to meet or exceed State BMPs on company-owned fo rest land (Prud’homme and Greis, 2002). In addition, some forest products companies im pose sanctions on timber producers who fail to implement BMPs when logging on other ownerships. Forestry operations that utilize experienced and informed land managers generally have high rates of BMP implementation. Thus, many

states recommend that landowners utilize forest ry professionals (e.g., private consultants, certified Master Loggers) when planning any fo rest management operations. Kentucky requires that a certified forestry professional be on- site for the entire harvest operation.

Educating an ever-changing population of small fo rest landowners is a continual challenge for state BMP programs. A survey of state forest ers found that landowner knowledge of BMPs and landowner attitude towards complying with BMPs was a top barrier to BMP implementation and

effectiveness. These same state foresters noted th at the top two keys to future progress of the BMP program are landowner and logger awarene ss and providing pre-harvest assistance while the top funding priorities in their respective programs are e ducation, training, and monitoring.Assessment of Water Quality Impairments Related to Forest Roads Page 121 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Compliance and enforcement of BMP programs vary among states, along with whether the state water quality agency is involved. Florida, for ex ample, relies on primar ily voluntary compliance with state approved forestry BMPs. However, BM Ps can be enforced when implementation is found to be deficient. When incidence of noncomp liance is found at the pr actice level, a further

evaluation is made to determine if a significant risk to water qu ality existed (NCASI, 2007). The Florida DOF defines significant risk as, "a situation or set of conditions where non-compliance with BMPs has resulted, or may result, in the measurable and significant degradation of physical, chemical, or biological integrity of water quality, to the extent that it presents an imminent and substantial danger to the designate d beneficial use.” When a signi ficant risk has been identified,

the BMP Forester advises the landowner on how to implement corrective measures. Afterward, a follow-up site evaluation is made to rea ssess compliance. Landowner non-compliance with recommendations made by the BMP Forester wi ll result in a referral to the appropriate regulatory agency for enforcement action. Unde r the State’s water quality laws, the Florida Department of Environmental Protection can enforce BMPs while the Florida Water Management Districts regulate forest roads, stre am crossings, and several other forestry related

activities.

The Kentucky DOF has a four-step enforcement pr ocess and is empowered to issue fines and designate noncooperators as ‘bad actors’. Where noncompliance with BMPs is observed, a written warning is issued desc ribing which requirement is not in compliance. Upon receiving a written warning an operator has an opportunity to meet with the district forester and the inspector to discuss how to reme dy the infraction. This technical as sistance meeting is referred to as an informal conference. A logger failing to effectively address an infraction (i.e., written warning) can receive a notice of violation. In some instances non-compliance can result in a special order being issued that allows the DOF to shut down a portion of the operation until compliance is achieved. Where viol ations pose significant threats to water quality, an emergency order can be issued which will shut down the entire operation. The DOF can initiate administrative hearings, levy fines, or bring court actions for all violations deemed to have impacts or potential im pacts on water quality.Assessment of Water Quality Impairments Related to Forest Roads Page 122 Contract # EP-C-05-066, TO # 0002 December 4, 2008

The Alaska DOF, with input from the Depart ment of Environmental Conservation (DEC), instructs the forest landowner, timber owner, operator, or forest manager to, “...conduct routine or comprehensive water quality monitoring fo r the purpose of assess ing the impacts of operations on water quality and protected water uses, and for the purpose of demonstrating the effectiveness of best management practices in meeting water quality standards”. Routine monitoring includes, at a minimum, visual inspection of streams to assess turbidity levels and can also include temperature measurements duri ng harvesting operations. If routine monitoring is deemed necessary by DOF during harvesting op erations, the guidelines are as follows: (1) make water quality observations at one or more locations at regular intervals; (2) use simple, qualitative assessment techniques; and (3) report data findings a nd any measures implemented to correct water quality problems to DOF and DEC.

Publicly owned forests are managed in ways that differ in some ways from forests under private ownership. On a national scale, 29 percent of timberla nd is publicly owned (Smith et al., 2001). In the Rocky Mountains and Pacific Coast region s, the majority of timberland is in National forests (USEPA, 2005). States with greater than 60% of their forests in public land include Arizona, California, Oregon, New Mexico and Washington; Idaho, Utah and Wyoming each have more than 80% of their forests in public la nd. Federally managed fore sts must meet state requirements, but also requirements of the USFS (Rice, 1992). The USFS manages more than 193 million acres in the NFS. Although most forest ed watersheds are in satisfactory condition,

some waterbodies on NFS lands do not meet stat e water quality standards. Year 2005 data show that over 4,300 water quality impairments (i n 2,600 waterbodies on NFS lands) are included on the Section 303(d) lists in 41 st ates, representing about 8 % of all water quality impairments nationally. Leading causes of the impairments on NFS lands include elevated temperature, excess sediment, and habitat modification.

Significant policy-level progress ha s been made to recognize the ecological impacts of roads on federally managed lands over the last decade. Poli cy changes can generally be linked directly to Endangered Species Act (ESA) listings for sa lmon, trout and other native fish, and CWA compliance concerns. Under the ESA, guidance has been developed in asso ciation with federal

lands consultation with the National Marine Fi sheries Service (NMFS) and the US Fish andAssessment of Water Quality Impairments Related to Forest Roads Page 123 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Wildlife Service. For example, current NMFS guida nce recognizes a series of indicators that relate directly to the impacts of roads on salmonids (road density and location, substrate character and embeddedness, physic al barriers, and suspended se diment/intergravel dissolved oxygen/turbidity). In many National Forests, waters hed restoration is synonymous with removal of excess roads (Elliot, 2000).

On September 28, 2007 the USFS and the USEPA signed a Memorandum of Agreement (MOA) on “Fostering Collaboration and Efficiencies to Address Water Quality Impairments on National Forest System Lands”. The purpose of the M OA is to establish gr eater coordination and

collaboration between the USFS a nd the USEPA’s Office of Water to foster efficient strategies to address water quality impairments by mainta ining and restoring NFS watersheds. The USFS has already coordinated and colla borated with states and USEPA on many activities to maintain and restore water quality in the National Forest System. For example, the USFS has supported states and USEPA in development of more than 300 TMDLs in more than 30 National Forests. For several National Forests, the USFS has also assisted states’ e fforts to develop a record that supports placement of waters in Category 4b.

In addition to these activities, the USFS uses a variety of watershed management techniques to address water resource impairments. The U SFS Watershed Management Program includes guidance to inventory and asse ss watershed conditions, identify and prioritize improvement needs, restore ecosystem components and functions, apply BMPs, implement pollution prevention design strategies, monitor project su ccess, and adapt management measures. For example, the USFS is in the process of updati ng national BMP guidance for administering its nonpoint pollution control strategy on NFS lands . This new USFS National BMP Program is

intended to meet or exceed all state BMP objectives as well as simplify and standardize water quality protection measures and monitoring on NFS lands.

4.2 State BMP Implementation and Effectiveness Monitoring

Measuring the success of BMP programs require s regular and credible surveying of BMP implementation (Prud’homme and Greis, 2002). However, implementation (or compliance)Assessment of Water Quality Impairments Related to Forest Roads Page 124 Contract # EP-C-05-066, TO # 0002 December 4, 2008

monitoring of nonregulatory BMPs is unique to forestry nonpoint source management. While other nonpoint-source sectors, su ch as agriculture, are genera lly unregulated, the degree of compliance with BMPs for agricultural activities is not systematically measured or reported. Many states have been monitoring forestry BM P implementation for a major portion of the 25 years of the nonpoint source progra m existence. During that time, state forestry agencies have approached implementation monitoring in differe nt ways, degrees of detail, precision, and statistical strength.

Under CWA Section 319, states must monitor fo restry BMP implementation, to assess whether BMPs are being applied, whether they are be ing applied appropriately (based on the state guidelines or rules) and, in some states, whether the BMPs are effective. Data obtained from the monitoring surveys has provided valuable inform ation which states have used to improve implementation rates and identify problem ar eas where corrections are warranted (NCASI, 2007). Summaries of the state forest road BMP imp lementation surveys are presented in Tables 4-4 and 4-5. Table 4-4 presents implementation data for states in which BMPs for forest roads are voluntary, and implementation data for states with mandatory BMPs are given in Table 4-5. These tables show which states are monitoring BMP implementation, and th e general nature of the results of the most recent surveys. Tables 4-4 and 4-5 include the number of surveys that have been conducted, the date of the most recen t survey, the survey site sampling design and methodology, and who conducts the survey. Results pr esented in these tables include the percent implementation (for all BMPs and specific catego ries related to roads and crossings), specific problematic BMPs, and whether the risk to water quality due to failure to implement BMPs was

evaluated. The tables also indica te whether the implementation data is maintained and tracked and if it accessible to agencies and the public; implementation results fro m 7 states where BMPs for forest roads are voluntary or mandatory are not published. States in which there are formal agreements between agencies for handling suspec ted incidents of water pollution from forestry operations are noted in the tables as well. Fi nally, Tables 4-4 and 4-5 indicate whether the surveys evaluate implementation separately for different categories of land owners, and what those categories are. In general, BMP implemen tation has been reported to be highest on public land, followed in descending order by forest industry land, corporate non-industrial land, andAssessment of Water Quality Impairments Related to Forest Roads Page 125 Contract # EP-C-05-066, TO # 0002 December 4, 2008

private non-industrial land (Prud’homme and Gr eis, 2002). BMP implementation data from several states are presented in more detail in Sections 4.4 and 4.5.

A National Association of State Fo resters survey of state silvic ulture nonpoint source control programs (Ice and Stuart, 2001) found that the BPM implementation rate is nearly 90% nationwide. Overall, rates of BMP implementa tion or compliance for western states are high, exceeding 80%. From recent survey data, the breakdown of statewide (i.e., data averaged across land ownership groups and performance measur es) implementation was as follows: Alaska (89%); California (94%); Idaho (96%); M ontana (96%); Oregon (96%); Utah (81%); Washington (80%); and Wyoming ( 97%). Ice et al. (2004) reported that over a 10-year period, audit reports show that BMP implementation ha s increased from 78 to 96% and water quality issues have decreased. Implementation rates in other regions are generally comparable, although there are also some states reporti ng lower rates of implementation.

Careful review of the tabulated summaries also demonstrate the difficulty of discerning actual rates of implementation with forest road BMPs . The overall BMP implementation rates can be misleading, because while 31 states regularly conduct compliance (or implementation) monitoring, only 21 states specifically monitore d road BMPs and only 19 monitored stream crossings. Where they are monitored, implementa tion rates for road and crossing BMPs tend to be considerably lower than the overall implementation rates.

Due to differences in methods for measuring BMP implementation, comparisons of rates among states cannot generally be made. Past differences in survey design and stat istical strength, rigor of inspections, and metrics chosen for evaluatio n within and among states also preclude precise reporting of state or regional progress over time . Results range from statistically valid to informative but of unknown statistical strength. The numbers of inspected sites and practices can vary widely between states and even among differ ent surveys within a stat e. For similar reasons the degrees of implementation achieved by re gulatory versus nonregulatory programs are difficult to assess (Prud’ homme and Greis, 2002).Assessment of Water Quality Impairments Related to Forest Roads Page 126 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Another area of inconsistency w ith the implementation surveys is how states quantify rates of BMP compliance and/or implementation. The state BMP manuals and monitoring reports often do not clearly define compliance and implementati on. As a result, some states use these words interchangeably and readers may interpret th em differently. Measures of BMP compliance indicate that a forest management action or pr actice abides by a requirement or recommendation. Conversely, implementation rates indicate whether or not a BMP prescription was utilized or installed. For these reasons, implementation moni toring is only partially effective in producing effective BMP implementation.

Another major difference among states for BMP implementation/compliance reporting involves whether states identify or quant ify ‘significant risks to wate r quality’ when BMPs are not implemented or are implemented incorrectly. Tabl es 4-4 and 4-5 indicate whether the rates of implementation were evaluated in terms of th reats to water quality. Though this measure can often be subjective, this additional piece of information is useful when trying to understand the implications of compliance or non-compliance rates. When states report th at a specific BMP was not implemented or was not implemented correctl y, this provides no information regarding the impact to water quality. Improperly installed BM Ps often do not result in significant risks to water quality, and this measure provides some insi ght when assessing rates of implementation or compliance.

Several regional groups have made efforts to promote consistency among state implementation monitoring programs. These include the Southe rn Group of State Foresters (SGSF), which developed voluntary BMP implementation monitori ng procedures in 1997, and the Northeastern Area Association of State Foresters (NAASF) and the USFS-Northern Region Program for State and Private Forestry, which jointly developed a protocol for monitoring the implementation and effectiveness of forestry BMPs (Welsch et al., 2007).

4.3 Are Compliance and Effectiveness Monitori ng of BMP Programs Actually Capturing the Success of These Programs in A ddressing Forest Road Runoff?

It is questionable whether high rates of BMP implementation and compliance truly reflect the effectiveness of programs to addr ess forest roads and protect wate r quality. As stated by Ice et al.Assessment of Water Quality Impairments Related to Forest Roads Page 127 Contract # EP-C-05-066, TO # 0002 December 4, 2008

(2004), there is unlimited skepticism about the e ffectiveness of forest nonpoint source control programs and limited assessment resources. Compliance rates per se may not be the best indicator of program effectivene ss (Ellefson et al., 1995). For example, if a state has out-dated or inadequate BMPs, compliance with these ineffec tive practices does not s how true water quality protection. The majority of compliance monito ring efforts are usually completed on recently harvested land. These evaluations may not investigate road maintenance or obliteration practices. On-the-ground determinations of BMP implemen tation are qualitative and judgmental by design, adding to the difficulty of compar ing or reproducing results. Impl ementation audits usually occur during summer, when conditions are dry and vege tation is leafed out; under these conditions it would be unusual to actually observe runoff, erosion, or sediment tr ansport. It is also noteworthy that most state surveys are conducted after on- the-ground activities have ceased. Thus, it is possible that water-quality impacts could occur bu t stabilize prior to the site being evaluated.

Moreover, effectiveness is different than impl ementation and can be much more difficult to accurately measure. Although implementation of BMPs is commonly over 90%, this does not correctly identify the effectiven ess of the practice (Rehder and Stednick, 2006). Effectiveness is how well a BMP system meets its goal, usually a water quality standard. In a monitoring strategy document for Washington, Schuett-Hames et al. (1996) noted that monitoring of aquatic resource trends was important because pr otection and restoration of aqua tic habitat and species are the fundamental management objectives (Ice et al., 2004). In 2000, seventeen states were conducting effectiveness monitoring of their BMPs (Ice and Stuart, 2001). No national-level analysis of the

results of these BMP effectiveness studies has been undertaken. Effectiv eness studies may not truly measure the effects of roads under the conditions that cause the most significant damage, such as during wet weather or under heavy usage. For example, an eff ectiveness study may not necessarily have monitored how road drainage features handle stormw ater during wet weather events and directly after—they may have only monitored their effects during dry weather when stormwater erosion was not taking place.

Of all the state monitoring implementation, onl y Texas has prepared an approved Quality Assurance Project Plan (QAPP) for collecting monitoring data. To fully address the quality of the information produced by implementation monito ring requires an evaluation of the samplingAssessment of Water Quality Impairments Related to Forest Roads Page 128 Contract # EP-C-05-066, TO # 0002 December 4, 2008

design, methods and conduct of inspections, and an alysis of the results. Are sampling programs based on random, representative site selections ? Are a sufficient number of practices and BMPs inspected to yield precise, accura te and representative results? Are the inspections objective, reproducible and complete? Durgin et al. (1988) observed that compliance with regulations tended to diminish with distance from the point of entry to the harvest ar ea, so this should be considered when selecting practices for evaluatio n. If monitoring results ar e used to assess trends in BMP implementation, are the inspection survey results compar able through time? Many states have found it necessary to revise their implemen tation monitoring programs over time, because it is difficult to foresee all of the potential site conditions that will be encountered during inspections; protocols require m odification and revised protocol s must be field tested. An example of this refinement is the Interage ncy Mitigation Monitoring Program (IMMP) pilot project implemented in California in 2006. The fi rst phase of the IMMP pilot project (2006) revealed that monitoring protocols required m odification and revised pr otocols are being field tested in the second phase of the IM MP pilot project in 2007 (NCASI, 2007).

The success of forestry BMP programs can be largely assessed by two measures: are BMPs being used, and when BMPs are applied do they reduce impacts so that desired water quality goals are achieved? The implementation monitori ng discussed above and in Section 4.3 largely deals with the first of these questions. A numb er of states have developed active monitoring programs, using water and biological sampling, bi oassessment and habitat research, to address the second question.

4.4 BMP Implementation Data: Examples from States

In the following sections, BMP implementation and effectiveness data are presented (alphabetically) for eleven stat es: California, Colorado, Florida, Georgia, Idaho, Maine, North Carolina, Minnesota, Oregon, Virginia and Washington. This list includes stat es from each of the forestry regions in the United States.Assessment of Water Quality Impairments Related to Forest Roads Page 129 Contract # EP-C-05-066, TO # 0002 December 4, 2008

4.4.1 California

California’s forest management rules and sediment control measures for forestry are arguably the strictest in the nation. For example, the requir ement for a detailed forest harvest plan alone places compliance with forest prac tices in California in a categor y by itself. California’s rules are also extensive: the 2007 FPRs are 212 pages long (NCASI, 2007). This state also has a rich legacy of compliance monitoring (NCASI, 2007). These include the following programs:



### y Hillslope Monitoring Program (HMP) pilot project, evaluating FPR implementation and effectiveness, conducted in 1993-95 by the CAL FIRE and the California State Board of Forestry and Fire Protection (CSBOF);



### y HMP annual statewide evaluations conducte d by independent contractors from 1996- 2002;



### y Modified Compliance Report (MCR) monitoring to assess water quality related FPRs, conducted from 2001-04 by CAL FIRE and CSBOF;



### y Forest Practice Rule Implementation and Effectiveness Monitoring (FORPRIEM), a second phase of the MCR program, focuse d on high risk (non-random) watercourse crossings and road segments th at drain to crossings, is being implemented in 2007; and



### y The Interagency Mitigation Monitoring Pr ogram (IMMP) pilot project was begun in 2005 to provide information about forest practic es at high-risk sites where measures have been specially designed to protect water quality.

The main conclusions from all the monitoring completed to date are that California’s water quality-related rule implementation rate is am ong the highest of any of the western United States, and that when properly implemented, the FPRs are effective in protecting water quality. Monitoring results have also shown, however, th at improvements are needed in watercourse crossing design, construction, maintenance and for road drainage, partic ularly near stream crossings. To improve practices on roads and at st ream crossings, there have been several efforts over the past five years, including the deve lopment of a guidebook on how to properly design crossings for 100-year flood flows and the passage of wood and sediment.Assessment of Water Quality Impairments Related to Forest Roads Page 130 Contract # EP-C-05-066, TO # 0002 December 4, 2008

IMMP data collection has focused on high risk (non-random) watercourse crossings and road segments that drain to the crossings, since pa st monitoring work has shown that these are particularly high risk sites for se diment delivery to stream channe ls. The first phase of the IMMP pilot project (2006) revealed that monitoring protocols requ ired modification and revised protocols are being field tested in the second phase of the IMMP pilot project in 2007. Pilot project work completed in 2006 showed that im proper installation of hi gh risk crossings and drainage structures near cr ossings is often the major cau se of water quality problems. Preliminary conclusions from the pilot work ar e that improved implementation of practices can be accomplished with additional timber operator education and more frequent multi-agency crossing inspections, both during logging operati ons and immediately following completion of harvesting.

From 2001 to 2004, the MCR monitored 244 randomly selected 1,000-ft (305-m) road segments (i.e., 46 forest road miles). Of the 1,991 road features rated for im plementation, only 83 departures from the FPR requirements were observed, a 95.8% implementation rate. The MCR report also indicated that these departures from the FPRs tended to be clustered, with 33 departures found within five road segments. De partures from FPRs were found for 4% of road segments. The most frequent problems (lack of compliance with the FPRs) were found to be related to road drainage. Evidence of sediment movement to waterbodies was found for nine

road related features ou t of 1,147 features rated for effectiveness (~1%). Approximately 8% of

the features with eviden ce of erosion (e.g., rills, gullies, mass failures,) delivered sediment to

stream channels. Of the nine instances of sediment delivery to channels from roads, five were found to be non-compliant with the FPRs. Tw o involved sediment m ovement onto “erodible materials or failure to discharg e into cover” and three were fo und to have “an inadequate number of drainage structures or inadequate spacing.”

The earlier Hillslope Monitoring Program found ove rall FRP implementation ratings greater than 90 percent for landings and for road, skid trail, and watercou rse protection zone transects (Cafferata and Munn, 2002). Implementation of app licable BMPs at problem points was nearly always found to be less than that required by the FPRs. HMP monitoring suggested that the forest practice rules were generally found to be sufficient to prevent er osion, and 97% of the 727Assessment of Water Quality Impairments Related to Forest Roads Page 131 Contract # EP-C-05-066, TO # 0002 December 4, 2008

erosion problem points identified were associated with departures from rule requirements (CBOF, 1999). Watercourse crossings had the lowest overall implementation ratings at 86 percent. BMPs for crossings were noted as a pr oblem, and a larger pr oportion of the crossing rule implementation ratings were for major de partures (significant outlet scour, 35%; some degree of plugging, 22%). Watercourse crossing pr oblems were caused by a number of factors, including inherent uncertainties in determining and implementing site specific construction and abandonment needs, improper maintenance, the fin ite expected life of culverts, and high risk locations for sediment delivery when stream discharge exceeded the design conditions. The majority of the evaluated crossings were existi ng structures that were in place prior to the development of the FPRs. Common problems in cluded culvert plugging, stream diversion potential, fill slope eros ion, scour at the outlet, and ineffec tive road surface cutoff waterbreaks. A need for greater attention focused on improve ment of crossing design, construction and maintenance was also noted (MSG, 1999).

Rules related to roads had greater than 90% comp liance, and most road rule departures were related to drainage and maintenance. The ot her main problem area identified by the HMP program was erosion from roads caused by impr oper design, construction, and maintenance of drainage structures. Nearly half the road transects had one or more rills present and approximately 25% had at least one gully. Eviden ce of sediment transpor t to at least the high

flow channel of a watercourse was found on 12.6 and 24.5% of the rill and gully features, respectively, with high percentage s of delivery to Class III waterc ourses. These erosion features were usually caused by a drainage feature deficiency, and the BMPs at these problem sites were nearly always found to be out of compliance. Mo st of the identified road problems were related to inadequate size, number, and location of draina ge structures.

Two of the major conclusions of the HMP mon itoring was that “roads and their associated crossings were found to have the greatest potential for delivery of sediment to watercourses,”

and that “where roads are built will remain critical for reducing the likelihood of producing significant sediment input to channels.” Recomme ndations therefore include d greater attention to and better implementation of rules related to drainage, crossing design, and maintenance. Erosion problem points were almost always a ssociated with improperly implemented FPRs.Assessment of Water Quality Impairments Related to Forest Roads Page 132 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Standard BMPs generally appeared to provide adequate water qual ity protection when they were properly implemented, and poor implementation was most common cause of observed water quality impacts (MSG, 1999).

There are several cooperative in-s tream monitoring projects in wa tersheds throughout California, including: Caspar Creek in Me ndocino County, where data has been collected since 1962, Garcia River in Mendocino County, South Fork Wages Creek in Mendocino County (CAL FIRE and Campbell Timberland Management), Judd Creek in Tehama County (CAL FIRE and Sierra Pacific c Industries), and Little Creek in Sant a Cruz County (CAL FIRE and Cal Poly-San Luis Obispo). These instream projects are an impor tant component of our overall water quality monitoring program. They are measuring sedime nt concentrations in water samples and recording the turbidity, or clarity of the water, at automated monitoring stations. This data helps provide connections between stream channel co nditions and management practices occurring on hillslopes in the watershed.

Watershed-scale monitoring conducted in California has produced mixed results for the effectiveness of road BMPs on water quality. Review of 40 years of research in Caspar Creek found that while California’s sediment control measures for forestry mitigate some of the problems with runoff from roads, these impacts are not eliminated. Ther e are no quantitative data for the California coast indicating that road BM Ps have substantially improved instream water quality or salmonid habitat conditions (Harris et al., 2005). It is not known how site-level effects

translate into benefits to water quality and stream habita t at the stream reach or watershed scales. Little is known about the temporal scale at wh ich improvements may occur. Recent studies show that restoration of upper watershed locations or non-fish-bearing streams causes short-term impacts on local water quality due to pos t-construction adjustments (Klein, 2003).

In the North Coast region, more than 85% of th e rivers are listed as impaired under the Clean

Water Act because of excessive amounts of sedime nt in stream channels, and all native salmon species are listed as threatened with extinction under the Enda ngered Species Act. In listing these streams and fish during the 1990's, th e USEPA and the NMFS both identified loggingAssessment of Water Quality Impairments Related to Forest Roads Page 133 Contract # EP-C-05-066, TO # 0002 December 4, 2008

operations approved under the FPRs as being th e primary reason for such listings becoming necessary (EPIC, 2002).

There are few regulatory regimes whose adverse impacts to water quality have been more comprehensively documented than the Californi a FPRs. The same fundamental problems have been noted by a variety of agencies, blue-ribbon pa nels, scientists, and cour ts throughout the last two decades (EPIC, 2002). Various federal and st ate agencies, including National Oceanic and Atmospheric Administration (NOA A), USEPA, the California Depa rtment of Forestry, and the California Department of Fish and Game have been critical of the effectiveness of the California FPRs (EPIC, 2000). As noted by Leslie Ried of the USFS Redwood Sciences Laboratory, the rules have not prevented the cumulative watershe d impacts that led to the recent listing of multiple northern California streams as impair ed by sediment under section 303(d) of the Clean Water Act (Reid, 1999). Modern FPRs were unable to prevent nearly a 10-fold increase in landsliding rate in the Bear Cr eek watershed that occurred when Pacific Lumber Company increased the rate of logging (PWA, 1998a; Reid, 1998; Reid, 1999b). Results from nearby

watersheds show similar landslide increases by factors of 3 to 13 (P WA, 1998b; Michlin, 1998; PWA, 1999). Even in the absence of major lands liding, the implementatio n of current forest practice rules could be associated with increased turbidity levels in streams. According to Reid (1999), the Forest Practice rules were not adequate to prevent forestry-related changes to the production and transport of sediment, water, and woody debris in watersheds. Changes in these "watershed products" are the most common causes for downstream cumulative impacts. The

rules were not sufficient to rest rict excess sediment production fr om logging-related activities to

levels that will not accelerate reservoi r sedimentation, increase flooding by channel sedimentation, and degrade water quality (Reid, 1999).

According to an analysis prepared by Reid ( 1999), standard FPRs were not protective enough to avert cumulative impacts. Cumulative impact ev aluations submitted with Timber Harvest Plans (THPs) and Sustained Yield Plans (SYPs) prep ared by Pacific Lumber Company she examined did not adequately evaluate the potential cumulative impacts of the plans. The expertise available in state and federal agencies did not appear to be appropriately em ployed during the review process. Contributing factors to the failure of FPRs to protec t water quality in these casesAssessment of Water Quality Impairments Related to Forest Roads Page 134 Contract # EP-C-05-066, TO # 0002 December 4, 2008

included excessive harvesting rates, even in pr eviously-degraded waters heds, and the political

control of the CAL FIRE.

In the case of both sediment production and hydrologic change, some imp act from forest land use is inevitable. Effective management for cu mulative impact prevention, according to Reid (1999), would require that the intensity of land use in a waters hed be maintained below the level at which the resulting impacts are no longer accepta ble. Such an approach would require that the FPRs include provisions that allow regulation of the rate of logging and the density of roads in a watershed. Without such provision s, standard rules and BMPs would need to be excessively protective to ensure that incremental additions are not dama ging. Such an approach would also require improvement of cumulative impact asse ssment methods, including a provision for a preliminary watershed assessment to be done by interagency staff. This assessment would identify issues of concern, the impacts affec ting them, and the causes of those impacts. The watershed assessment would provide the backgro und information needed to analyze cumulative impacts of future projects anywhere in the watershed and would provi de guidance for carrying out such analyses. Additionally, Reid (1999) reco mmended giving authority to staff of relevant departments (i.e., Water Quality Control Boar d, Department of Fish and Game, etc.) for decisions falling within the purview of t hose departments' areas of expertise.

4.4.2 Colorado

Roughly 14.5 million acres of forest are located on public lands in Colorado (NCASI, 2007). Forest inventory data show substantial timber vol umes in the state; howev er, growth and harvest rates are very low (USFS 2000). In 1998, Colorado developed forestry BMPs, referred to as forest stewardship guidelines (FSG ), to protect water quality. This is a non-regulatory approach to forestry BMP implementation. The recomm endations included in the Colorado forest stewardship guidelines to prot ect water quality were approve d by the Colorado State Forest Service in partnership with the Colorado Timb er Industry Association (CTIA). The foundation of Colorado’s recommendations is based, in large part, on recommendations developed by Montana (CO FS, 1998).Assessment of Water Quality Impairments Related to Forest Roads Page 135 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Colorado, along with Arizona, appear to be the only western states th at have not conducted audits to evaluate rates of BMP implementation and effectiveness. Colorado has been active in education outreach, largely th rough the Central Rockies Sust ainable Forestry Education Program, which includes a 30 hour course on fore st BMPs. Instead of conducting field surveys of BMP implementation, Colorado has used anecdotal feedback on BMP implementation rates through these workshops (Ice et al., 2004). According to NCASI (2007), the Colorado State Forest Service and the Colorado Timber Industry A ssociation hope to initiat e a statewide audit of BMP implementation at some time in the future.

4.4.3 Florida

Commercial forest land covers 47% of the land area in Flor ida (FDEP, 1997). Since 1981, the Florida Division of Forestry (DOF) has monitore d forestry operations for BMP implementation by conducting biennial surveys. Through 2005, the DOF has evaluated over 4,400 individual forestry operations and recorded statewide impl ementation ranging from 84% in 1985 to 99% in the most recent survey (FL DOF, 2006). Aver aged over the years, the FL DOF reports a cumulative statewide average of 93.4% for overall forestry BMP implementation.

Sites for the 2005 survey were sel ected using criteria that provid ed the FL DOF with a list of sites where “...the greatest potenti al for forestry-related nonpoint source (NPS) pollution exists, and where any such impacts are still discernibl e and measurable at the time of the survey” (NCASI, 2007). DOF BMP Foresters evaluated a nd scored implementation at three levels on each site: (1) individual practice(s), (2) categorie s of practices, and (3) overall. For individual practices, implementation was recorded as yes, no , or not applicable. For categories of practices, as well as the overall score, implementation was e xpressed as a percent of all applicable BMPs. Each incidence of non-compliance at the practice level was further evaluated to determine if a “significant risk to water quali ty” existed. The FL DOF defines si gnificant risk as, "A situation or set of conditions where non-compliance with BMPs has resulted, or may result, in the measurable and significant degradation of physi cal, chemical, or biological integrity of water quality, to the extent that it presents an immi nent and substantial danger to the designated beneficial use.” When a significant risk has been identified, the BMP Forester advises theAssessment of Water Quality Impairments Related to Forest Roads Page 136 Contract # EP-C-05-066, TO # 0002 December 4, 2008

landowner on how to implement corrective measur es. Afterward, a follow-up site evaluation is made to reassess compliance. Landowner non-compliance with recommendations made by the

BMP Forester will result in a referral to th e appropriate regulatory agency for enforcement

action.

In 2005, the FL DOF BMP implementation survey examined 4,477 practices on 190 sites in 39 counties. There were fourteen categories m onitored for BMP compliance such as special management zones; wetland forestry operations; roads and stream crossings; timber harvesting, site preparation and planting; fireline cons truction; and waste disposal. The landownership breakdown was as follows: 24% on non-industrial pr ivate forest landowners (46 sites), 62% on industrial lands (119 sites), and 13% on public forestlands (25 s ites). Overall, 87% of sites visited, regardless of ownership, showed complete implementation of all applicable BMPs (FL DOF, 2006). The statewide BMP implementati on rate average was 99.1%, and rates of implementation ranged between 85-100% across the state for individual s ites. Most important, the 2005 survey reported no instances of non-complian ce that would result in a significant risk to water quality (FL DOF 2006). For fo rested wetland harvesting opera tions, 94% (560 practices on 70 monitored sites) were found to be in full compliance with recommended forestry BMPs. Forest road and stream crossing BMP complianc e averaged 98.1% and 100%, respectively. The most commonly cited incidence of non-compliance fo r roads was a failure to “stabilize critical road segments” and install draina ge structures (FL DOF, 2006).

In 1996, the Florida Division of Forestry a nd Department of Environmental Protection conducted a biological assessment of four commerci ally harvested sites be fore and after harvest (Vowell, 2001). Four sites were selected on fore st industry land; the methods for selecting the study sites were unknown. The sites were schedu led for harvest as part of normal ongoing company operations, and the state’s silviculture BMPs were strictly adhered to during all operations. Forestry activities took place in 0.05 to 24% of the site watersheds. Forest roads were not discussed in the study report, although all si tes had roads and 2 sites had stream crossings. Upstream and downstream habitat and biologi cal assessments were conducted before and immediately after activities were performed, and were continued for 2 years. The investigators found no statistically significant differences in parameters measured between the reference andAssessment of Water Quality Impairments Related to Forest Roads Page 137 Contract # EP-C-05-066, TO # 0002 December 4, 2008

treated sites. From this limited study, the author s concluded that Florid a’s silviculture BMPs were effective in protecting water quality, aquatic habitat, and overall stream ecosystem health (Prud’homme and Greis, 2002).

4.4.4 Georgia

The Georgia Forestry Commission (GFC) is resp onsible for the development, implementation, and monitoring of forestry BMPs in Georgi a. BMP implementation and compliance surveys were conducted in 1991, 1992, 1998 and 2002. For th e 2002 survey, the number of sites evaluated in Georgia was based on the amount of timber harvested in each county as determined by the USDA Forest Service’s Forest Statistics for Georgia, 1997 report (GA FC 2005). This methodology resulted in a pool of 421 potential survey sites with at least one site in each of Georgia’s 159 counties. The sample was also target ed to reflect the range in forest ownerships using the USFS Forest Statistics report. Th e ownership classes ar e categorized into nonindustrial private forestland, forest industry land s, and public lands. Of the 421 potential survey sites identified by the GFC, 283 s ites (69%) were on non-industrial private forest land, 107 sites (26%) were on forest industry lands, a nd 22 sites (5%) were on public lands.

Survey sites were evaluated using 108 specific, yes/no questions directly related to BMPs recommended in the manual. Rates of implementa tion and scoring occurred at three levels: (1) individual BMP, (2) category of BMP practices , and (3) overall site BMP implementation. The SGSF BMP monitoring framework was utilized. For categories of BMP practices and overall site BMP implementation, the score was expressed as a percent of all applicable BMPs implemented against all applicable BMPs in the category of practice and overall site (NCASI, 2007). Therefore, each category of practice and overall site coul d score between 0% and 100%. Included in the 13 categories of BMP practices ev aluated by the GFC were stream crossings and

main haul roads.

In addition to evaluating rates of BMP implemen tation, BMP performance was also evaluated in terms of ‘water quality risk a ssessments’ and levels of BMP comp liance. The GFC defined a risk to water quality as, “a situation or set of conditions that has resulted, or may result, in erosion orAssessment of Water Quality Impairments Related to Forest Roads Page 138 Contract # EP-C-05-066, TO # 0002 December 4, 2008

other pollutants entering a wate r body, an increase in stream temperature, or the physical degradation or obstruction of water bodies observed at each BMP question.” Rates of BMP compliance are used by the GFC to track tempor al changes among sample surveys for specific

BMPs.

Overall, BMP implementation and compliance rate s were 89.8% and 99.4%, respectively, for the 2004 GFC BMP survey (GA FC, 2005). Rates of BMP implementation and compliance, respectively, were 80.6 and 44.1% for stream cro ssings, and 88.1 and 93.4% for main haul roads, and 95.9% compliance in terms of stream miles. Th ese results suggest that stream crossings are the priority area to focus a ttention regarding water qual ity (NCASI, 2007). The GFC 2004 survey more specifically notes that, “The biggest concern and area for th e greatest improvement is eliminating the skidder fords and debris a nd dirt type crossings (GA FC, 2005).” Stream crossings were problematic in that 115 out of 349 stream crossings were, “...associated with skidder fords or debris type crossings. Thes e automatically count as noncompliant since the [State] BMPs do not recommend their use. Just eliminating these type crossings offers the greatest potential to increase compliance”. Th e GFC differentiated existing roads and stream crossings from ‘newly’ constructed forest ro ads and crossings. Over all compliance of preexisting roads and stream crossings averaged 94.7% and 62.0%, respectively. Conversely, newly constructed road compliance averaged 83.7%. New stream crossings scored only 31.9%. Skidder fords made up 52% of the non-compliance observa tions for new stream crossings. Removing skidder fords from the analyses would have raised ‘newly’ constructed stream crossing compliance to 66.7%. Still, the compliance rate fo r stream crossings was well below the overall BMP implementation and compliance rates.

The previous BMP implementation survey was conducted from fall 1997 through summer 1998 on 386 sites selected from across Georgia in a st ratified random sample, and was the first that conforms to the BMP monitoring protocol e ndorsed by the SGSF in 1997. All sites experienced some kind of silvicultural treatment in the pre ceding 2 years, and repres ented all land ownership categories in all geographic and physiographic provinces (Prud’homme and Greis, 2002). By ownership, 72 % of the sites were non-industria l private, 26 % were fo rest industry, and 2 % were public. By physiographic province, about 6. 5 percent were in the mountains, 34.5 % wereAssessment of Water Quality Impairments Related to Forest Roads Page 139 Contract # EP-C-05-066, TO # 0002 December 4, 2008

in the Piedmont, 19 % were in the upper Coas tal Plain, and 40 % were in the lower Coastal Plain. A judgment was made for each BMP not properly implemented, or found to have failed, as to whether a significant risk to water quality resulted. Results were al so expressed in acres, miles of road and streams, and number of st ream crossings in full compliance for each BMP category, for the site as a whole, and for the State overall.

A total of 6,690 individual BMPs were ev aluated over about 43,118 acres. Statewide BMP implementation compliance was estimated at 78.7 % for all BMP categories in all land ownerships and all physiographi c regions. By land ownership, BMP compliance was 75.4 % on private non-industrial, 86.3 % on forest indus try land, and 84 per cent on all public land, respectively. Compliance rates for stream cro ssing BMPs were 58.8 % and 76.6 % for main haul roads. Stream crossings were of particular concern to the GFC. However, it was also noted that many of the out-of-compliance stream crossings ex isted before silvicultural treatments were conducted and were not specifically relate d to forestry operations. operations.

4.4.5 Idaho

Assessments of forestry BMPs in Idaho suggest that hillslope erosion does not contribute sediment to streams except where disturbances have occurred adjacent to streams, which in most cases has occurred only where activities were f ound to have been out of compliance with the rules (NCASI, 2001). In 2001, Idaho published the resu lts of the state’s fifth statewide Forest Practices Water Quality (FPWQ) audit (Hoelscher et al., 2001). That survey was conducted during the summer of 2000 on 40 timber sale s that were harvested between 1996 and 1999 (NCASI, 2007). The purpose of the audit was to assess the implementation and effectiveness of Idaho’s forest practices describe d in the 1998 FPA. To evaluate ra tes of compliance with Idaho’s FPRs, the FPWQ audit team was split into two groups. One group evaluated road segments and skid trails, road construction, and maintenance. The other group evaluated a Class I stream segment to assess compliance with the timber harvest rule.

On nine sales (23%) the audit t eam found violations with site-s pecific riparian prescriptions, specifically all roads paralleling the stream in th e Stream Protection Zone. Thirty Class I streamAssessment of Water Quality Impairments Related to Forest Roads Page 140 Contract # EP-C-05-066, TO # 0002 December 4, 2008

crossings were also evaluated w ithin the 40 timber sales. Eighteen were culverts (existing or new), of which five were found to be compliant (27.7%) with Idaho’s FPRs. Reasons for culverts being non-compliant fell into two groups, culverts that exceeded requirements for fish passage and culvert with excessive drop. The remaini ng crossing structures (bridges, fords, and temporary crossings) were all found to be co mpliant. Ten out of 12 new stream crossing structures provided adequate fish passage with in Class I streams and, again, the problematic crossings were culverts. Adequate culvert installa tion has historically been problematic in Idaho, with 11 of 18 culverts not meeting the minimum requirements (Hoelscher et al., 2001). To improve culvert compliance rates, the audit team recommended that the FPRs specify water velocity or drop requirements so that culv erts would ensure adequate fish passage.

The 1992 Idaho Department of Environmental Qua lity Water Quality Audit (Hoelscher et al., 1993) concluded that “BMP’s ... were judged to effectively prevent pollutant delivery to streams 99% of the time,” but that when BMPs were not applied, pollutants, primarily sediment, were

delivered to streams 75% of the time. Similarl y, the 1996 audit (Zaroban et al., 1997) concluded that “when properly applied and maintained, the management practices described in the Idaho forest practices rules are effective 99% of th e time.” The most frequent area of non-compliance

with BMPs was related to road construction and/or maintenance; 69% of all cases of noncompliance were associated with road rules. Se diment was found to be de livered primarily from roads, with comparatively minor contributions fro m harvest systems. Road rules were cited in 84% of those cases where sediment delivery o ccurred. Non-industrial private forest (NIPF) landowners, who own twice as much forestland as industrial timber companies in Idaho, do not have a good BMP implementation record (TetraTech, 2004).

4.4.6 Maine

A review of silvicultural NPS pollution control programs for Maine and eleven other northeastern states (C onnecticut, Delaware, Maryland, Ma ssachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and West Virginia) produced four principal findings related to BMP implementa tion and water quality monitoring (NCASI, 2007). First, while recognizing data limitations, states generally rank silvicultural sources of NPSAssessment of Water Quality Impairments Related to Forest Roads Page 141 Contract # EP-C-05-066, TO # 0002 December 4, 2008

pollution as insignificant. Second, state agencies in the Northeast generally devote few resources to enforcement and monitoring. Third, states in the region rely heavily on BMP implementation as well as logger education and training progr ams to control NPS pollution during forest management. Forth, only a handful of survey s evaluating BMP implementation have been conducted by states in this region. Since only a handful of state agenci es have conducted BMP implementation surveys, the Northeastern Area Association of State Foresters (NAASF) and the USFS-Northern Region Program for State and Private Forestry join tly developed a protocol for monitoring the implementation and effectiveness of forestry BMPs (Welsch et al., 2007).

The state of Maine has been actively involved in the NAA SF and USFS-NR BMP Monitoring Protocol, and has collected field data to assist in the protocol ’s testing and validation (NCASI, 2007). Additionally, the state has conducted th ree BMP implementation and effectiveness surveys. The results of the first study were published by Briggs et al. (1998) and two subsequent surveys have been conducted by the Maine Forest Service in 2001 and 2005. The study by Briggs and colleagues concluded that Maine’s BMPs were highly effective when implemented properly. However, implementation of individua l BMPs was highly variable across the state (Briggs et al., 1998). The Maine Department of Environmental Protec tion (1994, as cited in Stafford et al., 1996) found that 30% of timber harvests reviewed for potential nonpoint source pollution exhibited serious pot ential for erosion and had not followed BMP procedures.

In 1999, the Maine Forest Service (MFS) deve loped and tested a new field monitoring methodology. The state evaluates BMP implementati on on specific principles or prescriptions within a harvest area, and evaluates BMP eff ectiveness by evaluating the impact of harvest activities on water quality a nd is rated in terms of soil movement and delivery to waterbodies. In the second round of this survey (based on data collected from June 2001 to November 2003; ME DOC, 2005), overall BMP use was either ‘appr opriate’ or a ‘good attempt, but needs improvement’ on 75% of the sites evaluated. Thes e findings represent a 12% increase over the previous round of monitori ng by the MFS published in 2001. The MFS 2005 publication also reported a ‘minimal attempt’ to implement BMPs on 16% of the monitoring sites; 8% of the sites did not attempt to implement BMPs. No evidence of major soil transport or deposition within

waterbodies was observed on the 150 sites where BMPs were implemented properly. BMPs wereAssessment of Water Quality Impairments Related to Forest Roads Page 142 Contract # EP-C-05-066, TO # 0002 December 4, 2008

highly effective in preventing soil transport to waterbodies on 82% of th e sample sites. This represented a 22% improvement over the 2001 MFS report.

BMP implementation for logging filter strips were used appropriately or with a ‘good attempt, but needs improvement’ on 89% of the sites eval uated. Implementation rates for skid trails averaged 86%. Implementation rates for temporary stream crossings were much lower, however, and only used appropriately on 54% of the harves t sites evaluated. Minimal attempts and failure to implement stream crossing BMPs totaled 30%. Incidences of sediment delivery to streams were also high for temporary crossings (23 %). Categories of corr ect application and good attempt, but needs improvement for haul road st ream crossings were somewhat low scoring at 78% implementation, and only slightly higher than implementation levels for haul road filter strips and drainage systems (74%).

Implementation of forestry BMPs was also eval uated based on forestland ownership. In the ME DOC 2005 Report, 88% of the survey sites were se lected from the non-industrial private forest and industrial forestland categories. Implementa tion rates (sum of the appropriate use and good attempt, but needs improvement categories) vari ed among these categories from a low of 65% on investor forestlands to a high of 88% on public forestlands. The implementation rates of forest industry lands scored 81% while non-industrial pr ivate forests had an implementation rate of 70%. The 2005 report also indicated that nearly one-third of the investor forestland sites (~9 sites) had visible evidence of so il transport to surface waters.

Some ten years earlier, the Maine Department of Environmental Protection (1994, as cited in Stafford et al., 1996) found that 30% of timber harvests reviewed for potential nonpoint source pollution exhibited serious potenti al for erosion and had not follo wed BMP procedures. Historic information suggests that watershed disturbance in Maine related to ag ricultural practices has decreased dramatically and that mu ch of the land formerly in activ e farms has reverted to forests (Irland, 2000). However, it is unclear whether this change in land use has affected surface water quality.Assessment of Water Quality Impairments Related to Forest Roads Page 143 Contract # EP-C-05-066, TO # 0002 December 4, 2008

4.4.7 North Carolina

North Carolina has linked BMP implementation to other State regulatory programs, making it quasi-regulatory in some circumstances. The North Carolina Division of Forest Resources (NC DFR) established forestry BMPs to ensure that the state’s nine Forest Practice Guidelines (FPGs) related to water quality were met by forest ma nagement operations in the State (White, 1992). Mandatory FPGs are required for exemption of forestry operations from the 1973 North Carolina Sediment Pollution Control Act. The FPGs are pe rformance standards that are mandatory and, therefore, must be complied with. The state-r ecommended forestry BMPs are the more specific ‘on-the-ground methods’ that, when applied correctly, s hould result in maintaining compliance

with the FPGs.

The NC DFR conducted forestry BMP surveys in 1995, 1996, and 2000. The most recent BMP implementation survey, conducted by the DFR, was published in 2005 (NCASI, 2007). In that survey, rates of BMP implementation for the st ate averaged 82% (NC DFR, 2005). The survey

was conducted in all three of North Caroli na’s physiographic regions and included measurements in all 100 counties. Forestry BMP implementation rates in the Coastal Plain and Piedmont (85 and 87%, respectively) exceeded th ose in the Mountains (69%). Specific BMPs examined in the survey were: SMZs, stream temper ature, debris entering streams, waste entering streams, permanent forest roads, skid trails, stream crossings, access road entrances, and project site rehabilitation (NC DFR, 2005). The implemente d BMPs scoring consistently highest (>85%)

for the state as a whole were those related to SMZs, stream temperature management, debris entering streams, waste entering streams, and access roads. Conversely, implementation rates for stream crossings, skid trails, a nd site rehabilitation BMPs were consistently lower (65%, 72%, and 41%, respectively) across all physiograp hic regions. FPGs related to water quality maintenance for the surveyed sites ha d an 82% statewide compliance rate.

NC DFR also assessed the overall threat or risk to water quality posed by a forest management practice, as a surrogate meas ure of BMP effectiveness (NCA SI, 2007). The 2005 survey results indicated that forestry practices posed a small th reat to water quality, av eraging only 8%, when BMPs were implemented (NC DFR, 2005). This i ndicates that either th e BMP was implementedAssessment of Water Quality Impairments Related to Forest Roads Page 144 Contract # EP-C-05-066, TO # 0002 December 4, 2008

incorrectly, and water quality impairments occu rred as a result, or the recommended forestry BMP was inadequate for a specific situation. Mount ain region sites had the highest occurrence of water quality risks (~15%). Water quality risks due to BMP non-implementation were approximately 42% (NC DFR, 2005). The 2005 North Carolina monitoring survey also indicated that the North Carolina Forestry Association’s ProLogger Program, “...can do more in the future by focusing training on areas identified in this report that need improvement, such as stream crossings, debris entering streams, skid trials and streamside management zones. Also, additional training will be needed to improve perfor mance in the mountains and foothills.”

NC DFR conducted earlier fore stry BMP surveys in 1995 and 1996 (Hensen, 1996). In the 1996 survey, overall statewide BMP implementation wa s rated at 95 percent as either good or excellent. Implementation on public land was rated at 100 percent, industry land at 90 percent, and non-industrial land at 76 percent. There was no discernable BMP implementation pattern based on slope.

In the early 1990s the North Carolina Division of Water Quality and the USFS examined the

effectiveness of BMPs on a forest road in th e Appalachians (North Ca rolina Division of Water Quality, 1994). A long-existing road, which cl osely paralleled Timbered Branch and its

tributaries for about 2 miles and had been a chroni c source of road sedime nts to the stream, was retrofitted with a number of measures designed to reduce sediment loading. They included ditch outlets, sediment traps, berms, weeps, outslopes, humps, and relief culverts. Sediment reduction was assessed qualitatively, and biological monitoring was conducted on the affected streams to determine effects on aquatic species. Improvements in taxa richness and diversity in the aquatic community were attributed to the sediment reduction practices.

4.4.8 Minnesota

In 1995, the Minnesota Legislature adopted the Su stainable Forest Resources Act (SFRA), the only forest practices act in th e midwest region. The act estab lished policies and programs to ensure sustainable use and management of the states forest resources. The SFRA presents a broad strategy for achieving forest sustainability in two areas: site-based timber harvesting/forestAssessment of Water Quality Impairments Related to Forest Roads Page 145 Contract # EP-C-05-066, TO # 0002 December 4, 2008

management guidelines and landscape-level forest resource planning and coordination. Supporting programs involve BMP mon itoring, research, and education. While the other states in this region do not have forest practices act s, many do require permits or notification of management activities (NCASI, 2007). This is gene rally required when constructing or repairing stream crossings.

The SFRA statute requires the Minnesota Depart ment of Natural Resources (DNR) to develop and administer the implementation monitori ng program, with oversight provided by the

Minnesota Forest Resources Council MFRC. In 2004, the DNR published a report summarizing three years of monitoring sites harvested prior to the publication of the States integrated timber harvesting and forest management (TH/FM) gui delines (Dahlman and Phillips, 2004). The

information contained in that re port was intended to be used as baseline data for comparison with future BMP implementation assessments. Site selection procedures va ried among years, due to concerns over sample bias. Implementation of TH/FM guidelines was monitored in the following forestland ownership categories: state, county, public, forest industry, NIPF, and other (tribal, other public and non-forest industrial). The categories of BMPs examined in this report include: use of filter strips and riparian mana gement zones, protection of water quality and wetlands (waterbody crossings and a pproaches), and protection of fo rest soil resources (landings, roads, and skid trails).

During the three survey years, a total of 1,262 filter strips were identified for wetlands and open

water bodies associated with monitored timber ha rvest sites (NCASI, 2007) . Effective filter strip BMP applications were found for 73% of the si te evaluations (Dahlm an and Phillips, 2004). Only 31% of the SMZs for waterbodies within the harvest area met the guidelines for SMZ width and basal area, compared to 64% of the riparian management zones (RMZs) for water bodies adjacent to the harvest area. Rates of BMP implementation for waterbody SMZs appear low in this report. However, the results in this report reflect management practices for sites that were harvested prior to the pub lication of the current TH/FM guidebook (Dahlman and Phillips, 2004).Assessment of Water Quality Impairments Related to Forest Roads Page 146 Contract # EP-C-05-066, TO # 0002 December 4, 2008

The DNR also reported monitoring results for 54 8 road and skid trail crossings (NCASI, 2007). There were also 1,033 stream crossing approach es and 80 wetland approaches found. A majority of the crossings and approaches (68%) were reported to be ‘w inter-only operations.’ Furthermore, the majority of crossings for wetla nds and open waterbodies were assumed to have taken place when the ground was frozen, thereb y, limiting impacts to soils and water quality (Dahlman and Phillips, 2004). Data collected in the 2002 survey indicated that a majority of approaches to waterbodies were in good conditi on with only 6% showing signs of erosion and rutting and only 3.4% having sediment reachi ng a wetland or waterbody. The implementation of BMPs to protect soil resources generally scored well. The TH/FM guidelines recommend that forest roads and landings occupy no more than 3% of the harvest area. The statewide averages were similar all three years and averaged 3.0% for all ownerships. The TH/FM guidelines for forest roads recommend using an appropriate comb ination of erosion control and water diversion practices on all road segments, especially those road segments with grades exceeding 2%. A total of 311 road segments with a grade less than 2% were identified duri ng the three years of monitoring. More than 85% of th e segments had a grade less th an 10%, as is recommended in the TH/FM guidelines. Monitoring in 2002, however , found that only 41% of these sampled road segments were stable. Furthermore, 12% of the sa mple road segments had sediment that reached a wetland or waterbody. As indicated in the 2004 monitoring report, the limited use of erosion control structures and water diversion practices, “...is a cause for concern that has been and will

continue to be addressed in fu ture training programs.” A majority of the monito ring sites (57%) were found to have minimal, randomly distributed, and lightly trafficked skid trails across the

harvest sites.

Minnesota’s 2004 survey did not calculate a stat ewide BMP implementation average. The data from this report was to be used as a baseline measure for future implementation assessments (NCASI, 2007). Activities scori ng poorly included use of wa ter diversion techniques and approaches to stream crossings. Minnesot a reported that common departures or nonimplementation of BMPs was observed for water di version structures on roads and skid trails. Implementation was highest on both public lands and industrial forestlands and lowest on nonindustrial forestlands.Assessment of Water Quality Impairments Related to Forest Roads Page 147 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Implementing BMPs for stream crossings were gene rally not reported as probl ematic by states in this region. The reasons for this trend are many a nd include reasons such as: monitoring sites not containing waterbodies or mana gers conducting harvests in a manner where crossing a stream was not necessary. Another reason stated in the Minnesota report was that wetland and stream crossings were “assumed to be frozen” duri ng harvesting (Dahlman and Phillips, 2004).

4.4.9 Oregon

In Oregon, BMP compliance rate s from 1987 to 1996 have averaged between 96 and 98% (Dent and Robben, 1999). As in many states, the most frequent areas of non-compliance found in the 1998 Oregon Department of Forestry (ODF) mon itoring were in road construction and/or maintenance (Dent and Robben, 1999). Of 20 road -related practices out of compliance with BMPs, 9 resulted in sediment delivery to stream s. Non-compliant practices having the greatest impacts on streams were related to road drainage or temporary crossings. Of 22 sediment sources identified in the 1998 inspections, 19 were associat ed with roads. Six of the 22 sediment sources were estimated to be “incidental” ( less than 1 cubic yard of sediment), 10 were “moderate” (1 to 10 cubic yards), and 6 were judged to be “significant” (more than 10 cubic yards).

Additional monitoring by ODF indi cated that 31% of the surveyed road length potentially delivered sediment to streams, and that two-th irds of that potential delivery length occurred immediately upslope of live stream crossings (Skaugset and Allen, 1998). However, less than half (40%) of that potential delivery lengt h occurred where surface drain spacing exceeded recommended criteria, suggesting th at drainage spacing is not suffi cient by itself to adequately control sediment delivery from roads. For the portions of the road network where sediment delivery is occurring, three major issues were identified (Mills et al., 2003):



### y There is a general lack of filtering of drainage waters near streams. A number of cases were observed where cross drainage structures were not in place to filter road runoff before the runoff reached stream crossings.



### y Steep-gradient roads tend to have cross draina ge structures at wider spacing than lower gradient roads. Under the current rules, road design and maintenance practices shouldAssessment of Water Quality Impairments Related to Forest Roads Page 148 Contract # EP-C-05-066, TO # 0002 December 4, 2008



### y There are inconsistencies in drainage practices between georegions, with special concerns in the Siskiyou georegion.

Most forest roads in Oregon were constructed prior to state rules th at marginally improved construction standards (Mills et al., 2001). A significant amount of road networks in most watersheds remain hydraulically connected to streams (Rhodes and Huntington, 2000; Wemple et al., 1996). Although Oregon fore st practice regulations since 1978 have required operators to locate stormwater management BMPs so that runoff is filtered before entering streams, a report prepared on the Kilchis watershe d in the Tillamook State Forest found that roads in western Oregon generally do not comply with this rule (ODF, 1997).

ODF monitoring in 1996 showed that about 1/3 of active and inactive roads can (rated as “certain” or “possible”) deliver sediment to st reams by ditches (FPAC, 2001). That report noted the potential for significant amounts of sediment to be delivered from these sources during haul operations, especially during wet season. One probl em area not directly addressed by FPRs was erosion and sediment delivery associated with the use of roads during rainy or thawing periods. Current road maintenance rules directed operators to stop hauling when high levels of turbidity were observed entering streams. However, there were no rules that addressed the specific level of turbidity considered acceptable during wet season hauling.

4.4.10 Virginia

The Virginia Department of Forestry ( VA DOF) conducts quarterly BMP monitoring assessments (VA DOF, 2007). The VA DOF implementation and effectivene ss field audits serve four functions (NCASI, 2007). First, to quantify levels of effort in attempting to use BMPs and

whether BMPs utilized meet tec hnical specifications. The second f unction is to identify current levels of BMP implementation as compared to th e technical BMP standards. Implementation is a measure of the attempt to implement BMPs to the technical specifications described in the BMP

manual. The third function of the assessments is to identify levels of potential sedimentation. Finally, the assessments are also seeking to identify levels of active sedimentation.Assessment of Water Quality Impairments Related to Forest Roads Page 149 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Virginia state law requires landowners or managers to notify the VA DOF at least 3 days prior to conducting a timber harvest; therefore, a pool of potential survey si tes is readily available. For each semiannual survey, the VA DOF randomly sele cts and visits at least 30 timber harvests from their database for field audits. Monitoring is conducted in nine catego ries: stream crossings, water control structures, seeded areas, SMZs, skid trails/road grade, rutting, gravel/mats, oil spill/trash, and other.

The most recent BMP monitoring data (annual data) is available for 2006 (VA DOF, 2007). Rates of full BMP implementation expressed as a percentage of the total ranged from 1% (rutting) to a high of 100% (other category) ( VA DOF, 2007). Effort, expressed as a percentage of the total needed, ranged from 2% to 119% in 2006. Effort to implement water control structures was found to average 59% in 2006. By c ontrast, effort was high for stream crossings (119%), road/trail grade (94%), SMZs (86%), gravel/mats (100%), and oil spills and trash (84%). The reason for the high stream crossing effort level can be explained as follows. VA DOF personnel determined that 149 ‘total efforts’ were needed for stream crossings and total effort for logging sites totaled 178 (VA DOF, 2 007). Full implementation scored somewhat low

for use of water control structur es (35%). While strong efforts were made for stream crossing BMPs, full implementation was found to only be 68%. While the aforementioned levels of BMP implementation appear low, the impacts to wate r quality were not dramatic. For example, the percentage of sampled sites that received a pos itive evaluation (yes) in the potential and active sedimentation categories for 2006 were 9% and 6%, respectively (VA DOF, 2007). This finding indicates that while BMP prescriptions were not precisely meeting the VA DOF BMP technical specifications, the levels of effort ‘on-th e-ground’ were having positive effects on water resources during forest ma nagement (NCASI, 2007).

Earlier BMP monitoring in Virginia produced ve ry low rates of compliance (Prud’homme and Greis, 2002). For example, BMP compliance rate s between 1991 and 1999 ranged from only 7 to 16%. However, this was largely a consequen ce of the scoring methodology. To be in full compliance, 100 % of applicable BMPs at the audit si te had to be 100 % implemented and meet 100 % of the technical specifications of the BMP manual. Effort to implement BMPs was notedAssessment of Water Quality Impairments Related to Forest Roads Page 150 Contract # EP-C-05-066, TO # 0002 December 4, 2008

on 90 percent of the sites visited. The field eval uator indicated that 90 % of the sites were experiencing no related water-quality impact s, but 38 % exhibited potential for impact.

4.4.11 Washington

The State of Washington has a reputation for intensively mon itored watersheds and a strong emphasis on biological monitoring to measur e BMP effectiveness (Harris et al., 2005). However, Washington has no regular program to monitor BMP implementation, aside from a number of detailed but sporadic studies of rule implementation (Ice et al., 2004). New road construction and haul road maintenance BMPs were comprehens ively evaluated from 1992-95 in Washington to determine their effectiveness (Rashin et al ., 1999). The evaluation focused on determining whether these BMPs were effective at achieving state water quality standards pertaining to sediment-related water quality impacts. Field in vestigations were conduc ted to assess surface and stream channel erosion processes during the first one to three years following the forest practice operations. A number of qualitative an d quantitative survey te chniques were employed in a case study approach to assess surface erosion and chronic sediment delivery to streams, physical disturbance of stream channels, and th e condition of aquatic ha bitats and biological communities. Practices for installing stream cros sings for new road construction were generally found to be ineffective or only partially effective at preventi ng chronic sediment delivery to streams. Road drainage BMPs, sp ecifically practices for installing relief culverts, were found to

be effective at over half of the new road sites evaluated. Practices for construction and stabilization of cutslopes on road segments dr aining to streams were generally found to be ineffective or only partially effective at preven ting chronic sediment delivery to streams, while fillslope construction BMPs (beyond the immediate area of stream crossing fills) were generally

found to be effective.

Design BMPs for road drainage, specifically practi ces for locating and installing relief culverts,

were found to be effective at six of the new roads (55%), partially effective at four roads (36%), and ineffective at one road (9%). Eighteen percen t of the 49 individual reli ef culverts evaluated

at 5 of the 11 roads referred to above were found to deliver sediment and road drainage to streams via channel development or overland fl ow. Sediment transport distances below theseAssessment of Water Quality Impairments Related to Forest Roads Page 151 Contract # EP-C-05-066, TO # 0002 December 4, 2008

relief culverts ranged from 36 to 330 feet. Sixty- seven percent of all relief culverts monitored had channel development or distinct overland flow sediment plumes developed below their outfalls during the first one to three years following road cons truction. BMPs for construction

and stabilization of cutsl opes on road segments draining to str eams were rated ineffective at five of the new roads (46%) partially e ffective at four roads (36%), a nd effective at two roads (18%). The effectiveness of road construction practi ces was influenced by steps taken to control construction phase erosion and promote the estab lishment of vegetation on cut and till slopes, and to control ditch erosion. The majority of road construction sites relied on natural revegetation or dry grass seeding without mulc hing, and this was generally not effective in preventing chronic sediment delivery to streams. Fillslope stabilization and active haul road maintenance appeared to be effective.

4.4.12 Summary

As the cases above illustrate, there are wide variations in state efforts to monitor BMP implementation rates and effectiveness. Collectively, these state reports demonstrate that while compliance with forestry BMPs is high, most excu rsions are associated with roads, and that when road BMPs are not properly applied, sedi ment delivery to str eams is likely (NCASI, 2001b). However, even when BMP implementati on rates exceed 90% or higher, sediment delivery from roads can still occur. The quest ions then become: “How much sediment is delivered?” and “Will this much sediment impair aquatic resources?” Unfortunately, these questions are still difficult to answer. Whethe r current forest practice rules and BMPs will achieve the specific water quality targets of the Clean Water Act remains unknown (Rice, 1992).

4.5 Are Voluntary or Regulatory BMP Programs Effective?

Either type of BMP program (voluntary or regulatory) can be e ffective. Several factors have been used to compare and contrast regulator y and nonregulatory appr oaches to preventing nonpoint pollution from forest management s ources (Prud’homme and Greis, 2002). These include level of compliance, degrees of wate r-quality protection, costs to landowners, and program costs to the state. The evolution of “blended” BMP progr ams, which seek to capitalizeAssessment of Water Quality Impairments Related to Forest Roads Page 152 Contract # EP-C-05-066, TO # 0002 December 4, 2008

on the strengths of each approach, provide an indication that one kind of program may not necessarily be better than th e other. States with regulator y programs like Oregon are seeking incentives for voluntary stewardship, while stat es that based their programs on nonregulatory approaches now backing up these efforts with “bad actor” regulations or developing fully regulatory BMPs (Ice et al., 1997).

Different measures of implementation among st ates, reliability of these data, and other

differences and inconsistencies preclude objective comparisons between the effectiveness of voluntary and regulatory BMP pr ogram. One reason for the high rates of BMP implementation or FPR compliance reported for th e western states has to do with the regulatory framework under which foresters must operate. Oversight or approval of a management or harvest plan or, in some cases, an approved HCP is requ ired prior to any management activities taking place. For example, California requires approval of a THP before operations may begin. Washington requires application and notificati on regarding forest management ac tivities; the degree of detail or applicability of the state’s FPRs depends on which class of forest practices fall under which activity. Oregon’s notification prot ocols require the la ndowner or land manager to supply basic information on the type of operati on, its location, and the parties involved. Information provided

in the notification is used to determine whether or not a site inspection or technical assistance visit is necessary to avoid pot ential water quality problems. Ho wever, there is also some evidence that continually changi ng, detailed, and complex rules can also reduce compliance in some cases. Results from the 2006 BMP compliance survey in Wa shington appear to demonstrate this, as this state has some of th e most complex guidelines for forest management. Compliance with BMPs is higher in other west ern states (California, Montana and Oregon), where management requirements in the states’ FP Rs are less complex and have been in place longer. Mandatory programs also on average re port lower rates of compliance with BMPs guidelines, due in part to their complexity and strictness.

In the southeast region, mandatory programs repor t on average lower rates of compliance with BMPs guidelines (NCASI, 2007). Rates of BMP co mpliance reported in Kentucky and Virginia, regulatory and quasi-regulat ory states, are typically at the lo w end for the region. It is clear,Assessment of Water Quality Impairments Related to Forest Roads Page 153 Contract # EP-C-05-066, TO # 0002 December 4, 2008

however, that regulatory programs with mandatory BMPs often have larger monitoring and enforcement programs and, therefore, tend to have higher operating costs (Ellefson et al., 2006).

Hawks et al. (1993) compared Maryland’s regula tory with Virginia’s nonregulatory program. Neither approach was found to be clearly superior to the other in achieving BMP compliance or protecting water quality. Both states were reasonably effective in obtaining BMP implementation, but Maryland’s regu latory approach was more cost ly to landowners and to the

state.

Another evaluation by NCASI (1994) compared and modeled economic and non-economic costs and benefits of existing and hypot hetical regulatory scenarios in Virginia and Washington. The modeled regulatory program and the most aggressive nonregulatory program scenario were predicted to result in nearly equal water quality benefits. The projected costs of the regulatory program estimated to be nearly double those of the nonregulatory program.

Regulatory frameworks used by states to ensure mandatory implementation of BMPs and other FPRs can require substantial financial resources. These include tasks such as rule-making (e.g., California, Oregon, and Washington have forestry boards and staffs that assess and update state FPRs), permit approval, onsite in spections, and enforcement programs. Costs to operate these programs can be quite high on non-federal forest lands. For example, in 2003, states in the western region spent between $220,000 (Utah) and $13.8 million (California) regulating forest practices programs; these states had 337 full-time equiva lent regulatory staff, of which 35% were used by forest resource management agencies and 26% by air and wa ter pollution control agencies (Ellefson et al., 2006; NCASI, 2007).

4.6 How Often do States Revise Their BMPs?

There is considerable variation in how often states revise thei r BMPs. The most recent revision

date of each state’s BMPs is id entified in Tables 4-2 and 4-3; dates ranging from 1993 to 2003 were found. Some states like California, Wash ington and Oregon conti nuously revise theirAssessment of Water Quality Impairments Related to Forest Roads Page 154 Contract # EP-C-05-066, TO # 0002 December 4, 2008

BMPs and several states are currently revising thei r BMPs or have done so in the past 5 years. On the other hand, a few states are still operati ng under BMPs that are more than a decade old.

In California, implementation and effectiveness monitoring data have been used to revise BMPs. Determining which rules have the poorest impl ementation and effectiveness and the highest frequency of violations both provides input to the California State Board of Forestry (CSBOF) on needed rule changes and identifies training needs for CAL FIREs Forest Practice Inspectors, Registered Professional Foresters submitting THPs and Licensed Timber Operators (Ice et al., 2004). As an example of how the monitoring data have been used, the CSBOF adopted rule language in 2000 requiring FPR supervision of active timber operations based on information provided by the HMP (Ligon et al. 1999). Work shops on proper waterc ourse crossing design, construction, and maintenance were held in 2003 to provide traini ng needs identified by monitoring.

Washington State FPRs were establ ished in 1975 and have been revised 13 times (Holter, 2001). The most significant improvements for BMPs relati ng to fish habitat and water quality protection occurred in 1987 (the Timber, Fish and W ildlife Agreement), 1992 (cumulative effects assessment/Watershed Analysis), and 2001 (Watersh ed Analysis/ Endangered Species Act; Ice et al., 2004). For the past 15 years, an important feature of Washington’s forest management system has been the use of the adaptive mana gement approach to guide BMP development. Adaptive management requires the collection of information for feedback on system performance, and adaptive management approa ches are designed to utilize ongoing management as a test from which to learn (Ice and Whittemo re, 1998). Probably the two most useful examples of adaptive management monitori ng at the watershed scale are source searches and watershed analysis. Watershed analysis is defined as a stru ctured approach to develop a forest practice plan based on a biological and physic al inventory" (WFPB, 1993).

In Oregon, Department of Forest ry administrative rules continua lly evolve in response to scientific knowledge. Major revisions to the 1973 FPRs were made in 1978, 1983 and 1994 (FPAC, 2001).Assessment of Water Quality Impairments Related to Forest Roads Page 155 Contract # EP-C-05-066, TO # 0002 December 4, 2008

In Montana, rule improvements recommended by the Montana Environmental Quality Council (EQC, 1988) have precipitated several change s in nonpoint source management program for forestry, including formation of a Technical Committee to guide development of a set of statewide forestry BMPs. This committee incl uded industrial and nonindu strial landowners, logging contractors, Montana Water Quality Bureau staff, representatives of the USFS, and was led by the Montana Department of Natural Re sources and Conservation (Ice et al., 2004).

In Idaho, the rules of the Forest Practices Act require a “default” level of BMPs applicable across the state (NCASI, 2001b.). Every four years, the Department of Environmental Quality and the Department of Lands conducts an audit of the BMPs to determine if they were effective in maintaining water quality. Rule changes are developed to address in stances where practices have been found to be inadequate.

Florida first established BMPs in the mid 1970s. In 1992 a BMP technical advisory committee was formed and a BMP manual was published in 1993. The manual was revised in 1995 (FDA, 2004). Some forest road and stream crossing BMPs in the Florida manual appear to be outdated, at least in comparison to the we stern states. However, this can be a difficult judgment to make, given the differences in the nature of forest ry-related impacts between the west and the

southeast.

4.7 Do Existing BMPs Include the Most Tec hnologically Up-to-Date and Useful Practices Available?

BMPs are not uniform from one state to another, and in some states BMPs are based on older (pre 1980s) technology. In some cases, BMPs have not yet incorporated new research findings and/or lack long-term effectiveness studies (Ice et al., 1997). The low-cost, low-maintenance intermittent-use roads pioneered by Coweeta H ydrologic Laboratory in the 1960s is widely accepted and adapted to local conditions by gove rnment and industry land managers, and strongly recommended by st ate agencies with the aim of reducing sediment (Swift, 1988). The Coweeta research demonstrated outsloped ro ads and other BMPs (S ection 3.1.2.1) that are reflected in state BMP programs. However, some of these BMPs may not be suitable for all regions, locations or sites. Haupt et al. (1963) documented a case involving mountain haul roadsAssessment of Water Quality Impairments Related to Forest Roads Page 156 Contract # EP-C-05-066, TO # 0002 December 4, 2008

on granitic soils in Idaho in which severe ra instorms caused more damage to outsloped roads than insloped/ditched roads. Based on observe d slope failures, Hartsog and Gonsior (1973) recommended outsloping only where surfaces were relatively nonerodible. In some unstable areas and regions, especially in the Pacific Nort hwest, conventional BMPs for road construction may not be sufficient to prevent adverse eff ects on stream channels and fish habitat.

Designing and/or reconstructing st ream crossings to avoid divers ion potential, to accommodate natural disturbances, and to allow unrestricted passage of fish, sediment bed load and large wood, are examples of modern BMPs that have not been incorporated by many states. Several states still consider log cro ssings to be acceptable BMPs (Grace, 2002), although they are not generally recommended (Taylor et al., 1999). Fords ar e also generally perceived to have greater impacts on water quality than othe r crossings (Taylor et al., 1999) , yet are considered to be acceptable BMPs in many states. Fords introduce se diment into streams during construction and vehicle crossings, and provide mo re opportunity for runoff to flow down road approaches into

streams.

4.8 What Processes are Used to Address and Correct Failing BMPs?

The response of state forestry agencies to BMP violations or complaints varies widely. Some follow established, formal interagency agreements that can include referral to enforcement agencies. Other states have no formal process fo r follow-up or referral, but do refer some cases to other agencies. Information on the methods and mechanisms used by state forestry agencies to address water quality problems related to BMP ar e noted under the “other information” heading

in Tables 4-2 and 4-3. It should be reiterated th at when problem areas in state BMP programs are identified, the overwhelming response by the vari ous regulatory agencies is to strengthen education and training programs in the specific area identified. All state forestry agencies attempt to work with landowners to correct defici encies prior to referral to enforcement agencies (Prud’homme and Greis, 2002). Pers istent noncompliance can result in a variety of enforcement actions, which range from mandatory installation of BMP, fines, and orders to cease forestry

activities.Assessment of Water Quality Impairments Related to Forest Roads Page 157 Contract # EP-C-05-066, TO # 0002 December 4, 2008

States also use different mechanisms to iden tify and locate failing BMPs. Examples include public reporting of stream sedime ntation. Local observation of hi ghly-turbid streams has been reported to be one of the most important means of learning of problems or potential violations (Corner, 1992; Irland and Connors, 1994; Juul et al., 1990). A number of states acknowledge the role of citizen complaints (Corner et al., 1996) in identifying, locati ng and addressing nonpoint source pollution problems.

4.9 Is Concurrence or Approval by the State Agency Administering the Clean Water Act Required For: (a) Forest Road Bmps? (b) Fo rest Practice Rules Related to Roads and Water Quality? (c) Forest Operations or Pl ans Involving Road Construction and Maintenance?

In several states, agencies administering the CWA are notified of forest operations or plans involving road construction and maintenance. Ore gon and Idaho have forest practice notification programs that are designed to alert state agencies to pr oposed operations (NCASI, 2001b.). Notification allows for pre-harvest inspections wh ere there are priority risks and where special protection may be needed. In Oregon, where there are special risks associat ed with activities in areas with a high risk of landsli de or near fish-bearing streams and wetlands, written plans are required. The Oregon and Idaho FPRs also allow for special protecti on rules in watersheds that are water quality limited.

In California, it has been suggested that lead-a gency responsibility for approval of THPs and SYPs lies with the wrong agency (Reid, 1999), an d should be shifted from the Department of Forestry to the California Resources Agency. Sta ff of the relevant state departments (i.e., Water Quality Control Board, Department of Fish a nd Game, etc.) should be given authority for decisions falling within the purvi ew of those departments' areas of expertise. Reid noted that some Department of Forestry st aff members perceive their primar y mission to be to facilitate production of maximum sustained yield of high-quality forest products, Water Quality Control Board staff perceive their mission to be protectio n of water quality, and Department of Fish and Game staff perceive their mission to be maintena nce of fish and wildlif e populations. Some of these goals conflict with one a nother. Decision-making for THPs and SYPs is the responsibilityAssessment of Water Quality Impairments Related to Forest Roads Page 158 Contract # EP-C-05-066, TO # 0002 December 4, 2008

of the Department of Forestry, yet the most ge nerally valued and utilized "commodity" produced by California's forest lands is clean water.

4.10 What are the Circumstances Producing E ffective BMP Implementation? Case Studies of Successful State BMP Programs: Washington, Oregon and Idaho

Forestry BMP programs in the Pacific Northwest are quite advanced in relationship to other states. Forestry BMPs vary from state to state on the Pacific coast, and their detail and rigor seem to be related to the degree of urbanization and the economic importance of the forest products industry in each state (Rice, 1992). While some of the details may differ slightly for other regions, the fundamental issues and principl es that apply to the We st remain applicable across the country. Building on state FPR BMP- based systems, western states including Washington, Oregon and Idaho ha ve developed watershed anal ysis systems that address watershed conditions on a site-speci fic basis. Much of the material in this section was taken from NCASI (2001), which provides comprehensive descriptions of the FPRs in western states. Although aspects of these state programs and th eir implementation have been criticized (see Section 4.5), each of the programs described be low has developed analysis and management systems which address site-specific forest road impacts which vary widely within each state.

4.10.1 Washington Watershed Assessment Process

Writing watershed-specific rules has reached its most detailed level in Washington, where watershed analysis is used (Ic e et al., 1997). Washington’s watershed analysis approach to watershed management is based on biological an d physical inventories of watershed conditions. It is a collaborative process i nvolving resource scientists and managers representing landowners, agencies, tribes, and other interested citizens. Both the assessment and the management process based on assessment findings are highly structured and defined within the Forest Practices Act and its implementing rules, and are designed to be repeated and adaptive (NCASI, 2001).

In Washington’s system for management of road erosion and sediment delivery impacts, roads

are field inventoried and the data are used with simple spreadsheet based models that quantify erosion and sediment delivery in comparison to estimates of natural background watershedAssessment of Water Quality Impairments Related to Forest Roads Page 159 Contract # EP-C-05-066, TO # 0002 December 4, 2008

sediment delivery. When delivery is considered to be too high, an advers e condition exists that must be addressed with management prescripti ons designed to alleviate the condition. These prescriptions are developed by local land managers and agencies, must address the specific areas of hazard and resource concern identified by the scientific assessments, and are subject to public review and appeal prior to final acceptance of the plan.

4.10.2 Idaho Cumulative Watershed Effects Process

The objective of Idaho’s CWE assessment and forest practices management process is to lead landowners to conduct future forest practices ac cording to three “stage d” criteria (IDL, 2000b):

1. In watersheds where beneficial uses are not supported as a result of forest practices and are not improving, mitigation and rehabilita tion activities must be conducted in conjunction with current forest practice activities so that , in balance, a generally improving trend is maintained until a dverse conditions no longer exist.

2. In watersheds where beneficial uses are not supported as a result of forest practices but conditions are improving, activities must be co nducted in a way that does not interrupt this improving trend.

3. In watersheds where beneficial uses are s upported, forest practices will be designed to prevent loss of this support.

The Idaho assessment procedures are designed to detect the presence of adverse watershed or stream conditions, to identify cause s for the conditions, and to identi fy actions that will correct and prevent existing and potential future problems. The result of implementation of the CWE process in a watershed is the development of mandatory specia l rules for the watershed, called Cumulative Watershed Effects Management Practices , that are authorized by the state’s Forest Practices Act and are enforced by the Idaho Department of Lands. As in Washington, roads in

Idaho watersheds are inventor ied, and although based on a qualit ative rating of erosion and delivery of sediment to streams, road conditions leading to adverse instream conditions must be corrected until the qualitative rating score is redu ced to within the range considered to be acceptable.Assessment of Water Quality Impairments Related to Forest Roads Page 160 Contract # EP-C-05-066, TO # 0002 December 4, 2008

4.10.3 Oregon Watershed Assessment Process

The Oregon watershed assessment process is de signed to identify how natural processes and human activities affect fish habitat and water qua lity, and to evaluate the cumulative effects of land management practices over time. Although the pr ocess does not include development of site specific watershed management prescriptions , it provides the information necessary for development of action plans and monitoring strate gies for protecting and improving fish habitat and water quality. The assessment provides broad- scale screening and is developed by local citizens with some assistance from technical experts using the assessment manual’s “cookbook” procedures for compilation and evaluation of information about watersheds. The procedure concludes with development of a Watershed Condition Evaluation and Monitoring Plan. A standard list of Critical Questions is addre ssed for each of six watershed characterization

modules.

Road erosion and sediment delive ry are evaluated as a component of a broad sediment source

assessment that identifies where human caused sedi ment increases are most severe, as well as priority restoration opportunities. The assessment manual provides highly structured and organized procedures for evaluation of lands lide hazards, road surface erosion, and stream culvert capacity and condition.

The Oregon Department of Forestry (ODF) also c onducts watershed analysis projects in basins containing State Forest land. Thes e projects evaluate the inter actions between ODF management and a watershed’s physical and bi ological processes. The ODF wa tershed analyses are performed in several steps:



### y The analyst compiles available information to describe curren t watershed condition.



### y Based on this description, factors limiting im portant watershed functions are identified and assessed.



### y The analysts and ODF resource specialists determine whether riparian and aquatic strategies are addressing the appropriate c oncerns regarding proce ss and function within the watershed.Assessment of Water Quality Impairments Related to Forest Roads Page 161 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Information provided by watershed an alysis can be used to refine district implementation plans and, as necessary, contribute to a comprehensive review of forest management plan goals and strategies. In 2008, analyses were finalized for 5 watersheds: Elliot State Forest, Trask Watershed, Miami Watershed, Upper Nehalem a nd Wilson Watershed. As one component of these analyses, state-developed Rapid Watershed Risk and Current Condition Surveys were used

to evaluate the current effects forest roads ha ve on aquatic resources within a particular watershed, and capture attributes associated with roads and thei r potential envi ronmental risks (Duck Creek Associates, 2008).

4.10.4 Special Issue Management Systems

In some cases, management systems have evolve d around a specific issue or certain species of concern. Examples of this include Habitat C onservation Plans (HCPs), the Oregon Plan for Salmon and Watersheds, and Washington St ate’s Forest and Fish Agreement.

4.10.4.1 Habitat Conservation Plans

The ESA notes that it is unlawfu l to “take” endangered species, with the definition of “take” including, “...harass, harm, pursue, hunt, shoot , wound, kill, trap, capture or collect...” Regulations under Section 4 of the Act clarify that “harm” in th e definition of “take” includes “significant habitat modification” th at aresults in injury or death to the animal (50 C.F.R. section 17.3). In one of the few amendments to the 1973 ESA, Congress modified Section 10 in 1982 to permit “take” for listed species incidental to such otherwise lawful activities as grazing, farming, or logging (16 U.S.C. section 1539 (a)(a)(B)). Each application for such an incidental take permit must be accompanied by a HCP (16 U.S.C. section 1539 (a)(2)(A)). The process is intended to be proactive and creative, with th e landowner taking the init iative to obtain the HCP and suggest the habitat conservation measures designed to avoid take. The legal assurances provided by an HCP are not without cost – both in terms of th e cash outlay necessary for the completion of the agreement and the delays an d modifications to land uses that might be required in exchange for the HCP. The HCP fo r native fish species developed by Plum Creek Timber Company (NCASI, 2001) is one example of an HCP that addresses existing and potentialAssessment of Water Quality Impairments Related to Forest Roads Page 162 Contract # EP-C-05-066, TO # 0002 December 4, 2008

future road impacts through comprehensiv e assessment and inventory followed by implementation of forceful (and expensive) ro ad maintenance and construction requirements.

4.10.4.2 Oregon Plan for Salmon and Watersheds

Several “Evolutionarily Significant Units” of salm on and steelhead have been listed in recent years under the ESA in numerous rivers of coasta l and interior Oregon. U nder sponsorship of the state’s Governor, Oregon has developed its Plan for Salmon and Watersheds. The key elements of the Oregon Plan are:



### y An ecosystem approach that requires system atic consideration of the full range of attributes of aquatic health;



### y A focus on reversing factors for decline and m eeting objectives that a ddress those factors;



### y Use of adaptive management and a comprehensive monitoring strategy; and



### y Building citizens and constituent groups into the restoration process.

Several forest land initiatives have been impl emented, including development of the watershed assessment process (OWEB, 1999), development of standard road inventory and assessment procedures, and development of training material s for landowners, including the Forest Road Management Handbook (ODF, 2000). These procedures emph asize design and construction of culverts to ensure fish passage, along with road maintenance and repairs to prevent surface erosion, washouts, and road fa ilure associated landslides.

Several watershed assessments using the Oregon procedures have been completed and many more are in progress. Many members of the Ore gon Forest Industry Council and smaller forest landowners have voluntarily completed the required inventories and have initiated rehabilitation of road systems to address existing adverse circumstances (ODF, 2000).Assessment of Water Quality Impairments Related to Forest Roads Page 163 Contract # EP-C-05-066, TO # 0002 December 4, 2008

4.10.4.3 Washington Forest and Fish Agreement

In 1986, the timber industry, tribes, the state, and the environmental community agreed to resolve contentious forest pr actice problems through negotiations , resulting in Washington’s watershed assessment process and se veral stream and landscape resear ch efforts. As a result of research findings and common fi ndings within many of the completed watershed analyses, the Timber/Fish/Wildlife (TFW) program parties, expanded to include federal and local governments, began working together again to ad dress ESA listings, 660 streams included on the 303(d) list of water quality limited water bodie s, and the cost and uncertainty attendant upon timber acquisitions and harvest activities. Ag reement was reached and recommended to the

Forest Practices Board and the Governor’s Salmon Recovery Office in February 1999. The recommendations were subsequently adopted as Emergency Forest Practices Rules. These rules substantially modified the then-e xisting FPRs in such important areas as stream classification, riparian management requirements, management of unstable slopes, and road management.

Under the agreement and the subsequent Emergency Rules, the road management policy is to maintain or provide passage for fish in all lif e stages, provide for the passage of some woody debris, meet water quality standa rds, control sediment delivery, protect streambank stability, and

divert most road runoff to the forest floor. Perh aps the most comprehensive of these new rules is

that all landowners are now re quired to develop and submit fo r public review, and Washington Department of Natural Resources approval form al road maintenance and abandonment plans for their entire ownership and road system within specified time frames. Re quirements to inventory all stream crossing culverts and to replace or correct those with fish passage problems are included. Culverts not passing the now-required 100 y ear flood flow must be replaced at the end

of their useful life. The new rules also contai n comprehensive location, design, maintenance, and abandonment requirements for preven tion of both mass and surface erosion.Assessment of Water Quality Impairments Related to Forest Roads Page 164 Contract # EP-C-05-066, TO # 0002 December 4, 2008

5. SUMMARY AND CONCLUSIONS

In 2007, Great Lakes Environmental Center (GLEC) conducted a literature review and evaluated data to provide recent examples of water qualit y impacts from forest roads and to survey the effectiveness of forest road BMPs to prevent these impacts. This report summarizes these findings, focusing on three areas of interest to USEPA:

Section 2: Impacts of forest roads on water quality and aquatic resources.

Section 3: BMPs for forest roads (descriptions, effectiveness, shortcomings and costs).

Section 4: State BMP programs for forest roads.

This research builds on previous studies c onducted by USEPA, USFS, NCASI, the states, forestry and water quality scien tists, and other interest groups. Although much has been studied and written about forest roads, th eir relationship to water quality impacts, and the role of BMPs in mitigating these impacts, a number of conclusions have emerged from the process of reviewing and summarizing this literature. These are listed below:

• Potential effects of roads on water quality include increased loading of sediment due to erosion and mass wasting (landslides), in creased suspended solids and turbidity, increased sediment deposition and bed load, siltation of coarse streambed substrates, physical barriers to migration and downstr eam transport, and altered streamflow and pollution from other chemicals associated with road use.

• Adverse impacts of forest roads on aquatic ecosystems, especially anadromous salmonids, are well documented. These impacts arise from a number of factors: erosion and sediment delivery to streams, fine sediment accumulation, and obstructions to passage of fish and large debris. The great est impacts occur along the Pacific Coast and Northwest.

• National level assessments of water quality are based on state lists of impaired waters, the so-called 305(b) and 303(d) lists. These assessments re present the only available National data on the extent and causes of im pairment to rivers and streams, lakes, wetlands, and other waterbodies. The 2002 Na tional Water Quality Inventory lists silviculture as the 12 th leading source, responsible for impairment of 19,071 river miles; this represents 5% of impaired river miles.Assessment of Water Quality Impairments Related to Forest Roads Page 165 Contract # EP-C-05-066, TO # 0002 December 4, 2008

• Although the information in the National Assess ment Database provides a picture of state assessment results, these data cannot be us ed to compare water quality conditions between states or to identify trends in statewide or national water quality.

• Roads can have very different effects on wa ter resources depending on road size, design, location, construction, access, usage and main tenance techniques. Although most roads will have some effect on their watersheds, a sm all percentage of road area (or length) is often responsible for most of the erosion. A key to understanding this variation is the placement of roads in relationship to the erosion and sediment delivery potential of various points in th e forest landscape.

• The commonly-cited 80/20 rule ( 80% of the problems come from 20% of the roads) suggests that relatively few forest roads cause most of the problems.

• Soil losses and erosion occurring closer to a stream have greater potential to deliver sediment and lead to water quality impairment. In this regard, str eam crossings have the greatest potential to adversely impact water quality on the forest landscape.

• Adverse environmental effects from forest ro ads change over time and vary with season of construction and use, age, weather, kinds and intensity of maintenance, traffic level, and other location factors such as geol ogy, geomorphic location, soils and terrain.

There are a number of guiding principl es for forest road BMPs, including:

• Recognize and avoid high-erosion hazard areas.

• Minimize the total amount of landscape disturbed by roads, bare ground and soil compaction.

• Engineer stable road surfaces, drainage featur es and stream crossings to reduce erosion.

• Separate bare ground from surface waters and minimize delivery of road-derived sediments to streams.

• Provide a forested buffer around streams wh ich exclude roads and minimize crossings.

• Design and install stream crossings to allow pa ssage of fish, other a quatic biota, and large wood.

• Put BMPs in place to anticipate triggering events.

• Unless obliterated/removed, all forest roads, crossings and associated BMPs must be maintained.Assessment of Water Quality Impairments Related to Forest Roads Page 166 Contract # EP-C-05-066, TO # 0002 December 4, 2008

• Although silviculture BMPs are grounded in scie nce or are based on scientific principles, a lack of science to validate BMP effectiven ess is a shortcoming of many BMPs related to forest roads.

• Rating BMP efficiency is difficult because the performance of BMPs and their associated impacts vary considerably with geology, terrai n, watershed characterist ics, site locations and weather.

• The difficulty with rating BMP efficiency is th at the same practice on different sites, in different watersheds or even with differen t weather patterns, can result in different impacts.

• To maximize the performance of BMPs at a site, the BMP prescription must be customized to the setting, but customized BMPs require greater skill and effort on the part of the forest manager and knowledge of where the problems are located. Both increase the difficulty for states to dete rmine whether BMPs have been properly implemented. In this situation, performance standards that are realistically achievable should be used to set goals for the BMPs.

There are a number of recent promising i nnovations in forest road BMPs, including:

• Portable bridges, mats, pipe bundles, and altered logging equipment (e.g., wider tires, low tire pressure, dual tires).

• Development of methods to optimize BMPs.

• Management systems.

BMPs for forest roads fail to protect water quality for a variety of reasons, including:

• Lack of effective implementation.

• Erosion rates and mass failures can exceed cap ability of BMPs to prevent generation, transport and/or delivery of sediment to water bodies.

• Legacy roads and crossings (i.e., lack of main tenance, failure to upgrade and/or remove).

• Cumulative Impacts.

• Highly sensitive aquatic resources.

• Extreme storm events.

There are a number of ways to addre ss failing forest road BMPs, including:

• Improving inspection and maintenance practices.

• Identifying the location of failures.

• Determining which high-risk road s should be properly abandoned.

• Road reconstruction and upgrad ing to current standards.Assessment of Water Quality Impairments Related to Forest Roads Page 167 Contract # EP-C-05-066, TO # 0002 December 4, 2008

• Adding components to BMP systems.

• 15 states (Alaska, California, Connect icut, Idaho, Kentucky, Maryland, Montana, Nevada, New Hampshire, New Mexico, Ore gon, Pennsylvania, Vermont, Washington, and West Virginia) have de veloped regulatory programs that require permits or mandatory BMPs. Forest management programs in the western states are overwhelmingly regulatory.

• BMP implementation is largely voluntary in the other 35 states. This includes the southern states (Alabama, Florida, Georgi a, Kentucky, Louisiana, Mississippi, North Carolina, Oklahoma, South Carolina, Tenness ee, Texas and Virginia) although 3 states (Florida, North Carolina, and Virginia) have linked BMP implementation to other state regulatory programs, making them quasi-regul atory in some circumstances, and BMP implementation became mandatory in Kentucky in July 2000.

• 9 states have a nonregulatory BMP program w ithout enforcement. These states typically use incentive and education programs to ensu re pollution control and include states without a large timber industry or steep terr ain such as Illinois, Oklahoma, and Utah.

• 18 states have nonregulatory programs with enforcement where use of BMPs are not mandatory but enforcement action can be ta ken against polluters or landowners who refuse to implement proper BMPs.

• 8 states have combination programs that mix aspects of regulatory and nonregulatory programs.

• As the preceding summaries of state program s demonstrate, not all state BMPs are the

same.

For example:

• 20% of state BMPs do not address maintenance of roads.

• 80% do not address use of roads in wet weather.

• 48% do not address road closure.

• 30 states have conducted implementation and effectiveness monito ring of their BMPs since 2000.Assessment of Water Quality Impairments Related to Forest Roads Page 168 Contract # EP-C-05-066, TO # 0002 December 4, 2008

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TABLES

Table 2-1. Results of Keyword Searches in the TMDL Tracking System Database

Keyword(s) searched Type of TMDL Impairment (pollutant) Number of TMDLs

silviculture Point/nonpoint (Any) 155

silviculture, forest, timber, forestry Point/nonpoint sediment 127

(none) Nonpoint Sediment 91

silviculture, forest, timber, forestry Point/nonpoint turbidity 82

silviculture, forest, timber, forestry Point/nonpoint siltation 70

road, roads, timber Point/nonpoint sediment 70

road, roads Point/nonpoint sediment 70

forest road Point/nonpoint (Any) 52

road, roads, timber Point/nonpoint sediment 46

road, roads Nonpoint sediment 45

road, roads, timber nonpoint turbidity 36

forest roads nonpoint sediment 8

road, roads, timber nonpoint habitat alteration 1

road, roads, timber Point/nonpoint habitat alteration 2Assessment of Water Quality Impairments Related to Forest RoadsPage 202Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsControl And Mitigation Measures For Road ConstructionTemporary Stream CrossingsStream crossings can be designed and installed for temporary use and then removed after use. In some cases, portableand re-useable crossings are used. The streambed is restored following removal of the crossing.Portable BridgesPortable bridges made of wood, steel,and concrete can be used on haulroads and skid trails where permanentstructures are not needed. Bridges canbe installed and removed withminimal disturbance to thestreambank, channel, and adjacentRMA.Portable and temporary bridges makesuitable lower cost alternatives topermanent bridges, and they canreduce the environmental impactsassociated with culvert crossings,stream fords, and roads constructed todetour around crossings.Hinged steel bridge (8 m long):$14,205Concrete bridge (10.6 m long) :$11,500Glued-laminated bridge (9.1 m long):$16,100Stress-laminated timber bridge (9.7 mlong): $14,000Taylor (1994) estimated the haulingand installation costs of the gluedlaminated bridge to be $1000 percrossing. Using the bridge ten timesyields a cost per crossing that isequivalent to installing culverts.Log crossings and pole fordsLog crossings and pole fords aretemporary stream crossings that arecreated by placing logs in shallowchannels. The surfaceof log crossingsmay be improved with decking orwith log mats. Log crossings areremoved immediately after use orbefore the upstream end becomesclogged with sediment.Temporary culvertsTemporary placement of culvertsreduces the chance of culvert failure,and subsequent stream crossingfailure and erosion, compared topermanently placed culverts.There may be considerablesedimentation from a culvert crossingfrom the time of installation untilremoval. Culvert installation canincrease sediment loads (King 1981).Sediment loads 100 to 1000 timeshigher than normal have beenreported following culvertinstallations.Use of Cofferdams or StreamDiversions Around Construction SitesFlowing water is diverted around the construction site of stream crossings and excavations are not made in flowingwater. Instream flows are maintained. Excavation and equipment operation is kept out of streams to reduce sedimentyield which could cause turbidity and excess fines that may clog stream gravels and fill poolsAssessment of Water Quality Impairments Related to Forest RoadsPage 203Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsTiming Construction Activities NearStreams to Avoid Critical Periods forAquatic OrganismsConstruction activities near a stream can be timed to avoid disturbances that create increased sediment loads duringperiods when sensitive aquatic species are present or are moresusceptible to increased turbidity or suspended sediment.Pioneer RoadsPioneer roads are temporary access ways for construction equipment during construction of permanent roads. They areused to reduce the amount of area disturbed during road construction and to ensurethe stability of the roadway. Pioneerroads are confined to the surveyed permanent roadway and are fitted with drainage structures.Mulching, Seeding, and StabilizingDisturbed AreasAreas of disturbed and bare soil, including ditches, cut- and fillslopes, roads, landings, skid trails, fire lines, streamcrossings, and slides, are seeded and treated with erosion control practices. These can include includes planting trees,seeding, and applying mulch, hydromulch, erosion blankets, straw bales, filter fabric fences, and riprap.MulchingMulches protect the soil surface fromrain impact and help prevent surfaceseal formation until vegetation isestablished. Mulch improves soilconditions for seed germination bymaintaining infiltration capacity,preventing crust formation, shadingthe soil, and reducing evaporation.Research has shown that seeding andmulching effectively control erosionon road cutslopes and fillslopes.Effectiveness of each cover typeincreases as the percentage ofgroundcover increases (52 to 95%erosion reduction)Megahan et al. (1992) reported costsof $7,400 to $31,000 per acre.Vegetation EstablishmentEstablishment of vegetation ondisturbed areas provides a livingmulch which effectively reduceserosion and has advantages over adead or synthetic mulch. However, ittakes time for vegetation to becomeestablished and seeding is moreeffective when mulch is applied.Dense grass can be used in erosioncontrol of previously bare soils; 86 to100% sediment reductions with grass.Planting grass reduces erosion onlight traffic roads. Grassed roads had45% lower sediment yield than baresoil roads.Erosion BarriersErosion barriers such as straw bales,erosion filter fabric fence, rock dams,and geotextile barriers slow flowingwater and cause sediment deposition.The best performing slope-protectionproducts reduced sediment 84 to 93%compared to control (seeding withoutany additional erosion controltreatment).Channel and Ditch ProtectionChannels and road ditches can beprotected with channel liners, rockblanket, or riprap. Check dams can beconstructed in gullies and channels toprevent scour. Flexible channel linersare made of jute, coir (coconut fiber),straw, excelsior, plastic, nylon, andother synthetics.The best performing flexible channelliners significantly reduced sedimentyield 82 to 88% compared to control(seed alone).Fords (low water crossings)Fords can be used in place ofconventional culverts and bridgesLow-water crossings minimize theneed for fill, reduce or eliminateCosts vary with structure type, streamcharacteristics, and labor rates.Assessment of Water Quality Impairments Related to Forest RoadsPage 204Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostswhere the streambed is firm, banksare low, and the water is shallow.Simple fords are made of crushedrock, rock-filled gabions, or concretestructures.culvert and bridge costs, and havelow maintenance requirementsMilauskas (1988) provided thefollowing cost estimates of materials:Natural fords, using concrete barrierscost $130 to $160 per meter; Pavedfords (Cast-in-place concrete) wouldcost $260 per meter.Trash Racks (Debris ControlStructures)Trash racks are used to trap woodydebris and trash before they can pluga culvert. Designs vary with materialsavailable.Trash racks are located upstream ofculverts, to reduce the risk andlikelihood of culvert plugging andfailure by woody debris and sedimenttransported down a stream channel.May prevent fish passage.Increasing Capacity at ConstructedCrossingsThe flow capacity of bridges andculverts is increased to reduce theprobability of road washouts in areaswhere there is a problem of pluggingfrom large wood, debris andsediment.Increasing the clearance underbridges and using larger culvert sizesallow debris to pass that mightotherwise result in a crossing failureand road washout. Oversizing theculvert increases the expected life ofthe crossing. Increasing culvert sizemay reduce low-flow fish passage incertain situations.There are added costs of designupgrading and additional materials.However, these costs may be offsetover time if they result in reducedroad washouts and maintenance costs.Diversion-Proof CrossingsStream-diversion potential atcrossings is eliminated byconstructing crossings at right anglesto the stream and by designing bothapproaches to grade into the stream.By grading the road toward thecrossing, failure of the culvert byblockage or overflow does not divertdownslope but flows with thechannel, potentially removing onlythe road prism.If the stream channel is diverted intothe road, ditch, or skid trail during astorm flow, the diverted channel maycut gullies into roads and hillslopes.This may lead to debris torrents anddelivery of large sediment loads tostreams. Failure dips in the road canbe constructed at stream crossings toprevent crossing failure and streamdiversion.Costs to develop diversion-proofcrossings include design and planningas well as extra construction costs forgrading toward the stream.Reconstruction costs followingfailures and diversions can oftenexceed the originalconstruction costs.Benched Slopes (Terraced Slopes)Level benches or terraces areconstructed to reduce the amount ofsoil leaving the cutslope. Eroded soilis deposited on the level part of thebench instead of being transported offthe slopes.Terraced cutslopes reduced sedimentproduction by 86 to 94%.Costs can be estimated from the costof operating the equipment to buildbenches.Minimizing Sidecast MaterialSidecasting of road cut material iskept to a minimum to reduce theSidecasting road constructionmethods are not suitable on steep orAssessment of Water Quality Impairments Related to Forest RoadsPage 205Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsamount of bare soil that is exposedand to reduce the volume ofuncompacted fill material on unstablelandscapes where mass erosion is aproblem. This practice is intended toreduce sediment sources from roads.moderate slopes near stream channelswhere loose material could saturateduring wet weather and slide furtherdownslope.Summaries of landslide inventoriessuggest that new road constructionmethods, including the use of fullbench roads as opposed to sidecastroad construction, had resulted infewer road-related failures.Full-Bench/End-Haul ConstructionFull-bench and end-haul constructionmethods involve cutting the full widthof the roadbed into the hill slope. Cutmaterial is hauled to a suitabledisposal area. These methods are usedwhere there is a high probability offillslope failure and sediment deliveryto fish-bearing waters if sidecastmethods were used. End-hauling isalso used to prevent sidecast enteringfloodplains, wetlands, and othersensitive sites.Many landslides in steep areasoriginate in roadfill. Full-benchconstruction eliminates fillslopes andcan reduce slope failures originatingfrom roads. Road stability isimproved by full-bench constructionon slopes in excess of 55%. Thismethod reduced the area of bareslopes prone to erosion.There is an additional cost of endhauling and providing stable wasteplacement since a larger amount ofhillslope is removed in full-benchconstruction.Avoiding Incorporation of LargeOrganic Material in Road Fill/BaseIncorporation of slash, logs, and otherlarge organic material in landings androads can create an increased risk oflandslides Decomposition of theorganic matter can result in loose fillwhich is subject to liquefaction andfailure.Road Surfacing (Gravel, CrushedRock, Lignosulfonates, Asphalt)Forest roads are surfaced with gravel,rock, asphalt, or other suitablematerials to provide bearing strength,and to reduce deterioration anderosion of the traveled way. Coveringroads with asphalt or gravel caneffectively reduce the amount ofsediment produced.Swift (1984b) demonstrated thatcovering roads with a 15 cm layer ofcrushed rock reduced sediment lossesby 78%. Kochenderfer and Helvey(1987) showed an 87% reduction insediment yield from roads coveredwith a 15 cm thick layer of “3 in.clean limestone rock,” compared tobare soil roads. The authors noted thatrock type affected performance.Less information is available forCosts vary with availability ofmaterial and distance of transport.Swift (1984b) estimated thatsurfacing roads in the southernAppalachian Mountains with 15 cmof crushed rock would cost $6,000per km. Kochenderfer and Helvey(1987) estimatedthe cost forconstruction of unsurfaced road inWest Virginia to be $13,000 per km;surfacing with 15 cm of crushed rockAssessment of Water Quality Impairments Related to Forest RoadsPage 206Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostssediment reductions for other roadsurface treatments.Burroughs andKing (1989) report that dust oilreduced sediment yield by 85.3% andbituminous surface reducedsediment yield 96.6%, compared tobare soil roads.would cost an additional $16,000 perkm.Daylighting RoadsTrees and vegetation that shade theroad are removed in order to“daylight” roads where there aresections of road that are slow to dry.Removing tree canopy near streamsmay violate SMZ.Wet roads are subject to rutting,which concentrates runoff and leadsto increased sediment yields.Costs of daylighting roads areassociated with the removal of treesand vegetation.Maintaining or Planting Trees andWoody Species on Disturbed or SteepAreasNative woody species are planted ondisturbed areas and steep slopes,including cut- and fillslopes, closedroads, landings, skid trails, fire lines,stream crossings, and slides. Mulch,hydromulch, erosion blankets, strawbales, filter fabric fences, and riprapmay be used to provide soilprotection until trees are established.A buffer strip of trees can be leftabove the cutslope and below thefillslope to help stabilize slopes.Trees, shrubs, and grasses providetwo functions for disturbed areas. Incertain landscapes, tree roots canmarkedly increase slope stability. Inother cases, plant foliage and litterprovide cover and resistance tosurface erosion.Weaver et al. (1987) provided thefollowing cost estimates fromwatershed rehabilitation work done atRedwood National Park: Handplanted trees: $0.10 each seedling;Hand-planted Shrubs: $0.12 - 0.35each shrub. Seed, fertilizer, etc. is anadditional cost.Outsloping RoadsOutsloped road sections can be usedto shed water on moderate slopes andlow-volume roads,on closed anddecommissioned roads, landings, andskid trails. Outsloping is analternative to insloping with inboardditches and frequent cross drains.Outsloped roads are less likely thanditched roads to have catastrophicfailure, because the entire roadsystem is designed to drain, assumingthere is adequate maintenance to keepthe road tread rut free. Outsloping isbecoming an increasingly attractiveoption in locations where minimalmaintenance can be expected. Severerainstorms caused more damage tooutsloped roads than to inslopedroads on mountain haul roads ingranitic soils in Idaho.Weaver et al. (1987) estimated costsfor outsloped roads and landingsduring watershed rehabilitation inRedwood National Park. A bulldozerand a dragline crane outsloped twolandings at a total cost of $16,400.Outsloping during road obliterationcost $5665 per km.Road Dips (Broad-Based Dips,Rolling Dips)Broad-based dips and rolling dipsdrain water from the road by creatingMegahan and Ketcheson (1996)found shorter downslope sedimentAssessment of Water Quality Impairments Related to Forest RoadsPage 207Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsa reverse grade and an outsloped dip.Dips are used in place of ditch reliefculverts. Broad-based dips areconstructed by scooping out a shallowdip on the upslope side and buildingup a short reverse grade (about 3%)on the downslope side of the dip, witha berm crossing the ditch. Rollingdips are usually used on steepergradient roads (up to 15%, althoughdifficult when>10%) and areconstructed by creating a short 3 to8% reverse grade and a dip that isshorter and deeper than a broad-baseddip. Rolling dips are usually usedduring road construction and in roadclosure after hauling and not whenthe road is actively being used forhauling.travel distances for “rock drains”versus relief culverts.Water Bars (Log Bars, Earthen Drains,Turnout Ditches)Waterbars are supplemental drainagestructures not used during active loghauling. A water bar consists of acombination of berm and troughconstructed to divert runoff from aroad or trail onto vegetated areas orother stabilized outflow.Water bars function as cross drainsand are very effective at removingwater from roads and trails. Diagonalwater bars and ditches are moreeffective in reducing soil erosion onskid trails than are slash dams andslash mulches. Water bars and crossditches are effective because theydivert water off the trail and reduceslope length.Lickwar, Hickman, and Cubbage(1992) estimated thatwater bars weremost expensive of the six evaluatedBMPs that are used in the South.Based on an aggregate sample of 22timber harvests with an average ofone water bar per 5.4 acres, theauthors found that water bars cost anestimated $20 per water bar (1987dollars).Stabilizing Cutslopes and FillslopesSeveral construction methods areused to overcome the instability ofslopes, to repair slides, and tocorrect incipient slide conditions.Failure of road fill sections and roadcutslopes can deliver sediment tostreams or deposit loose sediment inditches and block culverts which canlead to road failure. Small rockbuttresses can be constructed at thefoot of a cutslope to stabilize theReinforced soil walls and fills havebeen successfully constructed fromtreated timber and geogrids; straw-,soil-, manure- and seed-facedreinforced fill; and fiberglassreinforced fill (Burke 1988).McNemar (1989) determined that ageogrid retaining wall was the mostcost-effective method to repair a steepfill slide.Porior (1991) used logs to face oneMcNemar (1989) reported thatgeogrid material to repair a slide 14 mlong and 2.4 m high cost $700. Othercosts were not specified but includedbackhoe work, dump truck hauling,stone, seed and mulch, and netting.Porior (1991) constructed a 15 m longand 2.4 m high log-faced chain-linkretaining wall for $3500. A 9.1 mlong and 2.4 m high hay-bale-facedchain-link retaining wall wasAssessment of Water Quality Impairments Related to Forest RoadsPage 208Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsslope from sliding and undercutting.Geotextile filter fabric and chain-linkfencing are used to construct earthenretaining walls. These walls are facedwith a variety of materials includinglogs, hay bales, and used tires.Bioengineering techniques are usedthat incorporate live and deadmaterials in slope-stabilizingmethods.chain-link retaining wall and used haybales to face another in road fillfailures.Keller and Cummins (1990)demonstrated that tire retaining wallscan be used to provide quick, easy,and inexpensive repairs to failedslopes.constructed for $1300.Keller and Cummins (1990)constructed a tire-faced geotextilereinforced wall for $183 per squaremeter.Burke (1988) estimated theconstruction cost of treated-timberfaced walls at $151 per square meterof facial area.Relief Culverts, Cross Drains, DitchesRoad ditches and cross drains areinstalled to control surface andsubsurface runoff from trails androads. Road drainage structuresinclude cross drains and waterdiversion structures.Cross drains carry water from oneside of the road to the other.Commonly used cross drains includepipe culverts, open top culverts,broad-based dips, rolling dips, waterbars and flexible belt diverters.Where necessary, drain-outflow wateris spread and directed onto stablevegetation, rock riprap, or other outletstructure.Proper cross drain sizing and spacinghelp to minimize surface erosion,saturation of road fills and thedistance of sediment transport belowdrains. Proper drainage helps keep theroad surface dry and structurallysound. The closer the spacingbetween cross drains the lower the rillerosion (50 to 97% control reported)of the road surface. Effective spacingdistance decreases with steeper roadgradients and with lower topographicposition (Packer, 1967). Decreasingthe drainage structure spacing from15 to 8 m resulted in a 62% decreasein erosion on skid trails with 20 to30% slopes (Kidd, 1963).The installation of frequent culvertcross drains can reduce the number oflandslides, the volume of material lostin mass erosion, and sedimentdelivery to streams from roadassociated landslides originating inroad fills (Megahan, Day, and Bliss,1978). Culverts will either plug orcorrode with time. Such failures canresult in debris torrents and streamdiversions and severe damage tohillslopes and stream channels.Therefore, it is necessary to regularlyCosts include machine time forexcavation and construction as wellas extra maintenance expenses.Material costs include culverts, rock,downspouts, outlet structures, trashracks, and other necessary material.Assessment of Water Quality Impairments Related to Forest RoadsPage 209Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsclean and eventually replace orremove culverts to prevent failures.Belt Diverters and Other SurfaceWater DeflectorsSurface water deflectors constructedof rubber belt (or PVC belt) are usedto divert water from forest roads onsteeper grades where dips are lesseffective. Strips of conveyor beltimbedded in the road surface stand upto intercept water flowing down theroad and carry it to a stabilizedoutfall. The belt is flexible so that itwill flatten to allow tires to pass andthen rebound to upright.Surface water deflectors effectivelyreduce erosion on roadways and areespecially suited for medium- to lowvolume roads with steeper grades(Rossman 1991). Effectivenessdepends on spacing betweenstructures, as described in Section4.21 on relief culverts and ditches.Rossman (1991) provided thefollowing costs for structures:Two-ply conveyor belt: $11.50 permeter; Rubber skirting: $8.22 permeter. Typical installation costs $250.Contractor low bid prices for threecontracts were $16, $30, and $66 permeter.Removing Direct Entry CulvertsDirect entry culverts deliver sedimentand water directly to streams wherethey can be routeddownstream. Thisminimizes opportunities for spreadingand settling of sediment andredistribution and infiltration ofrunoff. Furniss, Flanagan, andMcFadin (2000) concluded that directentry culverts are an important sourceof sediment to streams.While there are no watershed-scaletests of the effectiveness of directentry culvert removals, NCASI(1986) estimated that effectiveness(reduction in suspended sedimentdelivery from road drainages) isapproximately equivalent to thereduction in area contributing todirect entry.Costs involve placement andreconstruction of alternative drainagestructures to divert runoff from directentry culverts. The cost ofreconstructing culverts can often beseveral times the cost of installingthem at the time of initial roadconstruction.Controlling Erosion from DrainOutletsOutfall protection is installed belowdrains including riprap, rock-filledpipe, rock gabion, and log-rubblespreader (WDNR, 1997). Rock andother coarse materials are used toabsorb energy of flowing drainagewater. Synthetic erosion blankets areused as channel liners.Sedimentation Basin (Settling Basin)Sedimentation basins areimpoundments that are designed toreceive runoff and remove suspendedsediment before the water isdischarged to an outlet.Sedimentation basins may be used totreat sediment-laden runoff from roadWhile the opportunities for usingsedimentation basins in normalforestry operations may be limited,this practice is effective in retainingsediments and thus preventing theirentrance into aquatic ecosystems.Fennessey and Jarrett (1994)Assessment of Water Quality Impairments Related to Forest RoadsPage 210Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsand landings, gullies, quarries, pits,mines, and other high erosion sites.reviewed the literature oneffectiveness of sedimentation basinsand cite a range of 75 to 95%effectiveness for urban andconstruction sites. They emphasizethat this is “highly dependent on theinfluent particle size distribution.”Filter Windrow (Brush Barrier, SlashWindrow)Filter windrows are constructed ofslash (from road clearing or logging)placed at the toe of newly constructedor otherwise eroding fillslopes. Slash,consisting of tops, limbs and brushthat have been cleared from rights-ofway, is conserved and stockpiled atappropriate sites. Large logs areanchored against stumps, rocks, ortrees at the toe of the fillslope. Slashis placed either by machine (backhoe)or by hand on the bottom of thefillslope toe, upslope of the anchorlog, to form a neatly compactedwindrow. Filter windrows are alsoused at outlets of culverts, diversionditches, water bars and dips. Slash isplaced at outlets to slow runoff andtrap sediment diverted and drained offroads.Much of the sediment transported inrunoff from roads and road fill can betrapped in a filter windrow. Thepractice decreases runoff velocity andreduces sediment delivery to waterbodies. Effectiveness is measured astrapping efficiency and distancetraveled of the definable sedimentplume. Average sediment removalefficiency is about 50%, but widevariations are reported. Filterwindrows reduce the distance ofsediment flows below fillslopes;effectiveness of treatments with filterwindrows increased as slope percentincreased compared to treatmentswith no filter windrowsControl And Mitigation Practices For Road Operation And MaintenanceControlling Traffic (Closing Roads,Restricting Access, Wet WeatherTraffic, Seasonal Roads)Traffic is restricted on certain forest roads by one or more practices in order to prevent road deterioration and to preventerosion and sedimentation. The traffic control practices androad upgrading practices used depend on local conditionsand road management goals. Access may be blocked using gates, guard rails, concrete barriers, pole fences, pipes,natural onsite materials (logs and rocks, water bars), or vegetative plantings. When a road is no longer necessary ordesired, it can be obliterated.Assessment of Water Quality Impairments Related to Forest RoadsPage 211Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsClosing Roads“Closed” roads are temporarilyremoved from use and are retainedfor future use, but are not obliterated.They may require periodic inspectionand maintenance. As part of theclosing process, roads may beupgraded according to potentialimpact to riparian and aquaticresources. Upgrading can includeimproving stream crossings for fishpassage and stormflow, outsloping,stabilizing fills, and installing waterbars and cross drains. Roads may beseeded and mulched.“No traffic” control roads had anorder-of-magnitude lowersediment concentration than roadswith traffic.Moll (1996) provides the followingcosts for access control:Closure using onsite materials(Rocks, logs, water bars, slash piles,etc.): $50 – 500;Vegetative Plantings (Trees, shrubs,mulches, grasses): $100 -$1000.Imported Material (fences, gates,guardrails, concrete barriers): $200 -$2000;Pole Fences (poles with protectivemetal strips): $500 - $5000.Closure Devices (telescopic tubing,pipe and well casing): $500 - $5000;Road Obliteration (recon tour roadjunction or entire road): $2000 -$5000 km of road.Restricting AccessAccess iscontrolled to restrictunsuitable and nonessential traffic.Restricting access limits erosion andsedimentation becausesediment yieldfrom the road surface increases withtraffic volume. Sediment yield can bereduced by 75% (light vs. heavytraffic).Wet Weather TrafficWet weather traffic may be restrictedto prevent rutting and sedimentation.Accelerated erosion increases inproportion to traffic. Sedimentyield increases one to two times whena road becomes ruttedSeasonal RoadsIn cold climates, certain roads mayhave traffic restricted to times whensoils are frozen.Temporary road closures areparticularly important for roadsdesigned for seasonal use only. Forexample, unsurfaced roads in theCalifornia Sierra Nevada Mountainscan be used during the summer whenprecipitation is low and soils are dry.Extensive rutting and erosion wouldoccur if these same roads were usedin the winter (absent frozen soil orsnow cover), especially if used forpurposes other than log hauling andwhen maintenance is absent.Assessment of Water Quality Impairments Related to Forest RoadsPage 212Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsLowered-Pressure Truck Tires(Central Tire Inflation)Trucks can be equipped withlowered-pressure tires and central tireinflation to reduce ground pressure onlogging haul roads, thereby reducingrutting, sediment yield, and roadmaintenance. Central tire inflation(CTI) allows the operator to changetire pressure between loweredpressure on haul roads and higherpressure on paved roads.Lowered-pressure tires effectivelyreduce sediment losses from roads(Foltz 1994). Using lowered-pressuretires on rock-haul trucks in southeastAlaska reduced rutting depth by 78%and reduced road grading by 85%compared to use of high-pressure tires(Brunnette and Newlun, 1988).Brunnette and Newlun (1988)reported that the cost of changing tolowered-pressure off-highway tiresfor four rock haul trucks was$49,000, or $12,250 per truck, andincluded tires, tubes, and wheels.Cost savings occurred in reducing thenumber of road grading operationsfrom daily to weekly.Road Maintenance (Grading)Road grading removes rills and rutsthat can speed the deterioration of theroad surface and grading conservesthe road surface by returningmaterials from the side of the roadback onto the traveled way. Thisrestores the road surface for goodvehicle travel, helps maintain truckproductivity, and minimizesmaintenance costs. Grading schedulesand spot grading can improveefficiency since excessive roadgrading is costly and can bedetrimental to the road prismstability.There is conflicting information in theliterature on the effectiveness of roadgrading in conserving the road prismand in preventing erosion andsediment yield. Megahan (1988)reported that long-term road erosionwas inversely proportional to roadmaintenance. Regular grading canremove rills and ruts that degraderoads. However, grading can initiatean episode of surface erosion byloosening an armored surface.Effectiveness and efficiency can beimproved by moving from anautomatic (e.g., everyday) gradingschedule to one that is based onfrequent inspections and that usesspot grading and a flexible scheduleMost of the cost of grading isassociated with operator and machinecosts. Provencher and Me’thot (1994)demonstrated that machine hourscould be reduced by more than 30%by switching from an automatic orsystematic grading program to onethat uses spot grading and flexiblescheduling based on variables such asslope, shape of road segments, andtraffic.Assessment of Water Quality Impairments Related to Forest RoadsPage 213Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsInspecting Roads (Road Survey,Erosion and Landslide Inventories)Roads are inspected at regularintervals, especially during orfollowing large rainfall or snow meltevents. Road inspections can includean inventory of existing and potentialerosion and slope failures on allroads. Inspections can be used toprovide information about potentialsediment sources from roads forplanning watershed restorationprojects. Skid trails, landings, andobliterated roads are also giventhorough inspections.Culverts need to be located and theircondition checked for proper sizing,corrosion, separations, bends, andbreaks. Culvert inlets and outletsshould be checked for plugging,upslope debris, shotgun outlets, andbarriers to fish passage. Crossing fillsare inspected for diversion potential,condition, and volume. Roadinspection may also include a surveyof mass erosion potential includingfailure indicators in the cutslope androad surface, location of tensioncracks, and the potential for deliveryof sediment from incipient failures.Piehl, Pyles, and Beschta (1988)demonstrated the effectiveness ofroad inspections in a random surveyof stream-crossing culverts in theOregon Coast Range.Harr and Nichols (1993) documenteda road condition survey in CanyonCreek Watershed, Washington thateffectively identified road upgradeneeds including ditch relief, largerculverts at crossings, ditch cleaning,improved culvert gradients andalignments, and installment offlexible downspouts on culverts. Thesurvey also identified roads thatsubsequently were chosen for closureand decommissioning.Costs include labor cost of personnelfor inspections.Control And Mitigation Measures For Temporarily Putting-To-Bed, Decommissioning, And Obliterating RoadsTemporarily Putting-to-Bed,Decommissioning, and ObliteratingRoadsThere is a continuum of practices for temporarily putting roads to bed or completely decommissioning and obliteratingroads that can be used to decrease the costs and environmental impact of forest roads. These procedures are used toreduce road maintenance costs, to rehabilitate watershedsand associated wildlife and fish habitat, and to enhanceaesthetics of forested landscapesAssessment of Water Quality Impairments Related to Forest RoadsPage 214Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsPutting-to-Bed/DecommissioningPutting a road to bed can involveclosing access, reseeding the roadsurface, removing temporary streamcrossings, and opening drainagestructures that may fail. The road isput into an erosion-resistant conditionbut can be re-opened at a later datewhen access again might be neededHarr and Nichols (1993) documentedthe practices used and the overalleffectiveness of decommissioningforest roads as part of a watershedrehabilitation project in northwesternWashington aimed at improving fishhabitat and reducing flood hazards.The road decommissioning workstabilized fills, removed streamcrossings, recontoured slopes, andreestablished drainage patterns.During a 50 yr rain-on-snow event,the decommissioned road sectionswere largely undamaged compared tountreated sections and to nearbymainline haul roads that wereseverely damaged.Harr and Nichols (1993) provided thefollowing cost estimates for severallevels of road decommissioningwork: Insloped, water bars rebuilt,dips at draws, sidecast pullback:$1615/km; Extensive alder clearing,extensive sidecast pullback,recontoured landings: $4154/km;Clearing of trees and brush, sidecastpullback, built water bars: $3798/km.ObliteratingRoad obliteration is the removal ofthe road from the landscape.Obliteration goes farther thandecommissioning in restoringhillslopes, natural drainageways, andvegetation. Obliteration is intended toeliminate future road maintenance.The road prism is obliterated andreturned to a naturally functioningcomponent of the landscape.Vegetation is restored by sitepreparation, seeding, planting woodyplants, fertilizing, mulching, andencouraging naturalregeneration.There has been a large effort atRedwood National Park to restorewatersheds that had been logged andthat had poorly constructed roads,triggering landslides and severegullying. Several creeks had receivedenormous sediment loads and floods,and sediment threatened some of thelargest trees in the park. Weaver et al.(1987) documented the wide varietyof labor-intensive practices and heavyequipment used to obliterate roads,restore watershed hydrology andvegetation, and to repair erosiondamage.Weaver et al.(1987) provideextensive cost information for roadobliteration work in RedwoodNational Park. Average obliterationcosts ranged from $21,627 to$74,580/km of road (1979 dollars).Control And Mitigation Measures For Wetland OperationsAssessment of Water Quality Impairments Related to Forest RoadsPage 215Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsMaintaining Flow through RoadsMaintain flows using porous fills,culverts, and bridges and constructroads at ground level. Wetland roadsand crossings are kept to a minimumand are constructed at natural groundlevel where possible. Where fill isnecessary, roads are built on porousfills in order to maintain naturalsubsurface flow regimes. Fillsegments have culverts and bridgesthat allow cross drainage. Culvertsand bridges are installed so they donot interfere with duration, direction,or magnitude of flows.Only qualitative reports are availableon the effectiveness of maintainingflow through roads.Cost information is not currentlyavailable but would include thefollowing: culverts, bridges, andfords; fill gravel and crushed rock;road relocation costs; and, removal offills and crossings.Diverting Runoff from CrossingApproachesRoad approaches to wetlands aredesigned so that sediment deliveryfrom the road is diverted beforeentering the wetland. Water bars,dips, turnouts, and other crossdrainage structures are used to guiderunoff to a stable outfall. Erodingditches can be treated with rockcheck-dams, rock blanket, or suitableflexible channel liner. Design andconstruct ditches that are wide,shallow, U-shaped or flatbottomed, and well vegetatedMinimizing Rutting on WetlandRoadsOperations are ceased on forest roadswhen rutting becomes excessive.Roads are closed with gates or otherbarricades.The presence of wheel tracks onroads can increase rill erosion byconcentrating runoff instead ofshedding it (Foltz and Burroughs,1990; Elliot, Foltz, and Remboldt,1994). However, research in somestudies has found little connectionbetween rutting depth and soilmovement.Assessment of Water Quality Impairments Related to Forest RoadsPage 216Contract # EP-C-05-066, TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsUsing Temporary Roads andRemoving FillsUse temporary roads and crossings.Remove temporary fills andstructures to restore wetland flowpatterns. End-haul fills to nonwetlandsites.Berms on Wetland RoadsThe creation of a continuous filterberm along flat wetland roads allowsfor infiltration of surface runoffthrough the berm and keeps sedimentfrom being transported to nearbywetlands or streams.Appelboom et al. (1998) testedseveral control options to reducedelivery of road sediments from awetland road to adjacent wetlands andstreams. They found that a graveledroad surface reduced sediment loss by61%. A grass strip along the side ofthe road reduced sediment loss fromthe road by 56%. However, acontinuous berm filtered sedimentfrom the road and reduced sedimentloss by 99%.Water Level ManagementIn wetlands where drainage channelsare present, riser boards can be usedat ditch outlets to provide somecontrol over the water levels in thewetland. Careful operation of theseoutlets can create soil moisturestorage and can reduce stormflowsand material losses from the site.As early as 1980, Hollis, Fisher, andBeers suggested that drained forestwetlands might actually moderaterunoff and sediment loss from sitesby creating soil moisture storage.This, along with rapid revegetationand careful application of BMPs,could avoid serious sediment losses.Suspending Operations When RuttingBecomes ExcessiveHarvesting operations are haltedwhen soil rutting becomes excessive.Depending on the climate and soilcharacter, skidding can be done whensoil compaction potential is low, suchas when soils are dryor snow covered and frozen.Wetland surface and subsurface flowsthat can decrease site productivity orcause sediment delivery to water.Aust, Lea, and Gregory (1991) reportthat “bogging down” and excessiverutting due to skidding on wet sites inthe Southeastern Coastal Plain can beminimized by one-pass skid trails.Welch et al. (1995) recommendscheduling harvest during the drierseasons of the year or when soils arefrozen in order to avoid rutting.ssment of Water Quality Impairments Related to Forest RoadsPage 217TO # 0002December 4, 2008Table 3-1. Best Management Practices for Forest Roads: Descriptions, Measures of Effectiveness, and Costs. (source:Gallagher et al., 2000)Best Management PracticeDescription of PracticeMeasures of EffectivenessCostsOperating Equipment on FrozenRoadsLog hauling is restricted to periodswhen roads are frozen in order toreduce rutting and sedimentation.Operating on frozen roads helps toprevent rutting. Sediment yieldincreases one-to-two times when aroad becomes rutted.Mitigation And Enhancement Measures For Fish HabitatFish PassageStream-crossingculverts, bridges, andfords are designed and maintained toallow fish migration, and to pass aminimum peak flow.Robison (1997) discusses advantagesand disadvantages of alternatives forfacilitating fish passage throughculverts. Improvement of fish passageis the most poorly documented andevaluated of all stream habitatimprovement techniques (Hall andBaker, 1982).Relative costs for fish passageimprovement options are presented inRobison (1997) and Murphy andPyles (1989).AsseContract # EP-C-05-066,Assessment of Water Quality Impairments Related to Forest Roads Page 218 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 3-2. Effectiveness of Surface Erosion Control on Forest Roads (Source: US EPA, 2005, Adapted from Megahan, 1980, 1987)

Stabilization

Measure Portion of Road Treated Percent Decrease in Erosion a Hydro-mulch, straw mulch, and dry seeding b Fill slope 24 to 58 Tree planting Fill slope 50 Wood chip mulch Fill slope 61 Straw mulch Fill slope 72 Excelsior mulch Fill slope 92 Paper netting Fill slope 93 Asphalt-straw mulch Fill slope 97 Straw mulch, netting, and planted trees Fill slope 98 Straw mulch and netting Fill slope 99 Straw mulch Cut slope 32 to 47 Terracing Cut slope 86 Straw mulch Cut slope 97 Wood chip mulch Road fills 61 Straw mulch Road fills 72 Grass and legume seeding Road cuts 71 Gravel surface Surface 70 Dust oil Surface 85 Bituminous surfacing Surface 99

a Percent decrease in erosion compar ed to similar, untreated sites. b No difference in erosion reducti on between these three treatments.

c Intermountain Forest and Range Experiment Station, Forestry Sciences Laboratory, Boise, ID, nd.Assessment of Water Quality Impairments Related to Forest Roads Page 219 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 3-3. Estimations of Overall Cost of Co mpliance with State Forestry BMP Programs by Program Type (source: US EPA, 2005)

Applicability Cost Estimation Reference

Voluntary-to-mandatory implementation ($)

Coastal plain region: Piedmont region: Mountain region: =$15.79 per acre =$41.02 per acre =$60.05 per acre

Stringent/Enforceable implementation ($) Virginia and southeastern states (applicable to central and northern states)

Coastal plain region: Piedmont region: Mountain region: =$28.88 per acre =$51.28 per acre =$66.26 per acre Aust et al., 1996

California Average cost Inland areas Coastal areas =$337.37 per acre =$109.31-558.68 per

acre =$620.76 per acre Henly, 1992

Oregon, Washington, Alaska Average cost Noncoastal

areas Coastal areas =$236.16-503.35 per

acre =$236.16 per acre =$503.35 per acre Ellefson et al., 1995 (Division between coastal and noncoastal based on California model)

Other Western states with forest practice regulation. Cost per acre is estimated as the average of costs in we stern states without forest practice regulation and the low-end cost given for Oregon noncoastal forests: Nevada, New Mexico, Idaho

$202.42 per acre Western states without forest practiceregulation. Cost per acre is estimated as onehalf of California’s noncoastal cost: Arizona, Colorado, Montana, Utah, Wyoming, Hawaii

$168.68 per acre

Note: All costs in 2008 dollars.Asse Contract # EP-C-05-066, ssment of Water Quality Impairments Related to Forest Roads Page 220 TO # 0002 December 4, 2008

Table 3-4. Estimations of Implem entation Costs by Management Measure in the Southeast and Midwest (source: US EPA, 2005)

Practice Average Cost Cost Range Comments

Planning

Savings from road design/location ($520/mil)

Savings in maintenance ($312/mil) Savings were associated with av oiding problem soils, wet areas, and unstable slopes. Maintena nce savings resulted fro m revegetating cut and fill slopes, which reduced erosion. Southern states.

SMA $5,392 Costs for average tract size of 1,361 ac; include marking and foregone timber value. Southern states.

Road Construction $7,154/mi- $57,208 Lower end for no gravel and few culverts; upper end for complete graveling and more culverts. West Virginia.

$19,974- $57,208 Lower end for 1,832-ac forest with slopes <3%; upper end for 1,148-ac forest with slopes > 9%. Southern states.

$309/mi- $15,659 Lower end for grass surfacing; upper end for large stone surfacing. Appalachia.

Construction Phase (as percent of total cost) 10% 20-25% 20-25% 10% 30-40% Equipment and Material Clearing, grubbing, and slash disposal Excavation Culvert installation Rock surfacing

Road Maintenance $2,976- $5,318 Lower end for roads constructed without BMPs; upper end for roads constructed with BMPs. Costs over 20 years discounted at 4%.

$104/ac- $379/ac Lower end for disking only; upper end for shear-rake-pile-disk. Southern states. Mechanical Site Preparation $189/ac

$101/ac- $243/ac Lower end for light preparation, in cluding hand; upper end for chemicalmechanical site preparation.

$113/ac- $479/ac Lower end for direct seeding; upper end for tree planting with purchased planting stock.

$67/ac Regeneration

$65/ac- $81/ac Lower end for machine planting; uppe r end for hand planting. Southern states.

Cost for average sized tract of 1,361 ac; includes seed, fertilizer, mulch. Southern states. Revegetation $30,688

$178/ac- $323/ac Lower end for introduced grasses; upper end for native grasses. Includes seedbed preparation, fertilizer, chemical application, seed, seedlings.

Prescribed burning $18/ac $13/ac- $26/ac Lower end for windrow burning; upper end for burning after chemical site preparation. Southern states. Pesticide application $138/ac $76/ac- $186/ac Lower end for ground application; uppe r end for aerial application. Southern states. Fertilizer application $85/ac $58/ac- $99/ac Lower end for ground application; uppe r end for aerial application. Southern states. Note: All costs in 2008 dollars.of Water Quality Impairments Related to Forest RoadsPage 221TO # 0002December 4, 2008Table 3-5. Estimations of Construction andImplementation Costs for Individual Road Construction and Erosion Control BMPs, byRegion (2008 dollars; source: US EPA, 2005)Approximate Construction and Implementation Costs per BMP installed, by RegionBMPNortheastSoutheastMidwestRockyMountainsNorthwestSouthwestAlaskaCommentsBroad-baseddip$54$54-$121$67-$81$34-$47$135-$175$40-$54Depends on the cost of labor, equipment, andterrain (Northwest costs include profit andoverhead).Waterbar$27 (notincluding labor)$81-$101 (onskid trails)n/a$135$61-$81$34-$47Cost varies withsize and construction material.Mulch$96$27-$108 (ton)n/a$2,024 (ac)(hydro-mulch)$540-$675 (ac)$108-$121 (ton)Cost varies with regional market price and hauldistance.Seed$1,349 (ac)(hydro-seed)$1-$8 (lb)$1-$13 (lb)$8 (lb)$540-$607 (ac)$270-$540 (ac)$9-$13(lb)Cost varies withspecies of seed, regionalmarket price, and terrain.Riprapn/a$7-$13 (yd3)$28 (yd3)$20-$40 (yd3)n/a$26-$50 (yd3)Price varies with size of rock used.Gravel$8-$13 (ton)$47,232$53,979 (mile,14’ W x 4”)$22-$35 (yd3)$40 (yd3)$24-$30 (yd3)Cost varies with thesize of rock and hauldistance.Culvert$567$675-$2,699$26 (ft, 18” pipe)$35 (ft, 24” pipe)$135 (ft, 72”pipe)$32 (ft, 18” pipe)$31 (ft, 18” pipe)Cost varies with size and length of culvert.Costs provided reflect basecost for installation.Straw Matting$76 (roll, 7.5’ x120’)n/a$3(yd2)$1-$4 (yd2)$3.40 (yd2)Cost varies with size of matting.Geotextiles$510 (700 yd2)$3-$8 (ft)$11-$16 (ft)$1-$3 (ft)n/a$19 (ft)Woven geotextiles are the only geotextilerecommended for road-stream crossings.HardwoodMats (pallets)$162-$270$162-$270$229 (10’ x 12’)$162-$270$162-$270$162-$270$209 (10’ x 12’)Cost varies with size.Turn-outs$54-$67$67-$94$67-94$67$67$54-$67$96Costvaries with equipment and labor costs.Silt Fence$32 (24” H x100’ L)not commonlyusednot commonlyused$2 (yd2)$5.40 (ft)$2.70 (yd2)Cost varies with regional prices and length.Dust Control$1,349 (mile,using calciumchloride)$1,349-$4,048(mile, annually)$256 (ton)Varies widely with traffic level.TemporaryBridge$675-$26,989$675-$20,242$270-$33,737$1,349-2,699 (ft)n/a$1,687-$3,374(ft)Cost varies widely with quality of materialsused, width and span.Barge(Alaska)------------$1,349 (hr)Barge transport in southeastern Alaska (TongassNatl. Forest) is the most common means todeliver material to a site.Note: All costs are per unit provided (ac = acre; ft = linear foot; hr = hour; lb = pound; yd2= square yard; yd3= cubic yard; D = depth; H =height; L = length; W = width).Where units are not provided, cost is per BMP installed.AssessmentContract # EP-C-05-066,Assessment of Water Quality Impairments Related to Forest Roads Page 222 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 4-1. Summary of State Program s for Forest Road Management: States in which BMPs for Forest Roads a re Voluntary (adapted from TetraTech, 2004) Types of BMPs Specified

StateConstructionDrainageLocation/SpacingMaintenanceRoad ClosureStabilization/Soils/SlopeStream CrossingsSMZs/Bank Stabilization/Buffer StripsWet Weather UseWinter OperationsTraining/Technical AssistanceImplementation/Effectiveness MonitoringCompliance/Enforcement

Year of Latest BMP Revision

Other Information AL 

## 9 9 9 9 9 9 9 1993 • Licensing requirement for foresters

• Through cooperative agreement, Alabama Division of Environment refers suspected water-quality complaints due to forestry to the forestry commission.

• Rely on the Water Pollution Control

Act for enforcement AZ 

## 9 • Arizona state law does not contain silvicultural requirements related to NPS pollution from forestry activities or established BMPs . AR 

## 9 9 9 9 9 9 9 9 9 9 9 • Division of Environmental Quality (DEQ) has regulatory water pollution control authority, and a formal memorandum of understanding exists between the forestry commission and DEQ to address complaints or violations of water quality suspected to be due to forestry. CO 

## 9 9 9 9 9 9 9 1998

DE 

## 9 9 9 9 9 9 9 1996 y Voluntary BMPs plus enforcement

y Forestry administrator is responsible for preventing pollution to waterways and will perform BMP inspections on informal field visits

y Streamside Management Zone not required as long as BMPs are implemented FL 

## 9 9 9 9 9 9 9 9 9 9 9 1993 y “Combination” BMP program containing regulatory and nonregulatory elements

y State permits are required for forest roads, stream and wetland crossings

y Florida Department of Environmental Protection can enforce BMPs GA 

## 9 9 9 9 9 9 9 1999 y “Combination” BMP program containing regulatory and nonregulatory elements

y BMPs mandatory for stream crossings

y Persistent forestry-related water pollutionAssessment of Water Quality Impairments Related to Forest Roads Page 223 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 4-1. Summary of State Program s for Forest Road Management: States in which BMPs for Forest Roads a re Voluntary (adapted from TetraTech, 2004) Types of BMPs Specified

StateConstructionDrainageLocation/SpacingMaintenanceRoad ClosureStabilization/Soils/SlopeStream CrossingsSMZs/Bank Stabilization/Buffer StripsWet Weather UseWinter OperationsTraining/Technical AssistanceImplementation/Effectiveness MonitoringCompliance/Enforcement

Year of Latest BMP Revision

Other Information violations are referred to the Georgia Environmental Protection Division for enforcement action

y Registration of professional foresters HI 

## 9 9 9 9 9 9 9 • “Combination” BMP program containing regulatory and nonregulatory elements

IL 

## 9 9 9 9 9 9 9 9 9

IN 

## 9 9 9 9 9 9 9 9 9 9 9 9 • Voluntary BMPs plus enforcement

• State provides logger BMP training IA 

## 9 9 9 9 9 9 9

KS 

## 9 9

LA 

## 9 9 9 9 9 9 9 1998 • Voluntary BMPs plus enforcement

• No formal departmental process exists for dealing with specific forestry operations suspected of causing water pollution ME 

## 9 9 9 9 9 9 9 9 9 y “Combination” BMP program containing regulatory and nonregulatory elements

y Land Use Regulation Commission

y Shoreland Zoning Act

y Natural Resource Protection Act

y Marine Forest Practices Act

y General Permitting process for stream crossing

y State provides training for Certified Logging Professionals and Certified Master Loggers and workshops for landowners are held throughout the state. MA 

## 9 9 9 9 9 9 9 9 9 • Massachusetts Forest Cutting Practices Act

MI 

## 9 9 9 9 9 9 9 • Voluntary BMPs plus enforcement

MN 

## 9 9 9 9 9 9 9 9 9 9 9 y Sustainable Forest Resources Act

y Voluntary BMPs plus enforcement

y State provides logger BMP trainingAssessment of Water Quality Impairments Related to Forest Roads Page 224 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 4-1. Summary of State Program s for Forest Road Management: States in which BMPs for Forest Roads a re Voluntary (adapted from TetraTech, 2004) Types of BMPs Specified

StateConstructionDrainageLocation/SpacingMaintenanceRoad ClosureStabilization/Soils/SlopeStream CrossingsSMZs/Bank Stabilization/Buffer StripsWet Weather UseWinter OperationsTraining/Technical AssistanceImplementation/Effectiveness MonitoringCompliance/Enforcement

Year of Latest BMP Revision

Other Information MS 

## 9 9 9 9 9 9 9 9 9 2000 • Voluntary BMPs plus enforcement

MO 

## 9 9 9 9 9 9 9

NE 

## 9 9 9 9 9 9 9 y Erosion and sediment control program

y Written plans encouraged NJ 

## 9 y No formal legal requirements focused on forestry.

y Permanent steam crossings are regulated and require a Stream Encroachment Permit.

y BMP manual can be purchased for $5 NY 

## 9 9 9 9 9 9 9 9 • “Combination” BMP program containing regulatory and nonregulatory elements

• Permit required for stream crossings NC 

## 9 9 9 9 9 9 9 9 9 9 9 9 1994 y Adoption of Forest Practice Guidelines (performance standards) mandatory, but BMPs for forestry are “recommended”

y Cases of noncompliance are referred to department of land resources, division of water quality, or division of forest resources law enforcement

y Registration for professional foresters is mandatory

y North Carolina Forestry Association (NCFA) ProLogger program ND 

## 9 9 9 9 9 9

OH 

## 9 9 9 9 9 9 9 9 y Ohio Agricultural and Silvicultural Abatement Act

y Silvicultural Nonpoint Source Pollution Plan required

y Voluntary BMPs plus enforcement OK 

## 9 9 9 9 9 9 9 9 1994 y Forestry-related water-quality violations are referred to the DEQ for necessary enforcement action RI y “Combination” BMP program containing regulatory and nonregulatory elementsAssessment of Water Quality Impairments Related to Forest Roads Page 225 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 4-1. Summary of State Program s for Forest Road Management: States in which BMPs for Forest Roads a re Voluntary (adapted from TetraTech, 2004) Types of BMPs Specified

StateConstructionDrainageLocation/SpacingMaintenanceRoad ClosureStabilization/Soils/SlopeStream CrossingsSMZs/Bank Stabilization/Buffer StripsWet Weather UseWinter OperationsTraining/Technical AssistanceImplementation/Effectiveness MonitoringCompliance/Enforcement

Year of Latest BMP Revision

Other Information

y BMP manual can be purchased for $5 SC 

## 9 9 9 9 9 9 9 9 9 1994 y Voluntary BMPs plus enforcement

y State Forestry Commission must develop an erosion, sediment, and stormwater management plan

y Department of Health and Environmental Control may initiate enforcement action based on referral

y Memorandum of understanding between the Forestry Commission and Department of Health and Environmental Control (DHEC) defines the role of each agency in preventing or correcting water-quality impacts from forestry operations.

y Courtesy Exam Program, a proactive means to encourage proper BMP implementation, is uni que in the southern States SD 

## 9 9 9 9 9 9 9 9 9 9 9 9 • South Dakota Nonpoint Source Pollution Management Plan

TN 

## 9 9 9 9 9 9 9 9 9 9 9 1996 y Voluntary BMPs plus enforcement

y Department of Environment and Conservation may take appropriate enforcement action for water pollution due to forestry. TX 

## 9 9 9 9 9 9 2001 y “Combination” BMP program containing regulatory and nonregulatory elements

y No formal State interagency agreement by which BMP noncompliance is addressed.

y State coordinating committee consisting of all regulatory agencies and the forestry community provides advice for recommended BMPs and seeks cooperation of the logger and/or landowner in cases of reported or discovered BMP noncompliance. UT 

## 9 9 9 9 9 9 9 9 9 9 y Utah Forest Practice ActAssessment of Water Quality Impairments Related to Forest Roads Page 226 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 4-1. Summary of State Program s for Forest Road Management: States in which BMPs for Forest Roads a re Voluntary (adapted from TetraTech, 2004) Types of BMPs Specified

StateConstructionDrainageLocation/SpacingMaintenanceRoad ClosureStabilization/Soils/SlopeStream CrossingsSMZs/Bank Stabilization/Buffer StripsWet Weather UseWinter OperationsTraining/Technical AssistanceImplementation/Effectiveness MonitoringCompliance/Enforcement

Year of Latest BMP Revision

Other Information VA 

## 9 9 9 9 9 9 9 9 9 9 9 9 1994 y Voluntary BMPs plus enforcement

y Must notify Virginia Department of Forestry before start of logging operations.

y Silvicultural Water Quality Law authorizes the Department of Forestry to require corrective measures for silvicultural operations causing, or with potential to cause, sedimentation of State

waters

.

y The Department inspects harvesting operations for water quality degradation WI 

## 9 9 9 9 9 9 9 9 • Voluntary BMPs plus enforcement

WY 

## 9 9 9 9 9 9 9 9 y Voluntary BMPs plus enforcement

y Wyoming Nonpoint Source Management Plan

y State provides training in water quality protection measures

y Wyoming retains authority to take enforcement actions for violations of water quality standardsAssessment of Water Quality Impairments Related to Forest Roads Page 227 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 4-2. Summary of State Program s for Forest Road Management: States in which BMPs for Forest Roads a re Mandatory (adapted from TetraTech, 2004) Types of BMPs Specified

StateConstructionDrainageLocation/SpacingMaintenanceRoad ClosureStabilization/Soils/SlopeStream CrossingsSMZs/Bank Stabilization/Buffer StripsWet Weather UseWinter OperationsTraining/Technical AssistanceImplementation/Effectiveness MonitoringCompliance/Enforcement

Year of Latest BMP Revision

Other Information AK 

## 9 9 9 9 9 9 9 9 9 9 9 9 y Forest Resources and Practices Act

y For private, municipal, or non-state owned land, a “detailed plan of operations” must be submitted to the state forester that heads the Division of Forestry

y For state forests, the Commissioner must submit a forest management plan CA 

## 9 9 9 9 9 9 9 9 9 9 y California (Z’Berg-Nejedly) Forest Practice Act

y Must have a timber harvesting plan prepared by a Registered Professional Forester

y Non-industrial forests must have a timber management plan that addresses erosion

y The California Coastal Act regulates alterations to rivers and streams

• The Fish and Game Code mandates stream alteration permits for nonpoint source pollution that results in diversion or obstruction of the natural flow of any river, stream, or lake CT 

## 9 2007 y Connecticut Forest Practices Act

y BMP manual can be purchased for $90

y Commercial foresters must obtain a state certificate

• Soil Erosion and Sedimentation

Control Act ID 

## 9 9 9 9 9 9 9 9 9 9 9 9 2003 y Idaho Forest Practices Act

y Must post a notice of intent to engage in forestry practices

y Must implement site-specific BMPs for stream segments of concern KY 

## 9 9 9 9 9 9 9 9 9 9 9 1996 • Kentucky Forest Conservation Act

• Master Logger training provided by Department of ForestryAssessment of Water Quality Impairments Related to Forest Roads Page 228 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 4-2. Summary of State Program s for Forest Road Management: States in which BMPs for Forest Roads a re Mandatory (adapted from TetraTech, 2004) Types of BMPs Specified

StateConstructionDrainageLocation/SpacingMaintenanceRoad ClosureStabilization/Soils/SlopeStream CrossingsSMZs/Bank Stabilization/Buffer StripsWet Weather UseWinter OperationsTraining/Technical AssistanceImplementation/Effectiveness MonitoringCompliance/Enforcement

Year of Latest BMP Revision

Other Information MD 

## 9 9 9 9 9 9 9 9 9 y Maryland Erosion and Sediment Control Standards and Specifications for Forest Harvest Operations

y Professional foresters must be licensed

y Forest conservation practices

y Compliance Agreement for the Standard Erosion and Sediment Control Plan for Forest Harvest Operations must be obtained when disturbing more than 5,000 square feet of land MT 

## 9 9 9 9 9 9 9 9 1997 y Montana Streamside Management Zone Act

y 50-foot wide streamside management zones for forest streams

y Mandatory notice before engaging in forest practices

y Inspects SMZs/BMPs on Federal, State, and Private Land

y Refers water quality violations to Department of Health and Environmental Services NV 

## 9 1994 y Nevada Forest Practices Act

y Requires a permit from the State forester for logging or cutting operations, which may be denied if significant soil erosion and siltation will be caused

y BMP handbook can be purchased for $25

y Forestry statute prohibits skidding, rigging, or construction of roads within 200 feet of a waterbody NH 

## 9 9 9 9 9 9 9 9 9 • Timber Tax Law or Notice of Intent to Cut

• New Hampshire Wetlands Law, Basal Area Law

• Slash Law

• BMP program contains voluntary elementsAssessment of Water Quality Impairments Related to Forest Roads Page 229 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 4-2. Summary of State Program s for Forest Road Management: States in which BMPs for Forest Roads a re Mandatory (adapted from TetraTech, 2004) Types of BMPs Specified

StateConstructionDrainageLocation/SpacingMaintenanceRoad ClosureStabilization/Soils/SlopeStream CrossingsSMZs/Bank Stabilization/Buffer StripsWet Weather UseWinter OperationsTraining/Technical AssistanceImplementation/Effectiveness MonitoringCompliance/Enforcement

Year of Latest BMP Revision

Other Information NM 

## 9 9 9 9 9 9 9 9 9 2002 • New Mexico Forest Conservation Act

• “Combination” BMP program containing regulatory and nonregulatory elements OR 

## 9 9 9 9 9 9 9 9 9 9 9 9 1995 y Oregon Forest Practices Act and Forest Practice Administrative Rules PA 

## 9 9 9 9 9 9 9 9 9 y Pennsylvania Department of Environmental Protection Chapter 102 Rules and Regulations, the Clean Streams Act

y Chapter 102 regulations govern stream crossings

y Erosion and sediment pollution control plan required for timber harvesting operations

y Road maintenance activity involving 25 acres of earth disturbance or more requires an Erosion and Sediment Control Permit

y Adding or closing a state forest road requires permission from State Forester

y State provides BMP classroom training and on-site assistance provided by Service foresters located throughout the state VT 

## 9 9 9 9 9 9 • No formal Forest Practices Act

• 1986 amendments to Vermont Water Quality Protection Statutes require Acceptable management Practices (similar to BMPs)

• Alteration of Streams Law. WA 

## 9 9 9 9 9 9 9 9 9 9 9 2001 y Washington Forest Practices Rules and Timber, Fish, and Wildlife Agreement.

y Small forest landowners must submit a checklist and road maintenance and abandonment plan with application for forest practice

y Forest practice standards mandatoryAssessment of Water Quality Impairments Related to Forest Roads Page 230 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Table 4-2. Summary of State Program s for Forest Road Management: States in which BMPs for Forest Roads a re Mandatory (adapted from TetraTech, 2004) Types of BMPs Specified

StateConstructionDrainageLocation/SpacingMaintenanceRoad ClosureStabilization/Soils/SlopeStream CrossingsSMZs/Bank Stabilization/Buffer StripsWet Weather UseWinter OperationsTraining/Technical AssistanceImplementation/Effectiveness MonitoringCompliance/Enforcement

Year of Latest BMP Revision

Other Information WV 

## 9 9 9 9 9 9 9 • Logging and Sediment Control Act

• State certification in logger training including BMPs.Asse Contract # EP-C-05-066, ssment of Water Quality Impairments Related to Forest Roads Page 231 TO # 0002 December 4, 2008

Table 4-3. Detailed Review of State Forest Practice s and Selected Habitat Conservation Plan (HCP) Provisions for Roads (from Scurlock, 2007)

State or Corporation

State Forest Practices and Selected HCP Provisions CA OR WA ID MT Palco Plum Creek

Enforceable Road Design Standards? Yes Yes Yes Yes No Yes

Steep/Unstable Slope Prohibition? No No No No No Yes No Steep Slope Building special process? Yes Yes Yes No No - Yes

Timeline for Old Roads up to Standards? No No 2016 for large landowners No No 500 mi/year 2015; 2010 for high priority watersheds 100 year flood passage at new crossings? Yes No 50y Yes No 50y No 25y Yes No 50y Bedload/debris passage? Yes? No Some No No No

Upstream and downstream passage required? (Juveniles and adults) Yes Yes Yes Only for

new crossings No Yes

Seasonal/wet weather hauling restrictions? Yes Some No Yes No Some (visible turbidity) Orphan Roads addressed? No No Yes No No Adequately? n/a n/a No n/a n/a Watershed analysis/CWE process? No No (yes on state lands) No Yes No ?Assessment of Water Quality Impairments Related to Forest RoadsPage 232Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-4. Summary of State Forest Road BMPImplementation Surveys for States in which BMPs for Forest Roads are Voluntary.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumber ofBMPimplementation surveysYear ofmostrecentsurveySamplingdesignNumber ofsitesType ofsurvey Overall forestry SMZs Permanent roads Temp. road/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementation needsCommentsAL>62006Random(sites lessthan 1 yearold)50 (SW); 64(NW & NE)Aerialsurvey94(SW)95(NW&NE)yes•Alabama Forestry Commissionmonitors BMP compliance rates.•BMP implementation surveys areconducted annually for select portionsof state.•Data are not published in reports.AZ0•Arizona has not conducted a review offorestry BMP implementation.AR32005random249888484yesF, FI, S,NIPFRoads (closeout),temporarystreamcrossings,harvestingand SMZ•Arkansas Forestry Commissionmonitors BMP compliance rates.•Southern BMP monitoringrecommendations incorporated.•BMP implementation lowest onsites owned by non-industrial,private landowners and highest bythose who had BMP training•Implementation rates improving for FIlandowners (roads and harvestingBMPs)CODEFL>102006Randomlyselected byaerialobservation190Foresteron site;139 y/nquestionsurvey99999810094noPU, FI,NIPFStabilizecritical roadsegments &drainagestructures•Florida Division of Forestry monitorsBMP implementation.•Biennial surveys.•Risk to water quality is evaluated.•Southern BMP monitoringrecommendations incorporated.•Overall implementation has increasedfrom 84% (1985) to 99% (2006).Assessment of Water Quality Impairments Related to Forest RoadsPage 233Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-4. Summary of State Forest Road BMPImplementation Surveys for States in which BMPs for Forest Roads are Voluntary.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumber ofBMPimplementation surveysYear ofmostrecentsurveySamplingdesignNumber ofsitesType ofsurvey Overall forestry SMZs Permanent roads Temp. road/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementation needsCommentsGA>32005Targetedrandom412Foresteron site;108 y/nquestionsurvey90918881yesFI, PU,NIPFSkidderfords,Debris anddirt typecrossings•Georgia Forestry Commissionmonitors BMP implementation.•Risk to water quality is evaluated.•Southern BMP monitoringrecommendations incorporated.•Newly constructed road compliance84%; new stream crossings 32%.HIIL0•Illinois has not conducted a review offorestry BMP implementationIN12004154Interdisciplinary team8881937779S, NIPF,P+NIPFPlacementandconstructionof waterdiversion,crossingstructuredesign,skidding instreamchannels•Indiana Department of NaturalResources, Division of Forestry andWoodland Steward Institute monitorBMP implementation.•Implementation based on combining 4rounds of monitoring (1996-2000)IA0•Iowa has not conducted a review offorestry BMP implementationKSLA>42005Scattered145Surveyor onsite96>341062-957035noFI,CNIF,PU,NIPFPermanentroads(seedingand•Louisiana Department ofAgriculture and Forestry, Office ofForestry monitors BMPcompliance rates.•BMP implementation increased10Rate of BMP implementation is underestimated since many sites were rated as having no action required or no assessment was available.Assessment of Water Quality Impairments Related to Forest RoadsPage 234Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-4. Summary of State Forest Road BMPImplementation Surveys for States in which BMPs for Forest Roads are Voluntary.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumber ofBMPimplementation surveysYear ofmostrecentsurveySamplingdesignNumber ofsitesType ofsurvey Overall forestry SMZs Permanent roads Temp. road/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementation needsCommentsmulching)with technical assistance fromprofessional forester.ME32005Random28875892748678NIPF, FI,PU, IFTemporarystreamcrossings,haul roadBMPs•Maine Forest Service monitors BMPimplementation.•Involved in NAASF and USFS-NRBMP Monitoring Protocol11.MA•Massachusetts has not conducted areview of forestry BMPimplementation.MI0•Michigan has not conducted a reviewof forestry BMP implementation.MN12004Varies byyear31531-64,731241-8557PU, FI,NIErosioncontrolstructures,waterdiversion,crossingapproaches•Minnesota Forest Resources Councilmonitors BMP implementation.•Implementation based on 3 years ofmonitoring (2000-2002).•Majority of logging operations occuronly in winter.MS>12006Randomlyselectedfrom sitesidentifiedby aerialreconnaissance203Waterqualityteam onsite; 73questionsurvey9088778893noRoads,SMZs,temporaryroads andskid trails,crossings•Mississippi Forestry Commissionmonitors BMP implementation.•Risk to water quality is evaluated.11Northeastern Area Association of State Foresters (NAASF) and the USFS-Northern RegionProgram for State and Private Forestry Protocol.12Filter strips.Assessment of Water Quality Impairments Related to Forest RoadsPage 235Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-4. Summary of State Forest Road BMPImplementation Surveys for States in which BMPs for Forest Roads are Voluntary.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumber ofBMPimplementation surveysYear ofmostrecentsurveySamplingdesignNumber ofsitesType ofsurvey Overall forestry SMZs Permanent roads Temp. road/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementation needsCommentsMO2007Random5 sites/yearLoggertrainerevaluation on site•State of Missouri and Missouri ForestProducts Association monitor BMPimplementation.•Small sample size precludes calculatingimplementation.•Data are not published in reports.NENJ•New Jersey has not conducted areview of forestry BMPimplementation.NY2200053737859FI, S, NIRoaddrainage,streamcrossings•State Universityof New York, NewYork Department of EnvironmentalConservation, New York CityDepartment of EnvironmentalProtection, and New York CityWatershed Forestry Program monitorBMP implementation.•2000 survey of Adirondack and Catskillregions.•Involved in NAASF and USFS-NRBMP Monitoring Protocol.NC42005Sites onlyselected ifwater bodypresent8285857265yesP, FI,NIPFPermanentroads,water barsontemporaryroads andskid trails,and SMZencroachmint•North Carolina Division of ForestResources monitors BMPimplementation.•As professional assistance increased,BMP implementation increased.•Southern BMP monitoringrecommendations incorporated.ND0•New monitoring report underAssessment of Water Quality Impairments Related to Forest RoadsPage 236Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-4. Summary of State Forest Road BMPImplementation Surveys for States in which BMPs for Forest Roads are Voluntary.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumber ofBMPimplementation surveysYear ofmostrecentsurveySamplingdesignNumber ofsitesType ofsurvey Overall forestry SMZs Permanent roads Temp. road/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementation needsCommentsdevelopment.OH11999Failure toimplementstreamsidemanagement zonesand skidtrail BMPs•Ohio Division of Forestry monitorsBMP implementation.•Data are not published in reports.•Lack of BMP-trained loggersOK32006random100Surveyoron site;TexasBMPmonitoringchecklist9297907791100noFI, PU,NIPFRoaddrainage andstabilization,temporarycrossings,SMZs•Oklahoma Department of Agriculture,Food, and Forestry monitors BMPimplementation.•Risk to water quality is evaluated.•Southern BMP monitoringrecommendations incorporated.•Data are not published in reports.RISC72005Randomselectionfrom sitesidentifiedby aerialsurvey200Trainedforesteron site94879278yesP, FI,NIPFHarvestingsystems,SMZs,streamcrossings,roadstabilizationand poordesign•South Carolina Forestry Commissionmonitors BMP implementation.•Risk to water quality is evaluated.•Courtesy exam believed effective.•monthly summary report of completedcourtesy BMP exams is provided to thestate water quality agency and totimber buyers.SD2004Targeted92Road designand waterdiversion,drainagefeatures nearstream•Black Hills Forest ResourceAssociation, South Dakota Departmentof Environment and Natural Resourcesand Department of AgricultureDivision of Resource Conservation andForestry monitor BMPAssessment of Water Quality Impairments Related to Forest RoadsPage 237Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-4. Summary of State Forest Road BMPImplementation Surveys for States in which BMPs for Forest Roads are Voluntary.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumber ofBMPimplementation surveysYear ofmostrecentsurveySamplingdesignNumber ofsitesType ofsurvey Overall forestry SMZs Permanent roads Temp. road/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementation needsCommentscrossingsimplementation.•Site selection and implementationrating based on Montana procedures.TN32005Randomselectionfrom aspatial grid2158245yesStreamcrossings•Latest BMP implementation surveyconducted by University of Tennessee,Department of Forestry, Wildlife &Fisheries, and Tennessee Departmentof Agriculture, Division of Forestry.•Risk to water quality is evaluated.•Southern BMP monitoringrecommendations incorporated.•Data are not published in reports.TX62005Randomselectionfrom sitesidentifiedby aerialsurvey andforestserviceknowledge1561 or 2trainedforesterson site9291939031-81noPU, FI,CNIF,NIPFRoads(reshapingandstabilization), stabilizingtemporarystreamcrossings•Texas Forest Service monitors BMPimplementation.•Monitoring data collected inaccordance with QAPP approved byTexas State Soil and WaterConservation Board and EPA.•Risk to water quality is evaluated.•Southern BMP monitoringrecommendations incorporated.•Implementation was higher whenloggers had BMP training andwhen landowners were membersof forest organization; lower whenthe site was owned by nonindustrial private forest owner,mainly due to improper streamcrossings.UT1200640Auditteam9264-817786Roaddrainage,•Utah Division of Forestry, Fire, andState Lands monitors BMPAssessment of Water Quality Impairments Related to Forest RoadsPage 238Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-4. Summary of State Forest Road BMPImplementation Surveys for States in which BMPs for Forest Roads are Voluntary.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumber ofBMPimplementation surveysYear ofmostrecentsurveySamplingdesignNumber ofsitesType ofsurvey Overall forestry SMZs Permanent roads Temp. road/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementation needsCommentsdiversionand wetperiod useimplementation.VA>102007Surveyor on site8368noRutting andseeding,water controlstructures,streamcrossings•Virginia Department of Forestrymonitors BMP implementation.•Risk to water quality is evaluated.WI32004Random60Interdisciplinarymonitoring teams90 (S)93(C)95(IF)1371(S)96(C)78(S)69(C)S, CDiversiondevices, roadshaping andgrading,maintenance,culvertsizing•Wisconsin Department of NaturalResources, Division of Forestrymonitors BMP implementation.WY120056Auditteam97•Wyoming Timber Industry Association,Department of Environmental Quality,and State ForestryDivision monitorBMP implementation.Ownership codes and definition: F= Federal, FI= Forest industry, S= State, C= County, PU= Public, P=Private, CNIF= Corporate non-industrial,IF=Investor forestlands, NIPF= Nonindustrial private forest owners, NI= Nonindustrialforest, SM=Small landowners.13Overall BMP implementation on industrial forest surveyed in 2002.Assessment of Water Quality Impairments Related to Forest RoadsPage 239Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-5. Summary of State Forest Road BMP Implementation Surveys for States in which BMPs for Forest Roads are Mandatory.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumberof BMPimplementationsurveysYear ofmostrecentsurveySamplingdesignNumberof sitesType ofsurvey Overall forestry SMZs Permanent roads Temp. roads/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementationneedsCommentsAK200593 (C)74 (N)Evaluator on site;scoresheet94(C)84(N)Roads(retiremint) andstreamcrossing(landslides,blockedand washedoutculverts)•Alaska Department of Forestrymonitors BMP implementation.•Implementation surveys conductedfor coastal (C) and northern (N)regions.•Site evaluators are owner, operatoror manager.•Department of Forestry provideson-site assistance during fieldinspections.CA32006Random187(WLPZ)244 (roads)357(crossings)Forestpracticeinspectors onsite;951469-849683Drainage,culverts•California Department of Forestry andFire Protection and State Board ofForestry and Fire Protection monitorBMP compliance rates.•Hillslope Monitoring Program (HMR):1996-2002.•Modified Completion Reportmonitoring program: 2001-2004.•Forest Practice Rule Implementationand Effectiveness Monitoring: 2007.CTID52001Randomlyselectedfromtargeted“pool” ofsites40Multiagencyauditteams9557Culverts(fishpassage)•Idaho Department of Lands,Department of Fish and Game,Intermountain Forest Association,Idaho Forest Owners Association,USDA-FS and Idaho Departmentof Environmental Quality monitor14Overall implementation rate for FPRs related to water quality determined in earlier HMR.Assessment of Water Quality Impairments Related to Forest RoadsPage 240Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-5. Summary of State Forest Road BMP Implementation Surveys for States in which BMPs for Forest Roads are Mandatory.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumberof BMPimplementationsurveysYear ofmostrecentsurveySamplingdesignNumberof sitesType ofsurvey Overall forestry SMZs Permanent roads Temp. roads/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementationneedsCommentsBMP implementation.•Risk to water quality is evaluated.•Data have not been published inreports.KY>12006Randomlyselected byaerialobservation116Foresteron site;38 y/nquestionsurvey56695635noPU, FI,NIPFRoads(spacingand properimplementation ofdrainagestructures)and SMZs•Kentucky Department of Forestrymonitors BMP implementation•Risk to water quality is evaluated.•Data have not been published inreports.MD120079982838275•Maryland Department of NaturalResources-Forestry Servicemonitors BMP compliance rates.•Involved in NAASF and USFS-NRBMP Monitoring Protocol.•Data are not published in reports.MT>72007Stratifiedandprioritizedsiteselection44Interdisciplinary team;58potentialpracticesrated on5-pt.scale93-9698F, FI,NIPF•Montana Department of NaturalResources and Conservation monitorsBMP implementation.NV0•Nevada has not conducted a reviewof forestry BMP implementation.Assessment of Water Quality Impairments Related to Forest RoadsPage 241Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-5. Summary of State Forest Road BMP Implementation Surveys for States in which BMPs for Forest Roads are Mandatory.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumberof BMPimplementationsurveysYear ofmostrecentsurveySamplingdesignNumberof sitesType ofsurvey Overall forestry SMZs Permanent roads Temp. roads/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementationneedsCommentsNH•New Hampshire has not conducteda review of forestry BMPimplementation.•Participates in NAASF and USFSNR BMP Monitoring Protocol.NM0•New Mexico has not conducted areview of forestry BMPimplementation.•NCASI (2007) estimated 75%implementation based on timberharvest plan inspection reports.OR>32002Stratifiedrandom18994 (fishpassage)Forestpracticeforester& 2-personfieldsurveyteam9687-100481571-9570-88Fishpassage,Crossingfillstability,roadsurfacedrainageandmaintenance•Oregon Department of Forestrymonitors BMP compliance rates.•Sampling stratificationintentionally biased to capture highnumber of fish-bearing streams.•2 cases of sediment delivery >100cubic yards.PA0•Pennsylvania has not conducted areview of forestry BMPimplementation.•Participated in development ofNAASF and USFS-NR BMPMonitoring Protocol.15Removal of temporary crossings.Assessment of Water Quality Impairments Related to Forest RoadsPage 242Contract # EP-C-05-066, TO # 0002December 4, 2008Table 4-5. Summary of State Forest Road BMP Implementation Surveys for States in which BMPs for Forest Roads are Mandatory.Information and data compiled fromDissmeyer (1994), Grace (2002), Ice etal. (2004), Jones (2005), NCASI(2001),Prud’homme and Greis (2002), Simpson et al. (2005), Vowell (2004)Latest reported BMPimplementation rate (%)StateNumberof BMPimplementationsurveysYear ofmostrecentsurveySamplingdesignNumberof sitesType ofsurvey Overall forestry SMZs Permanent roads Temp. roads/Skid Crossings WetlandsFormalinteragencyStateagreemintsOwnershipclassesreportedIdentifiedBMPimplementationneedsCommentsVT2199617Surveyors onsiteImplementation ofdrainagestructureson forestroads andskid trails•Vermont Forest ResourcesAdvisory Committee AssessmentWorking Group monitors BMPimplementation.•1996 report was not a statisticallyvalid study.•Participated in development ofNAASF and USFS-NR BMPMonitoring Protocol.•Increased fine sediment depositiondownstream at 8 of 17 crossings.WA22007Stratifiedrandom97Fieldteams808678FI, SM•Washington Department of NaturalResources, Department ofEcology, and Department of Fishand Wildlife monitor BMPcompliance rates.•2006 survey focused on road andriparian rule implementation.•Low sample size for crossings.•Previous Forest PracticesCompliance Report published in1991.WV4200711685808486Drainagestructures,spacingbtwn. trailsand waterbodies,haul roadsin SMZs•West Virginia Department ofForestry monitors BMPimplementation.AsseContract # EP-C-05-066,ssment of Water Quality Impairments Related to Forest RoadsPage 243TO # 0002December 4, 2008Ownership codes and definition: F= Federal,FI= Forest industry, S= State, C=County, PU= Public, P=Private, CNIF= Corporate nonindustrial, IF=Investor forestlands, NIPF=Nonindustrial private forest owners, NI= Nonindustrial forest, SM=Small landowners.Assessment of Water Quality Impairments Related to Forest Roads Page 245 Contract # EP-C-05-066, TO # 0002 December 4, 2008

FIGURESAssessment of Water Quality Impairments Related to Forest Roads Page 246 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Figure 2-1. Distribution of Forest Land in the Continental United States (from US EPA, 2005 )

Figure 2-2. Cross-Sectional Diagram of the Forest R oad Prism and Components (from Moll et al., 1987)Assessment of Water Quality Impairments Related to Forest Roads Page 247 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Figure 2-3. Legal Basis and Definiti ons for Roads in the National Fo rests (from Coughlan and Sowa, 1998)

Notes:

1. Forest Roads: Roads wholly or partially within, or adjacent to, and serving the National Forest System and necessary to the protection, administration, and use of the National Forest System and the use and development of its resource (23 USC 101). 2. Public Roads: Roads under the jurisdiction of, and maintained by, a p ublic authority that are open to public travel. (23 USC 101(a)). 3. Forest Development Roads (FDR): Forest roads under the jurisdiction of the Forest Service (23 USC 101). 4. Uninventoried Roads: Short term roads associated with fire suppression, oil, gas or mineral exploration or development, or timber harvest not intended to be a part of the forest development transportation system and not necessary for resource management. Regulations (36 CFR 223.37) require revegetation within 10 years. 5. Maintained for Public Use: An MOU with FHWA defines FDR’s managed as open to the public as those roads open to unrestricted use by the general public in standard passenger cars, including those closed on a seasonal basis or for emergencies. 6. Maintenance Level 5: Roads that provide a high degree of user comf ort and convenience. Normally double lane, paved facilities, or aggregate surface with dust abatement. This is the highest standard of maintenance. Maintenance Level 4: Roads that provide a moderate degree of user comfort and convenience at moderate speeds. Most are double lane, and aggregate surfaced. Some may be single lane. Some may be dust abated. Maintenance Level 3: Roads open and maintained for travel by a prude nt driver in a standard passenger car. User comfort and convenience are not considered priorities. Typi cally low speed, single lane with turnouts and native or aggregate surfacing. Maintenance Level 2: Roads open for use by high-clearance vehicles. Pa ssenger car traffic is discouraged. Traffic is minor administrative, permitted or dispersed recreatio n. Non traffic generated maintenance is minimal. Maintenance Level 1: These roads are closed. Some intermittent use ma y be authorized. When closed, they must be physically closed with barricades, berms, gates, or ot her closure devices. Closures must exceed one year. When

open, it may be maintained at any other level. When closed to vehicular traffic, they may be suitable and used for nonmotorized uses, with custodial maintenance. 7. Public Lands Highways, Forest Highways: A coordinated Federal Lands Highway Program includes Forest Highways, Public Lands Highways, Park Roads, Parkways and Indian Reservation Roads. These are roads under the jurisdiction of and maintained by a public road authority other than the Forest Service and open to public travel (23 USC 101).Assessment of Water Quality Impairments Related to Forest Roads Page 248 Contract # EP-C-05-066, TO # 0002 December 4, 2008

1:1 line

Figure 2-4. Response of Suspe nded Sediment Concentrations to Forest Harvesting at Experimental Watersheds (fr om Binkley and Brown, 1993)Assessment of Water Quality Impairments Related to Forest Roads Page 249 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Figure 2-5. Figure 5 from Chapman (1988). Graph of p ercent survival of salmonid embryos to emergence in relation to percent fines smaller than 0.85 mm. Data provide comparisons of coho salmon survivals in the laboratory (lab.) and field (Cederholm et al., 1981) , of coho salmon in two different streams (Koski, 1966; Cederholm et al., 1981), and of chinook salmon in gravels with a range of percentages of particles smaller than 9.5 mm (shaded area; Tappel and Bjornn, 1983).Assessment of Water Quality Impairments Related to Forest Roads Page 250 Contract # EP-C-05-066, TO # 0002 December 4, 2008

Figure 2-6. Distribution of major forest type s in the continental United States. Sources and References: Swank et al., 1989. Forest Cover Types map compiled by the U. S. Geological Survey and the U.S. Department of Agriculture Forest Service Forest Inve ntory Analysis Program for the National Atlas of the United States. Landsat Thematic Mapper imagery with 25 forest cat egories, 1991 growing season. U.S. Environmental Protection Agency. 1997. Level III Ecoregions of the Continental Unite d States, Map M-1 (revision of Omernik, 1987). NHEERL, Corvallis, Oregon. Ecological Regions of North Amer ica, Commission for Environmental Cooperation, 1997.