Oregon Department of Forestry

Best Management Practices

Compliance Monitoring Project:

Final Report

Joshua Robben

Monitoring Specialist

Liz Dent

Monitoring Unit Manager

OREGON DEPARTMENT OF FORESTRY

FOREST PRACTICES MONITORING PROGRAM

TECHNICAL REPORT 15

April 2002
ACKNOWLEDGEMENTS

Erin Gilbert, Jim Ziobro, Jeff Peck, Conrad Tull, and Keith Mills were all instrumental in the study design

and implementation of this project. Erin Gilbert, Kristin Cotugno, Kyle Abraham, and Conrad Tull were all

responsible for data collection. Cassandra Webber, Julie Welp, and Kathleen Gomez provided valuable

project support. Ted Lorensen and David Morman prioritized this project for the monitoring program.

This project would not have been possible without the participation of private landowners and managers,

including Boise Cascade Corp.; Cascade Timber Consulting; ECM Partners; Forestree Ltd. Partnership;

Frank Lumber Co.; Freres Lumber Co.; Giustina Resources; Hampton Resources; Hogan Family

Partnership; Jeld-Wen, Inc.; John Hancock Mutual Life Insurance Co.; J-Spears Ranch Company; KOGAP

Enterprises; Lone Rock Timber Co.; Longview Fibre Co.; Malheur Lumber Co.; Menasha Corp.; Miami

Corp.; Moore Mill & Lumber Co.; Olympic Resource Management; Pioneer Resources,; Port Blakely Tree

Farms; River Bend Resources; Rosboro Lumber Co.; Roseburg Resources Co.; Schmidlin Bros. Forest

Management; Seneca-Jones Timber Co.; Shiloh Forest Enterprises; Silver Butte Timber Co.; Simpson

Timber Co.; South Coast Lumber Co.; Starker Forests, Inc.; Swanson-Superior Forest Products, Inc.; The

Timber Company; Timber Products Co.; Timber Service Co.; U.S. Timberlands; Weyerhaeuser Co.;

Willamette Industries, Inc.; Woodland Management, Inc.; Woodward Stuckart LLC; Worden Enterprises,

Inc.; Yaquina Forestry; and numerous small, private landowners. Also critical to this project was the

assistance of representatives from the City of Coos Bay, Hood River County Forestry Dept., Josephine

County Forestry Dept., Washington County Forestry Dept., Oregon Parks and Recreation Dept., and the

Port of Gold Beach.

The external and internal review committee provided valuable input over a four-year period. The authors

would also like to thank all the forest practice foresters and ODF State Lands foresters and engineers who

made the site selection process possible, contacted landowners, and arranged logistics to support the field

team.
TABLE OF CONTENTS

COMMITTEES AND COORDINATORS................................................................................... i

INTERNAL REVIEW COMMITTEE..................................................................................................................................................i

EXTERNAL REVIEW COMMITTEE.................................................................................................................................................i

PROJECT COORDINATORS.............................................................................................................................................................i

INTRODUCTION..........................................................................................................................1

BACKGROUND..............................................................................................................................................................................2

COMPLIANCE MONITORING IN OTHER STATES.......................................................................................................................3

RELATED MONITORING AND RESEARCH .................................................................................................................................5

OBJECTIVES AND MONITORING QUESTIONS..................................................................6

OBJECTIVES..................................................................................................................................................................................6

MONITORING QUESTIONS...........................................................................................................................................................6

STUDY DESIGN ..........................................................................................................................7

SITE SELECTION...........................................................................................................................................................................7

Defining the Population.......................................................................................................................................................7

Stratification...........................................................................................................................................................................7

Selection .................................................................................................................................................................................8

SITE CHARACTERISTICS..............................................................................................................................................................9

RULE FOCUS...............................................................................................................................................................................10

FIELD AND ANALYTICAL METHODS .................................................................................11

COMPLIANCE RATING SYSTEM ...............................................................................................................................................11

Administrative Noncompliance........................................................................................................................................11

Potential Resource Impact.................................................................................................................................................11

Resource Impact..................................................................................................................................................................11

NUMERIC DATA COLLECTION.................................................................................................................................................12

QUALITY ASSURANCE AND QUALITY CONTROL ..................................................................................................................12

SEDIMENT SOURCES..................................................................................................................................................................12

CALCULATING COMPLIANCE ...................................................................................................................................................13

RESULTS....................................................................................................................................14

UNIT-LEVEL COMPLIANCE .......................................................................................................................................................14

Unit Noncompliant Practices............................................................................................................................................15

Unit Compliance Trends in Ownership...........................................................................................................................15
RULE-LEVEL COMPLIANCE ......................................................................................................................................................15

Reforestation (OAR 629-610)...........................................................................................................................................17

Treatment of Slash (OAR 629-615).................................................................................................................................18

Chemical and Other Petroleum Products (OAR 629-620)...........................................................................................18

Road Construction and Maintenance (OAR 629-625)..................................................................................................19

Harvesting (OAR 629-630)...............................................................................................................................................25

Vegetation Retention Along Streams (OAR 629-640).................................................................................................29

Protection Measures for Significant Wetlands (OAR 629-645).................................................................................37

Riparian Management Areas and Protection Measures for Lakes (OAR 629-650)................................................38

Protection Measures for Other Wetlands (OAR 629-655)...........................................................................................38

Miscellaneous Water Protection Rules (OAR 629-660)..............................................................................................38

Administrative Requirements (From All Divisions)....................................................................................................38

FINDINGS ...................................................................................................................................41

MONITORING QUESTION 1.......................................................................................................................................................41

Unit-Level Compliance......................................................................................................................................................41

Rule-Level Compliance .....................................................................................................................................................42

MONITORING QUESTION 2.......................................................................................................................................................43

MONITORING QUESTION 3.......................................................................................................................................................43

Forest Practices Forester (FPF) Inspections...................................................................................................................43

Statistical Representation..................................................................................................................................................44

MONITORING QUESTION 4.......................................................................................................................................................44

Compliance and Sample Size............................................................................................................................................44

Areas of Higher Compliance.............................................................................................................................................45

Areas of Lower Compliance .............................................................................................................................................45

MONITORING QUESTION 5.......................................................................................................................................................47

Slash Accumulations..........................................................................................................................................................48

Riparian Vegetation Damage............................................................................................................................................49

Alteration of Bed or Banks................................................................................................................................................49

Sediment Delivery ..............................................................................................................................................................49

RECOMMENDATIONS.............................................................................................................51

RAISE AWARENESS AND UNDERSTANDING OF KEY FINDINGS...........................................................................................51

UPDATE RULES AND GUIDANCE .............................................................................................................................................52

PROVIDE FOR ADMINISTRATION AND ENFORCEMENT .........................................................................................................52

CONSIDER RELATED MONITORING.........................................................................................................................................53
REFERENCES ...........................................................................................................................55

APPENDIX A..............................................................................................................................58

APPENDIX B..............................................................................................................................63

APPENDIX C..............................................................................................................................65

APPENDIX D..............................................................................................................................67

LIST OF TABLES

TABLE 1. OREGON DEPARTMENT OF FORESTRY ADMINISTRATIVE RULES................................................................... 1

TABLE 2. LANDOWNER POPULATION CHARACTERISTICS ................................................................................................. 8

TABLE 3. UNITS REVIEWED DURING SELECTION PROCESS WHICH DID NOT MEET SURVEY CRITERIA................... 8

TABLE 4. UNITS SURVEYED BY OWNERSHIP AND STREAM CLASS FOR EACH ODF DISTRICT................................. 10

TABLE 5. UNIT-LEVEL COMPLIANCE RATES BY OWNERSHIP CLASS ............................................................................. 15

TABLE 6. RULES AND REGULATIONS SECTIONS MONITORED........................................................................................ 16

TABLE 7. COMPLIANCE RESULTS FOR RMA REFORESTATION TIMING RULES ............................................................ 17

TABLE 8. COMPLIANCE RESULTS FOR TREATMENT OF SLASH RULES......................................................................... 18

TABLE 9. COMPLIANCE RESULTS FOR PETROLEUM-RELATED RULES......................................................................... 19

TABLE 10. COMPLIANCE RESULTS FOR CHEMICAL APPLICATION RULES ...................................................................... 19

TABLE 11. COMPLIANCE RESULTS FOR ROAD LOCATION RULES.................................................................................... 20

TABLE 12. PERCENT OF NEW AND EXISTING ROAD LENGTHS IN EACH LOCATION CATEGORY................................. 20

TABLE 13. COMPLIANCE RESULTS FOR ROAD PRISM DESIGN RULES............................................................................ 20

TABLE 14. COMPLIANCE RATES FOR ROAD STREAM CROSSING DESIGN RULES......................................................... 21

TABLE 15. CHARACTERISTICS OF 208 ROAD STREAM CROSSINGS SURVEYED............................................................ 21

TABLE 16. COMPLIANCE RATES FOR ROAD DRAINAGE DESIGN RULES ......................................................................... 22

TABLE 17. DISTRIBUTION OF ROAD DRAINAGE DESIGN INSTALLED................................................................................ 22

TABLE 18. UNFILTERED DITCH LENGTH DRAINING TO CHANNEL AT NEW STREAM CROSSINGS............................... 23

TABLE 19. COMPLIANCE RATES FOR ROAD DRAINAGE MAINTENANCE RULES............................................................. 23

TABLE 20. DISTRIBUTION OF ROAD DRAINAGE MAINTENANCE CONDITION................................................................... 24

TABLE 21. COMPLIANCE RESULTS FOR ROAD WASTE AND STABILIZATION RULES..................................................... 24

TABLE 22. COMPLIANCE RATES FOR VACATED ROAD RULES.......................................................................................... 24

TABLE 23. COMPLIANCE RATES FOR ROCK PIT RULES...................................................................................................... 25

TABLE 24. COMPLIANCE RATES FOR GENERAL YARDING PRACTICES RULES.............................................................. 25

TABLE 25. COMPLIANCE RATES FOR FELLING AND HARVESTING SLASH RULES ......................................................... 26

TABLE 26. COMPLIANCE RATES FOR CABLE YARDING NEAR WOS RULES .................................................................... 26

TABLE 27. COMPLIANCE RATES FOR GROUND EQUIPMENT NEAR WOS ........................................................................ 27

TABLE 28. COMPLIANCE RATES FOR HARVESTING WASTE RULES................................................................................. 27

TABLE 29. COMPLIANCE RATES FOR LANDING RULES....................................................................................................... 27

TABLE 30. COMPLIANCE RATES FOR SKID TRAIL RULES................................................................................................... 28
TABLE 31. SKID TRAIL LOCATION DISTRIBUTION................................................................................................................. 28

TABLE 32. SKID TRAIL DRAINAGE........................................................................................................................................... 28

TABLE 33. COMPLIANCE RATES FOR TEMPORARY CROSSING RULES ........................................................................... 29

TABLE 34. NUMBER OF STREAMS, TOTAL LENGTH, AND RMA WIDTH BY STREAM SIZE AND TYPE CLASS.............. 30

TABLE 35. COMPLIANCE RATES FOR VEGETATION RETENTION RULES FOR TYPE F RMAS ....................................... 30

TABLE 36. HARVEST PRESCRIPTIONS FOR TYPE F RMAS SURVEYED............................................................................ 31

TABLE 37. COMPLIANCE RATES FOR VEGETATION RETENTION RULES FOR TYPE N AND D RMAS.......................... 37

TABLE 38. COMPLIANCE RATES FOR SIGNIFICANT WETLAND PROTECTION RULES.................................................... 38

TABLE 39. COMPLIANCE RATES FOR OTHER WETLAND PROTECTION RULES .............................................................. 38

TABLE 40. COMPLIANCE RATES FOR MISCELLANEOUS WATER PROTECTION RULES................................................. 38

TABLE 41. COMPLIANCE RATES FOR NOTIFICATION RULES............................................................................................. 39

TABLE 42. COMPLIANCE RATES FOR PRIOR APPROVAL RULES....................................................................................... 40

TABLE 43. COMPLIANCE RATES FOR WRITTEN PLAN RULES............................................................................................ 41

TABLE 44. COMPLIANCE RATES FOR RULE SECTIONS....................................................................................................... 42

TABLE 45. AVERAGE COMPLIANCE RATES FOR RULES BASED ON NUMBER OF TIMES APPLIED.............................. 44

TABLE 46. RIPARIAN AND STREAM CHANNEL IMPACTS OF NONCOMPLIANT PRACTICES........................................... 48

TABLE A-1. UNIT COMPLIANCE DATA....................................................................................................................................... 59

TABLE C-1. REPEATED MEASUREMENT OF ROAD LOCATION CLASSIFICATION.............................................................. 66

TABLE C-2. REPEATED MEASUREMENT OF ROAD DRAINAGE CLASSIFICATION ............................................................. 66

TABLE C-3. REPEATED MEASUREMENT OF RMA WIDTHS ................................................................................................... 66

TABLE C-4. REPEATED MEASUREMENT OF RMA TREE COUNTS........................................................................................ 66

TABLE C-5. REPEATED MEASUREMENT OF RMA RETAINED BASAL AREA........................................................................ 66

LIST OF FIGURES

FIGURE 1. LOCATION OF UNITS SURVEYED FOR BMP COMPLIANCE................................................................................. 9

FIGURE 2. DISTRIBUTION OF UNITS BY OWNERSHIP CLASS............................................................................................. 10

FIGURE 3. SOURCES OF RULE COMPLIANCE DETERMINATION........................................................................................ 13

FIGURE 4. FREQUENCY DISTRIBUTION OF UNIT-LEVEL COMPLIANCE RATES............................................................... 14

FIGURE 5. COMPLIANCE RATES FOR RULE SECTIONS....................................................................................................... 17

FIGURE 6. RIPARIAN PRESCRIPTION AND OWNERSHIP CLASS ........................................................................................ 31

FIGURE 7. BUFFER RETENTION FOR NO-HARVEST PRESCRIPTION RMAS..................................................................... 33

FIGURE 8. RELATIVE RETENTION FOR BASAL AREA PRESCRIPTION RMAS................................................................... 34

FIGURE 9. TREE COUNT RETENTION FOR BASAL AREA PRESCRIPTION RMAS............................................................. 35

FIGURE 10. FREQUENCY DISTRIBUTION OF UNIT-LEVEL COMPLIANCE RATES............................................................... 42

FIGURE 11. 1987-2000 COMPLIANCE RATES ........................................................................................................................... 43

FIGURE 12. DISTRIBUTION OF SEDIMENT DELIVERY VOLUMES FROM NONCOMPLIANT PRACTICES ......................... 50

FIGURE 13. DISTRIBUTION OF SEDIMENT DELIVERY SOURCES ......................................................................................... 50

FIGURE B-1. DRAFT CHECKLIST FOR ACTIVITIES ASSOCIATED WITH WOS REQUIRING PRIOR APPROVAL ................ 64

FIGURE B-2. DRAFT CHECKLIST FOR ACTIVITIES ASSOCIATED WITH WOS REQUIRING AN APPROVED WRITTEN PLAN..... 64

FIGURE D-1. OREGON PLAN VOLUNTARY MEASURES........................................................................................................... 68
i

COMMITTEES AND COORDINATORS

This study was conducted with the oversight of external and internal review committees. The committees’

main functions were to review and approve the study design, methods, and reports. The committees met

over the course of four years of development, implementation, analysis, and reporting of the project.

Internal Review Committee

Jeff Brandt R & M Coordinator, Salem

John Buckman Protection Unit Forester, Pendleton

Dave Lorenz Forest Practices Forester, Roseburg

Gregg Cline Forest Practices Program Director, Salem

George Ponte Forest Practices Fore ster, Prineville

Jeff Peck Forest Practices Operations Analyst (Former), Salem

Dan Shults Southern Oregon Area Director, Roseburg

Gary Schulz Forest Practices Supervisor, Coos Bay

John Seward Forest Practices Geotechnical Engineer, Roseburg

Mike Simek Protection Unit Forester, Columbia City

Tom Savage Assistant NWO Area Director, Forest Grove

Julie Welp Forest Practices Policy Support Specialist, Salem

Kathy Wiggins Forest Practices Forester, Coos Bay

External Review Committee

Paul Engelmeyer National Audubon Society

Chris Jarmer Oregon Forest Industry Council

Jeff Lockwood National Marine Fisheries Society

Dr. George Ice National Council for Air and Stream Improvement

Rex Storm Association of Oregon Loggers

Dr. Paul Adams Oregon State University

Tom Rosetta Oregon Department of Environmental Quality

Paul Ketchum Audubon Society

Steven Gennett Oregon Small Woodlands Association

Jeff Boechler Oregon Department of Fish and Wildlife

Jason Miner Oregon Trout

Project Coordinators

Liz Dent Oregon Department of Forestry Monitoring Program Director

Josh Robben Oregon Department of Forestry Monitoring Specialist

Jim Ziobro Oregon Department of Forestry Enforcement Coordinator (Former)
BMP Compliance Report.doc/Jaz B 1

ODF BMP Compliance Monitoring Project

INTRODUCTION

The Oregon Department of Forestry (ODF) regulates forestry operations on non-federal land. Landowners

and operators are subject to the Forest Practices Act and Rules when they conduct any commercial activity

relating to the growing or harvesting of trees. The Oregon Forest Practices Act (FPA) was adopted in

1972. The overarching objective of the Act is to

...encourage economically efficient forest practices that assure the continuous growing and

harvesting of forest tree species and the maintenance of forestland for such purposes as the

leading use on privately owned land, consistent with sound management of soil, air, water, fish and

wildlife resources and scenic resources within visually sensitive corridors as provided by ORS

527.755 that assures the continuous benefits of those resources for future generations of

Oregonians. (ORS 527.630 Policy, Oregon Forest Practices Act)

The Oregon Board of Forestry has been vested with exclusive authority to develop and enforce statewide

and regional Forest Practice Rules. These rules are designed to address the resource issues identified in

the FPA policy (sound management of forest, soil, air, water, fish and wildlife resources, and scenic

resources). The rules are categorized into divisions (Table 1), each with its own description of purpose.

The purpose statements further refine the broad objectives of the Rules and Act. All divisions are within

Oregon Administrative Rules chapter 629.

Table 1. Oregon Department of Forestry Administrative Rules

Division Division Description

600 Definitions

605 Planning Forest Operations

606 Stewardship Agreements

610 Reforestation Rules

611 Afforestation Incentive

615 Treatment of Slash Rules

620 Chemical and Other Petroleum Product Rules

625 Road Construction and Maintenance Rules

630 Harvesting Rules

635 Water Protection Rules: Purpose, Goals, Classification and Riparian Management Areas

640 Water Protection Rules: Wetlands and Riparian Management Areas

645 Water Protection Rules: Riparian Management Areas and Protection Measures for Sign. Wetlands

650 Water Protection Rules: Riparian Management Areas and Protection Measures for Lakes

655 Water Protection Rules: Protection Measures for Other Wetlands, Seeps, and Springs

660 Water Protection Rules: Specified Rules for Operations Near Waters of the State

665 Specified Resource Site Protection Rules

670–680 Civil Penalties, Appeals, Hearings Procedures, Stay of Operations, Access to Notifications and Written

Plans, Regional Forest Practice Committees, and the Resource Site Inventory and Protection Process

The Forest Practices Program is responsible for administering and monitoring the Forest Practice Rules.

These rules are subject to revision as necessary based on the best available science and monitoring data.

Such revisions shall maintain the policy of the FPA as described above. The Rules have undergone many

revisions since 1972. The most recent changes to the water protection rules were in 1994, 1995, and
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1996. Therefore, this project was monitoring some rules that had only been in place for approximately

three years.

The Forest Practice Rules cover a wide range of issues pertaining to forest operations and resource

protection. In general, the Rules are designed to minimize impacts of forest activities on other forest

resources. Among other things, the rules focus on minimizing sediment delivery to channels, providing 50-

year flow and juvenile fish passage through culverts, maintaining function of riparian areas, and protecting

water quality, air quality, wildlife and fish habitat. It is important to recognize that the Rules address

minimizing impacts versus having no impact. This is a practical approach to both maintaining an

economically viable forest industry and protecting other forest resources.

The Rules vary by georegion and by stream type. There are seven georegions defined as geographic

areas with similar vegetation type, climate, physiography. There are nine stream types defined by stream

size (stream flow) and beneficial use. This approach endeavors to recognize that forests are dynamic, with

regional differences resulting from inherent characteristics and disturbance regimes.

The Forest Practices Act and Rules are considered a Best Management Practices (BMPs) program. BMPs

are defined as practices that are practical and effective at reducing non-point source pollution to standards

compatible with water quality goals. Once an agency’s BMPs are approved by the state water quality

regulatory agency, they are certified as the water quality management plan (WQMP) for landowners that

implement them. A WQMP illustrates how a landowner will achieve acceptable water quality. When forest

landowners properly implement BMPs, they are actually implementing a WQMP designed to maintain water

quality. It is the responsibility of the ODF to monitor the effectiveness and implementation of BMPs in

achieving that objective.

The ODF Forest Practices Monitoring Program implemented this study to monitor compliance with BMPs

on non-federal forestland. The BMP Compliance Monitoring Project (BMPCMP) was a three-year project

designed primarily to look at how the department, landowners, and operators are implementing the Forest

Practice Rules relating to water quality. The first year of the project (1998) was a pilot study used to revise

the site selection and data collection protocols, determine the needed sample size, and provide preliminary

compliance results. During the 1999 and 2000 field seasons, the final version of the BMPCMP was

implemented. The goal of the BMPCMP was to identify the level of forest operations in compliance with the

Forest Practice Rules based on a statistically reliable sample and to determine if adjustments to the

administration of the compliance program are needed, such as areas where forest practice rule language

can be clarified, administration of the rules can be improved, or where additional education and training are

needed.

The BMP Compliance Monitoring Project is just one component of the Forest Practices Monitoring Program

(Dent, 1997). The strategy of the monitoring program is to monitor compliance separately from

effectiveness and validation monitoring. The Forest Practices Monitoring Program currently coordinates

separate projects to monitor the effectiveness of Forest Practice Rules with regard to landslides, riparian

function, stream temperature, chemical applications, and turbidity and sediment delivery from forest roads.

Validation monitoring is being conducted to test the basic assumptions underlying BMPs.

Background

The ODF achieves BMP compliance through a balanced program of rule education, technology transfer,

incentives, and enforcement. The ODF employs 52 forest practice foresters (FPFs), stationed in 25 unit
BMP Compliance Report.doc/Jaz B 3

and district offices throughout the state. Through a series of inspections and field visits, FPFs work with

landowners and operators to facilitate proper implementation and compliance with the Forest Practice

Rules. Not all operations are inspected by FPFs due to extremely heavy workloads, therefore, FPFs

prioritize operations to determine inspection schedules. When rules are not properly applied and an

unsatisfactory condition exists, the FPF may issue a written statement of unsatisfactory condition that

requires immediate action to prevent damage. When a violation exists and damage occurs, the FPF may

issue a citation and a repair order. A civil penalty may also be assessed.

Citation records are a valuable monitoring tool, but a statistically reliable sample of BMP compliance is needed

to more precisely determine the degree to which the compliance program is producing the desired results and to

identify areas of low compliance. Furthermore, more detailed information is needed on compliance rates of

specific practices and rules and to quantify resource damage that occurs as a result of noncompliance.

Compliance Monitoring in Other States

Other states have implemented projects to assess compliance rates and effectiveness of administration

programs to protect natural resources. Most commonly these projects have utilized an interdisciplinary

team approach and combined compliance and effectiveness monitoring. Projects typically consist of some

sort of rating criterion on which to assess both compliance and effectiveness. Ellefson et al. (2001) found

that 34 states had instituted some sort of compliance monitoring project of voluntary or mandatory forest

practices requirements. The following is a summary of some of these other programs.

California

A 1999 report from California (CDF, 1999) evaluated both compliance and effectiveness of Forest Practice

Rules in protecting water quality. Registered professional foresters and an earth scientist evaluated forest

practices on 150 randomly selected sites. The authors conclude that California Forest Practice Rules are

effective at protecting water quality, since 95% of the sediment issues resulted from noncompliant

practices. Roads and crossings had the greatest potential to deliver sediment to streams. Of particular

concern were stream crossings; construction, spacing, maintenance, and size of drainage structures;

erosion of fill from road discharge; and sidecast on steep slopes. Compliance rates were lowest for roadrelated rules and roads had a much greater impact on water quality than landings and skid trails.

Compliance rates related to the protection of streams and lakes were very high.

Idaho

An interdisciplinary team was used consisting of a representative from forest landowners, Idaho

Department of Fish and Game, U.S. Forest Service, Plum Creek Timber Co., Bureau of Land Management,

Department of Lands, and DEQ (Idaho Department of Health and Welfare, 1997). The study focused on

practices that could result in delivery of pollutants to streams. Effectiveness and implementation was rated

as poor to excellent. Forty sites were monitored from July through September 1996. Results indicate 97%

compliance. Rule effectiveness was rated as 99% effective, yet half the sites delivered sediment to the

stream as a result of forest activity. Most common departures from BMPs were associated with road rules.

Minnesota

The Minnesota Department of Natural Resources began implementing an effectiveness and compliance

monitoring program in 2000. Surveys were conducted on 108 sites by an independent contractor across all

land ownerships. These surveys were conducted to collect baseline harvesting and management data for

future annual monitoring. Areas identified as having the lowest compliance were retention of required filter
BMP Compliance Report.doc/Jaz B 4

strips and RMA vegetation along streams, lakes, and wetlands; effective diversions of road drainage at

approaches to streams and wetlands; rutting levels of roads and skid trails; and leave-tree retention levels

specific to management classifications.

Washington

In Washington, three “surveyors” accompanied by one Department of Natural Resources (DNR) staff person

evaluated compliance and public resource damage on private forest operations (TFW, 1992). Data forms and

questionnaires were developed to assess all Forest Practice Rules that applied to the site. One hundred and

ninety-one sites were randomly selected from notifications and assessed during the summer of 1991. Low

compliance was most commonly associated with maintenance of active and inactive roads, harvest activities

within riparian management areas, and “special conditioning,” which refers to wildlife protection.

Montana

In the state of Montana, application and effectiveness of Forest Practice Rules were rated on federal, state,

and both non-industrial and industrial forestland in 1994 (Frank, 1994), 1996 (Mathieus, 1996), and 1998

(Fortunate et al., 1998). Three to four interdisciplinary teams were used, each consisting of a fish biologist,

a forester, a hydrologist, a conservation group representative, a road engineer, and a soil scientist. Fortytwo to 47 sites were monitored for each year of surveys. Results indicated that in 1994, 1996, and 1998,

compliance with minimum BMP requirements was 91%, 92%, and 94%, respectively. Compliance was

83%, 81%, and 89% for high-risk sites in 1994, 1996, and 1998, respectively. The greatest impacts and

highest percent of departure from BMPs were associated with road drainage and maintenance during all of

the monitoring periods.

West Virginia

The West Virginia Division of Forestry conducts compliance surveys of logging BMPs on a recurring basis.

Surveys have been completed and reported in 1981, 1987, 1991, and 1996. West Virginia’s BMPs focus on

conducting road, landing, and skid trail practices to limit erosion and sediment delivery to streams. The most

recent report (Egan et al., 1998) discusses results from 95 sites. All sites were surveyed by a single outside

consultant in 1995 and 1996. The majority of sites were non-industrial private ownership (79) and the rest

(16) were industrial private ownership. Areas of lowest compliance were road and skid trail drainage relief

and stabilization of exposed soils. Compliance rates were highest on industrially-owned sites.

Maryland

In Maryland, survey teams were formed of representatives from each agency with a vested interest in

resource protection (Koehn and Grizzel, 1995). Team members were fixed for the field season, yet varied

between sites. A field-based questionnaire was implemented on sites grouped by physiographic region.

Compliance was rated qualitatively as: excellent, fair, good, or poor for each BMP. They also used a

landowner/operator questionnaire to determine BMP awareness. Ninety-nine sites were sampled from

summer through fall 1994. Results indicate an 82% compliance rate overall. Poorest compliance was

associated with soil stabilization on road fill and cut slopes, skid trails and road drainage.

Florida

Compliance with best management practices has been monitored by The Florida Division of Forestry since

1981 (Vowell, 2000). Compliance monitoring is done biennially on 150-200 sites by a professional forester.

Virtually all aspects of the operation are assessed, and the site is given a pass/fail based on the data

collection. Statewide compliance with BMPs ranged from 84 – 94%, and averaged over 90% through 1993.

Surveys conducted in 1995, 1997, and 1999 found results of 96% compliance each year.
BMP Compliance Report.doc/Jaz B 5

Virginia

A 1997 report from the Virginia Department of Forestry reported that sediment production resulting from

timber harvesting has increased in Virginia (Austin, 1997). This increase was estimated using a computer

model that utilized measured sediment volumes from research and monitoring sites, BMP compliance rates,

and the area logged each year. The model estimates sediment load from harvesting, burning, and bulldozing;

sediment reduction from BMPs; and the post-harvest rates of decline in sediment yield. The increased

sediment production was attributable to two factors: decreasing compliance with Forest Practice Rules and

increasing rate of harvest. Results indicate that as compliance with BMPs decreased from 1992 through

1997, the sediment yield increased. In addition, the estimated land area being logged each year increased.

Southern Group of State Foresters

A regional BMP Task Forces was assembled in the fall of 1993 to establish criterion for BMP Compliance

Monitoring (Southern Group of State Foresters, 1994). Under consideration were the frequency, site

selection, categories to be evaluated, methodology, enforcement issues, and precision. The group

recommended a biennial review on sites that were no more than 2 years old. The sites are selected using a

random, stratified process, and the sample size should be large enough to achieve a 5% precision level.

Timber harvesting, site preparation, roads, stream crossings, streamside management areas, chemical

applications, burning and harvest plans should be evaluated. Evaluations and reports are to be provided at

the rule level, the practice level, and at the operation level. BMPs are to be compliant or noncompliant (i.e.,

not marginally noncompliant) and operation compliance level should be based on the number of practices that

applied at the site. A risk or impact assessment should be made. If significant noncompliance is identified

and the party is unwilling to comply with correction recommendations, enforcement should be taken.

Related Monitoring and Research

ODF Stream Rule Research

Compliance rates can be a function of landowner support of current rules and regulations. Hairston-Strang

and Adams (1997) researched the response of landowners and operators regarding Oregon 1994 stream rule

changes. This study looked at what kinds of factors influenced the willingness and support of industrial

landowners, non-industrial private landowners and logging operators to participate in the administrative

program. There was a significant difference in response based on survey group (industrial, non-industrial,

and operator). Hairston-Strang and Adams interpreted this as a reflection of different social norms for these

groups and recommended reaching the respective groups with techniques that speak to these norms.

Cost and personal control were most commonly listed as reasons for lack of support. Factors which

influenced support for the rules include understanding and involvement in the rule revision process (without

prerequisite of technical knowledge), economic incentives, rules based on social norms, and good science

and assurance of no increased regulation.

The Hairston-Strang and Adams study documented a sentiment that due to the importance of road

sediment control, more literature needs to be available to operators on such topics as waterbars, culverts

and road fills. Forest practice foresters should emphasize beginner and small ownership reforestation

inspections, give less attention to proven operators and landowners, and be freed up from paperwork.

Water Quality in Relation to Compliance Monitoring

Results from past monitoring and research indicate that road systems are by far the greatest chronic

sources of sand and/or fine sediment to stream systems. Of all the activities that take place on a forest
BMP Compliance Report.doc/Jaz B 6

operation, roads are considered to have the greatest potential to impact water quality (Megahan and

Ketcheson, 1996). Compliance monitoring may reveal more than water quality monitoring, especially in the

arena of roads (MacDonald and Smart, 1993). Instream measures are an integration of everything

upslope. Consequently, instream measurements can be a diluted or exaggerated version of what is

occurring higher up in the channel network or on adjacent slopes. It is usually easier to accurately identify

a drainage-related sediment source and to quantify the volume of sediment it produced than it is to

measure sediment in the stream and work backwards to the source.

Burroughs and King (1989) demonstrated that certain practices can reduce the delivery of road sediment to

stream channels. Examples include surfacing the road, erosion control on fill slopes, increasing distance

between fill slopes and streams, reducing connectivity to stream crossings, adequate and functional cross

drains, and rocking ditches (Burroughs and King, 1989; Skaugset and Allen, 1998). Implementation

monitoring of these practices can improve our understanding of how to further minimize road-related impacts.

OBJECTIVES AND MONITORING QUESTIONS

The purpose of this project is defined by the objectives below, with specific monitoring questions created to

outline the types of information to be gathered and analyzed.

Objectives

The ODF BMP Compliance Monitoring Project was designed based on previous monitoring and research

studies of Forest Practice Rules and utilized lessons from projects undertaken by other states. The specific

objectives are as follows:

1) Determine, through statistically valid sampling, the level of operator/landowner compliance with best

management practices (BMPs) designed to protect water quality, and

2) Identify opportunities to improve program administration, operator education, and technology transfer,

or rule clarity.

Monitoring Questions

In order to meet these objectives, the following monitoring questions were designed:

1) How often did operators comply with BMPs described in the Forest Practice Rules pertaining to water

protection, road construction and maintenance, harvesting, and high-risk sites?

2) Have stream crossing structures on newly constructed and/or reconstructed roads been designed and

installed according to ODF guidelines regarding fish passage and the 50-year peak stream flow event?

3) How do the statistical sample results compare with results based on forest practice foresters (FPF)

inspections? Is there a correlation between number of FPF inspections and compliance rates? How

statistically representative are the results of this project?
BMP Compliance Report.doc/Jaz B 7

4) Are there particular rules that consistently have a higher or lower level of compliance? If the latter, can

the guidance and/or rule language be modified to improve compliance? Are there educational and

training opportunities/materials regarding those rules?

5) When BMP compliance is inadequate, to what extent are quality and function of riparian areas, stream

channels, and/or fish habitat compromised?

STUDY DESIGN

At selected harvest unit sites, practices and features within that unit (harvest practices, roads, skid trails,

etc.) were evaluated for compliance with 150 Forest Practice Rules relating to the protection of water

quality and fish habitat. A brief description of the site selection process and data collection methodology

follows. Please visit http://www.odf.state.or.us/FP/fpmp/default.htm to view the detailed protocol for this

project. Stream crossing structures (bridge, culvert or ford) were evaluated for fish passage and 50-year

event stream-flow capacity using a separate selection process and field protocol. These detailed stream

crossing results are reported in a supplement to this report, Compliance with Fish Passage and Peak Flow

Requirements at Stream Crossings (ODF, 2002A). The stream crossing report will not be discussed further

in this document, but can be found online at http://www.odf.state.or.us/FP/fpmp/default.htm.

Site Selection

Defining the Population

The focus of this project was to monitor forest operations that had to comply with 1994 rule revisions and

that had the potential to affect waters of the state (WOS). Therefore, “eligible notifications” had to meet

both of the following criteria to be field surveyed:

• harvest units associated with any stream or wetland, and

• harvest units with a 1998 notification.

Stratification

The sample was stratified by district, stream classification, and ownership to address three characteristics

that warranted further consideration in the sampling design. These included:

• Regional differences in the numbers of notifications and types of practices implemented,

• Heightened concern for fish-bearing streams, and

• Differences between industrial, non-industrial, and other landowners.

District Stratification. Oregon is partitioned into 14 ODF districts covering the state. FPFs in district offices

are responsible for administering the FPA on non-federal ownership that fall within their areas. The sample

distribution was weighted to match that of the statewide district distribution of notifications, with goal of a

minimum of 10 units per district.

Stream Classification. The ODF uses a designation of Type F for fish-bearing streams, Type D for

domestic water sources that are not fish-bearing, and Type N for streams that are neither fish-bearing nor

domestic water sources. Streams with no classification were referred to as “unknown." Because of the

critical issues surrounding fish habitat, sampling stratification was intentionally biased to capture more fishbearing streams. An additional justification was that most fish-bearing streams are likely to have small

Type N streams as tributaries within the operation unit. Therefore, the selection process, although biased

towards fish-bearing streams, was still likely to capture a sufficient number of small Type N streams for

analysis. Consequently, the goal was to have 60% of the units contain fish-bearing streams. The remaining
BMP Compliance Report.doc/Jaz B 8

40% were partitioned according to the relative proportions of Type N and unknown-usage streams in the

population. The result was 10% of the units being known N or D streams and 30% unknown. Streams of

unknown-usage were updated to either Type F, D, or N upon survey of the unit, thus potentially altering this

distribution somewhat. The weakness of this stratification is that it may undersample steep terrain as these

units are less likely to have Type F streams.

Land Ownership Stratification. The landowner classes were industrial, non-industrial, and other. “Other”

includes lands owned by state or local governments, as well as nonprofit organizations. While the numbers

of notifications for industrial versus non-industrial were comparable (1,998 and 1,578), the average size of

an operation with a stream was twice as large for industrial (137 acres) than for non-industrial landowners

(64 acres). Therefore, the sample size for each landowner class was weighted to be proportionate to the

total acreage of operations with streams for each class. The relative sampling proportions used, based on

acreage, were 70% industrial, 20% non-industrial, and 10% other (Table 2). It is important to note that the

operation size only applies to operations with streams and may be artificially high due to this focus.

Table 2. Landowner Population Characteristics

Landowner Class Number of

Notifications Average Acres Total Acres Percent of Total

1 State, Local, Other 433 84 36,184 9%

4 Non-Industrial 1,578 64 101,464 25%

5 Industrial 1,998 137 274,282 67%

Selection

A total of 4,075 eligible notifications were compiled with a query of the Forest Activities Computerized

Tracking System (FACTS) database, then stratified by the criteria described above.

Based on the results of the pilot study, it was estimated that a sample of roughly 190 units would be

needed to represent compliance for the defined population with 95% confidence. Notifications were

randomly ordered within each of the sub-samples created by district, stream type, and ownership

stratification and then reviewed for meeting the criteria of this study. In the process of identifying and

surveying the desired sample of qualified units from each sub-population, a total of 464 notifications were

reviewed, with 275 disqualified during this process (Table 3).

Table 3. Units Reviewed During Selection Process Which Did Not Meet Survey Criteria

Reason Unit Disqualified Units

Did Not Meet WOS Criteria 128

Did Not Meet Harvest Criteria 119

Operation Did Not Occur (51)

Operation Still Active (27)

Non-Harvest Operation (16)

Land Use Change Following Operation (11)

Non-Forest Practices Operation (8)

Removal of Hazard Trees Only (6)

Survey Could Not Be Arranged 25

Landowner Not Available (13)

Access Denied (12)

File Not Found 3

Total Units Disqualified 275
BMP Compliance Report.doc/Jaz B 9

Of these 275 operations, 124 were not surveyed because they did not have any waters of the state

associated with the operation. A total of 119 operations were dropped for a variety of harvest criteria:

51 operations did not occur, 27 were still active at the time of review, 16 were non-harvest activities only

(pick-up log decks, site preparation, or road maintenance), 11 were land-use changes, 8 were various non

forest practices related activities, and 6 were removal of hazard trees (along roads, homes, or utility lines).

Twenty-five operations were dropped because surveys could not be arranged, with the landowner

unavailable for 13 of these and access denied by the landowner for 12. The file was misplaced and could

not be reviewed for three of the notifications selected.

Site Characteristics

Data collection was completed on a total of 189 units around the state (Figure 1). The ownership,

classification and stream type are listed in Table 4. Distributions vary somewhat from targets as units were

dropped for a variety of reasons over the course of the survey period. Seventy-seven percent of the

sampled units were under industrial ownership, 15% non-industrial, and 8% were under other ownership

(Figure 2). Fifty-six percent had Type F streams and 44% had only Type D or N streams or significant

wetlands. The distributions of stream types and RMA harvest prescriptions are detailed in the Vegetation

Retention Along Streams portion of the Results section of this paper.

Figure 1. Location of Units Surveyed for BMP Compliance
BMP Compliance Report.doc/Jaz B 10

Table 4. Units Surveyed by Ownership and Stream Class for Each ODF District

Total Landowner Class Stream Type

ODF District Visited Industrial Non-Ind. Other Type F No Type F

Astoria 10 7 1 2 3 7

Tillamook 9 7 0 2 5 4

Forest Grove 28 22 4 2 15 13

West Oregon 24 19 4 1 10 14

Clackamas-Marion 16 8 6 2 10 6

Linn 9 8 1 0 4 5

Eastern Lane 14 14 0 0 11 3

Western Lane 10 8 1 1 7 3

Douglas 9 7 2 0 5 4

Northeast Oregon 9 6 3 0 4 5

Coos Bay 19 14 4 1 12 7

Southwest Oregon 11 8 0 3 7 4

Klamath-Lake 14 11 3 0 10 4

Central Oregon 7 6 0 1 2 5

 Total 189 145 29 15 105 84

Figure 2. Distribution of Units by Ownership Class

Rule Focus

The Forest Practice Rules designed to protect water quality and fish habitat are detailed, complex, and

span multiple rule divisions. Potentially, 150 rules could be assessed at any given unit, with multiple

applications of some rules possible.

Rules in 10 divisions were assessed: Planning Forest Operations (division 605), Treatment of Slash

(division 615), Chemical and Other Petroleum Products (division 620), Road Construction and Maintenance

(division 625), Harvesting (division 630), Vegetation Retention Along Streams (division 640), Significant

Wetlands (division 645), Lakes (division 650), Other Wetlands and Seeps (division 655), and Operations

Near Waters of the State (division 660). The individual rules surveyed and rule requirements are detailed

in the Results section of this report.

145

29 15

0

50

100

150

200

Industrial Non. Indust. Other

Ownership Class

Number of Units
BMP Compliance Report.doc/Jaz B 11

Rules that are designed to maintain productivity and wildlife habitat or that describe the purpose of the

rules, have not been assessed by this project for three reasons. First, the focus of this project is BMPs that

are designed to protect waters of the state (WOS). Secondly, some of the rules must be assessed at the

time of application, prior to application, or a few years after application. The BMP evaluations occurred one

to two years after application. Finally, rules that describe the purpose and background of the division do

not define how a practice should be implemented and therefore cannot be readily monitored for

compliance.

FIELD AND ANALYTICAL METHODS

In an effort to answer the monitoring questions, the ODF developed a protocol with two approaches to data

collection: (1) compliance rating data and (2) numeric data. Data collected from these two approaches

were combined to quantify compliance and impacts on riparian and channel conditions. A brief description

of these methods follows. Please refer to the protocol for this project (Oregon Department of Forestry’s

BMP Compliance Monitoring Project) for a detailed description of the data collection methods and field

forms. This protocol, as well as information on other projects, is available online at

http://www.odf.state.or.us/FP/fpmp/default.htm.

Compliance Rating System

An experienced, retired FPF evaluated each unit using the compliance rating system. The compliance

rating system provides qualitative data regarding rule compliance. All the rules that applied to each unit

were rated as Compliant or Noncompliant. Noncompliance, when identified, was further described as

Administrative, Potential Resource Impact, or Resource Impact. For the purposes of this project,

observable impacts to riparian, stream channel, or wetland conditions were used as surrogates for water

quality impacts. Instances when vegetation-retention rule requirements were exceeded were also

documented and are discussed in the Results section.

Administrative Noncompliance

Administrative noncompliance refers to an activity that did not comply with notification and/or written plan

requirements described in the rules. For example, if a unit was harvested within 100 feet of a Type F

stream without a written plan, this would have been an administrative noncompliance. This type of

noncompliance was for rules which deal only with procedural and documentation requirements and not

those directly governing on-the-ground harvesting practices which could potentially lead to resource

impacts.

Potential Resource Impact

There were other situations where noncompliance was with a practice in the field, yet there were no

immediate, identifiable impacts to riparian or channel conditions. For example, OAR 629-615-100 (2)

requires the disposal of unstable slash accumulations around landings to prevent their entry into streams.

Noncompliance with this rule may identify unstable landing slash that has not entered the stream, but has

the potential to impact riparian or channel conditions in the future. This would be identified as a potential

resource impact.

Resource Impact

Noncompliant practices that result in significant loss of riparian vegetation, channel alteration, or delivery of

sediment, slash, or other waste to WOS were considered to have a resource impact.
BMP Compliance Report.doc/Jaz B 12

Numeric Data Collection

A two-person field team also surveyed the units collecting numeric data. The numeric data are a

combination of quantitative and categorical assessments. For example, in the case of riparian

management areas, the BMP field team established transects spaced 200 feet apart for the entire length of

the RMA. Along each transect, the team documented area (quantitative) and source (category) of

vegetation and ground disturbance, accumulations of slash in the channel (category) width of no-cut buffers

(quantitative), sediment delivery (quantitative and source category), and effects of ground and vegetative

disturbance on stream and riparian resources (quantitative and categorical). In addition, if the riparian area

was managed to meet a basal area target, the team conducted a 100% cruise of conifers and other trees

and snags that count towards the basal area target (quantitative). A similar approach was used for

notifications, written plans, wetlands, yarding, treatment of slash, road maintenance, road drainage, road

location, stream crossings, skid trails, temporary crossings, landings, waste areas, rock pits, and high-risk

sites.

Quality Assurance and Quality Control

In order to test the reliability of the numeric data collection methods, six units were revisited and

measurements of RMA and road conditions repeated. The results of these repeat measurements

demonstrate the degree to which the numeric data can vary. For example, the road length recorded for

every location and drainage condition category when revisited was within two 100-foot stations of that

recorded on the first visit (see Tables C-1 and C-2 in Appendix C). This variation was expected because

conditions were categorized into stations, and because of the error involved in measuring great distances

of road with a hip chain or odometer.

The reliability of the numeric data collection is most critical for the survey of RMAs because it was used to

directly evaluate compliance. Ten RMAs were resurveyed for uncut tree width. The measured uncut width

did not differ between the two visits for a single transect in any of these ten RMAs (Table C-3 in Appendix

C). Four RMAs were resurveyed for tree counts, with differences between visits of 0, 1, 1 , and 5 trees

(Table C-4 in Appendix C). These four RMAs were also resurveyed for basal area, with differences

between visits of 3.7, 1.5, 4.6, and 3.0 total square feet (Table C-5 in Appendix C). These variations were

due to the difficulty in determining the exact beginning or end of an RMA and whether particular trees were

in the RMA or out of the unit at these RMA edges.

Sediment Sources

The Forest Practice Rules, in part, are designed to minimize sediment delivery to stream systems, and

interpretation of compliance often hinges on whether sediment was delivered to the stream or not. For the

purposes of this study, all sediment delivery reported here is the result of noncompliant forest practices.

Included is sediment which is observed to have eroded into a channel, material that was placed so that it is

actively or imminently eroding to the channel (generally below the high water line, e.g., temporary crossing

fill not completely removed), and instances where there is clear evidence of sediment which has been

eroded to a channel and transported off site by an erosional feature (e.g., rill, gully, concave area left after a

landslide). Sediment volume estimates were made from observed delivered material or from concave

erosional features. Because of the lack of precision of this method, sediment delivery volumes were

estimated within broad categories: 0-1 cubic yards, 1-10 cubic yards, 10-100 cubic yards, and greater than

100 cubic yards.

There are limitations to this approach to sediment input monitoring. This approach captures only sediment

input that can be traced during the dry, summer field season. Road maintenance practices themselves can
BMP Compliance Report.doc/Jaz B 13

eliminate evidence of erosion. In addition, over time, evidence of erosion can be obscured by vegetation.

The ODF has done extensive work assessing forest practices and landslides (Robison et al., 1999) and on

the potential of forest roads to deliver sediment to streams (Skaugset and Allen, 1998), but more monitoring

is needed on chronic sources of sediment from wintertime equipment operation and road use. The ODF is

currently conducting a study to evaluate the impacts of road use and surfacing material on stream turbidity

during wet weather.

Calculating Compliance

The rating system and the numeric data were used to assess the same rules. The numeric data were used

to report feature conditions and distributions (e.g., lengths of road by location or drainage type, lengths of

RMA by prescription used, number of landings in a unit, etc.). The numeric data were also drawn on to

determine compliance for 52 rules with numeric criteria or measurable standards written into the rules. For

example, the Riparian Vegetation Retention rules provide precise measures of compliance that can be

evaluated numerically (e.g., no-cut buffer widths, basal area retention, etc.). Other rules require operators

to meet subjective requirements, such as minimize and avoid resource impacts. These 67 rules require

judgement on the part of an experienced forest practice forester or natural resource specialist to determine

compliance. For example, road construction and maintenance rules require that operators locate roads to

minimize the risk to waters of the state and avoid steep slopes. The numeric data can be used to describe

the percent of roads in different locations, but the compliance assessment data is needed to assess if those

roads were in compliance with these sort of subjective road location rules. Compliance for the remaining

30 rules evaluated was determined by combining both the numeric and compliance assessment data.

These rules were those for which compliance could be measured by either method (e.g., removal of all

petroleum-related products from the unit). The distribution of these three sources of compliance

determinations is shown in Figure 3.

Figure 3. Sources of Rule Compliance Determination

Compliance rates are calculated and reported at a unit level and at a rule level based on the total number

of rule applications evaluated for each unit or rule. For 70 rules, compliance was evaluated once for each

unit as a whole (e.g., reforestation), and for 80 rules, it was evaluated for each feature to which it applied

within the unit (e.g. removal of temporary crossings).

53

67

30

0

20

40

60

80

Numeric Data Compliance

Assessment

Both

Compliance Source
BMP Compliance Report.doc/Jaz B 14

RESULTS

Surveys were conducted on 189 harvest units for the applications of up to a 150 rules relating to specific

harvesting practices and features that could potentially impact water quality. This resulted in the evaluation

of compliance and resource-impacts for 13,506 total BMP applications. Survey results are discussed in

detail at two levels: (1) compliance rates by unit surveyed (unit level) and (2) compliance rates by rule

surveyed (rule level). The unit-level results summarize overall compliance for each of the 189 units

surveyed. The rule-level results summarize compliance for all applications of each of the rules surveyed.

See the Field and Analytical Methods section for a detailed description of how compliance rates were

calculated.

Unit-level Compliance

The average unit-level compliance rate was 96.1%. Compliance rates for each unit ranged from a low of

78.8% (26 compliant practices out of 33 applied) on one unit to 100% compliance on 46 units (Figure 4).

Figure 4. Frequency Distribution of Unit-Level Compliance Rates 

(All units had a compliance rate of 79% or greater.)

Only a portion of all rules considered actually applied to each unit, with an average of 49 different rules

applying per unit (ranging from 17 to 80). However, a particular practice was often repeated within a unit

(e.g., multiple stream crossings), for an average of 71 total rule applications surveyed per unit (ranging from

17 to as many as 419). The number of rules applied, number of rule applications, and compliance rate for

each unit are shown in Table A-1 of Appendix A. Because each of these rule applications is a BMP

designed to protect water quality, unit-level compliance is reported as the number of compliant practices

(compliant rule applications) out of the total number of rule applications surveyed on a unit. This means

that rules which applied more frequently weighed more heavily in unit compliance, but it creates a more

complete representation of compliance and potential resource impacts.

1

0

1

0 0 0

1

2 1

5 5

2

8

5

14

10

16 17

13

25

19

46

0

5

10

15

20

25

30

35

40

45

50

798081828384858687888990919293949596979899

100

Unit Compliance Rate (%)

Number of Units 

n = 189
BMP Compliance Report.doc/Jaz B 15

The achievement of high compliance with the Forest Practice Rules depends on effective interactions

between the Oregon Department of Forestry, landowners, and forest operators. It is important to recognize

the number of BMPs that must be properly implemented to put these results into perspective. A total of

13,506 individual applications of rules designed to protect waters of the state were surveyed for this project.

There are also a host of other rules that must be properly implemented on each unit (relating to wildlife

protection, soil productivity, and reforestation outside of RMAs, for example) that were not evaluated by this

project.

Unit Noncompliant Practices

There was an average of 2.7 noncompliant practices per unit (3.9% of total practices per unit) ranging from

0 to 14. In general, this number is not correlated to the number of practices that applied to a unit. All

noncompliant practices surveyed fell into one of three categories relative to water quality protection:

administrative issues relating only to notification and public record requirements (1.0 per unit), general

resource issues with the potential to impact future water quality (0.8 per unit), and observed impacts to

riparian and channel conditions (0.9 per unit). The number of noncompliant practices of each type for each

unit are given in Table A-1 in Appendix A, and specific resource impacts are further detailed in the Findings

section.

Unit Compliance Trends in Ownership

Three ownership classes were examined to investigate relationships between ownership and compliance:

industrial, non-industrial, and other (state and local government lands). The average unit-level compliance

rates were similar across all three ownership types (Table 5). The average unit-level compliance rates

were 96%, 97%, and 98% for industrial, non-industrial, and other ownerships, respectively. All ownership

classes had at least one unit which met the maximum compliance rate of 100%. The minimum unit

compliance rates for each of the three classes were more divergent, however, at 79%, 81%, and 94% for

industrial, non-industrial, and other ownerships, respectively. These differences may very well be due to

sample size, as the ownership classes with the least number of units surveyed have the lowest range of

compliance rates.

Table 5. Unit-Level Compliance Rates by Ownership Class

Unit-level Compliance

Statistics Industrial Non-Industrial Other

Number of Units 145 29 15

Average Unit Compliance 96% 97% 98%

Max. Unit Compliance 100% 100% 100%

Min. Unit Compliance 79% 81% 94%

Rule-level Compliance

The Forest Practice Rules and Regulations are organized into divisions addressing the various aspects of

forest operations and administration. Compliance for the 150 rules surveyed is reported here in 11 sections

which follow this formal division format. The exception is that all procedural and documentation

requirements are pulled from all divisions and reported in a single section titled “Administrative

Requirements.” Within each section, individual rules are further organized for reporting purposes into subsections by the specific harvesting practice or feature which they address (Table 6).
BMP Compliance Report.doc/Jaz B 16

Table 6. Rules and Regulations Sections Monitored

Chapter - Division Section Heading Practice or Feature Sub-Sections

629-610 Reforestation RMA Reforestation Timing

629-615 Treatment of Slash Harvesting Slash Disposal

629-620* Chemicals and Petroleum Products Chemical Applications

Petroleum Products*

629-625 Road Construction and Maintenance Road Location

Road Prism Design

Road Stream Crossing Design

Road Drainage Design

Road Drainage Maintenance

Road Waste and Stabilization

Road Vacating

Rock Pits

629-630 Harvesting General Yarding Practices

Felling and Harvesting Slash

Cable Yarding Near WOS

Ground Equipment Near WOS

Harvesting Waste

Landings

Skid Trails

Temporary Crossings

629-640 Vegetation Retention Along Streams Type F RMAs

Type D/N RMAs

629-645 Protection Measures for Significant Wetlands Significant Wetlands

629-650 Protection Measures for Lakes Lakes

629-655 Protection Measures for Other Wetlands Other Wetlands

629-660 Operations Near WOS Stream Channel Changes

All* Administrative Requirements Notification

Prior Approval

Written Plans

 * Includes one petroleum-related rule from Division 629-630

The compliance rate for all 13,506 rule applications surveyed for this project was 96.3%, with compliance

rates for each rule division section ranging from 70% to 100% (Figure 5). Both the Reforestation (division

629-610) and Operations Near WOS (division 629-660) sections had 100% compliance for all rules.

Compliance rates were lowest for rule applications in the Protection of Other Wetlands (division 629-655)

and Administrative Requirements (pulled from all divisions) sections, at 70% and 83%, respectively.
BMP Compliance Report.doc/Jaz B 17

Figure 5. Compliance Rates for Rule Sections 

(Number of rule applications surveyed for each section shown in boxes.)

What follows are detailed survey results for each of the specific practices or features surveyed for this

project and listed in Table 6. These include total compliance results for each sub-section, individual rule

compliance rates, explanation of the source of rule applications, and discussion of cause of noncompliant

practices and resulting impacts to water resources.

Reforestation (OAR 629-610)

Compliance was 100% for both reforestation rules evaluated within harvested portions of RMAs. Rules

were evaluated on a unit-wide basis, with no issues on any of the units to which they applied (Table 7).

The two rules evaluated for this section dealt with the requirements to begin (within 12 months) and

complete (within 24 months) reforestation when RMA harvesting reduced trees below the stocking

standard. These rules applied to 34 and 2 units, respectively, with the rest of the units surveyed either

harvested too recently for these rules to apply or exempted from reforestation requirements by zoning

changes to non-forestry land uses.

Table 7. Compliance Results for RMA Reforestation Timing Rules

# Rule Applications = total number of rule applications surveyed, Percent Compliant = percent of rule

applications compliant, NC: Pot. Impact = noncompliant rule applications with a potential riparian/channel impact

(e.g., placement of material in unstable location above stream channel), NC: Impact = Noncompliant rule

applications with an observed impact on riparian/channel resources (e.g., sediment delivery to a stream), NC:

Admin. = Noncompliant rule applications relating to administrative requirements only (e.g., failure to gain prior

approval for harvesting within 100' of a stream)

# Rule Percent NC: Pot. NC:

 Rule Number Rule Description Applications Compliant Impact Impact

629-610- 040 2 RMA Reforestation Begun w/in 12 Months 34 100.0 0 -

629-610- 040 3 RMA Reforestation Completed w/in 24 Months 2 100.0 0 -

 Compliance of All Section Rule Applications 36 100.0 0 -

36 1157 696 2495 6876 833 42 96 0 186 1089

0

10

20

30

40

50

60

70

80

90

100

Reforestation

Treatment of Slash

Chem./Petroleum 

Road Const./Maint.

Harvesting

Stream Vegetation

Significant Wetlands

Other WetlandsLake Protection

Operations Near WOS

Admin. Req'ments

Rules Section

Compliance Rate (%)
BMP Compliance Report.doc/Jaz B 18

Treatment of Slash (OAR 629-615)

Compliance was 98.2% for all applications of treatment of slash rules. There were 1,157 total applications

of 7 rules in this section (Table 8). These rules applied three aspects of post-harvest disposal of slash:

slash around landings that could enter streams, mechanical site preparation near waters of the state, and

protection of RMAs during prescribed burning.

Surveys for disposal of unstable slash accumulations (615-100 (2)) at 868 landings revealed 99.2%

compliance. Six noncompliant practices had a potential resource impact and one delivered slash to waters

of the state. Four mechanical site preparation rules (615-200 (1), (2), (3), (4)) evaluated unit-wide found 14

total noncompliant practices on 77 units. These resulted in seven cases of potential sediment or slash

delivery to WOS, five cases of observed slash delivery, and two cases of observed sediment delivery. The

lowest compliance in this section was with mechanically-gathered slash placed in a stable location away

from WOS (629-615 200 (4)). Compliance was 89.6%, with eight noncompliant practices. The protection

of RMA vegetation and removal of RMA slash before burning (615-300 (2d) and (2e)) were 100% compliant

for all three units with broadcast burning.

Table 8. Compliance Results for Treatment of Slash Rules

# Rule Percent NC: Pot. NC:

 Rule Number Rule Description Applications Compliant Impact Impact

629-615- 100 2 Landing Slash - Unstable Accumulations Disposed 868 99.2 6 1

629-615- 200 1 Mech. Site Prep. - No Sed./Debris Delivery to WOS 77 94.8 1 3

629-615- 200 2 Mech. Site Prep. - WOS Filtering Distance Provided 77 97.4 2 0

629-615- 200 3 Mech. Site Prep. - RMA Soil Protected 52 100.0 0 0

629-615- 200 4 Mech. Site Prep. - Debris Placed Away From WOS 77 89.6 4 4

629-615- 300 2d Prescribed Burning - RMA Vegetation Protected 3 100.0 0 0

629-615- 300 2e Prescribed Burning - Chan./RMA Slash Removed 3 100.0 0 0

 Compliance of All Section Rule Applications 1157 98.2 13 8

Chemical and Other Petroleum Products (OAR 629-620)

Compliance was 94.3% for all applications of petroleum product and chemical application rules. There

were 696 total applications evaluated for six rules in this section. Compliance rates for individual rules are

discussed in two sub-sections titled Petroleum Products and Chemical Applications. Rule 630-400 (3) is

reported here with the Division 620 rules in the Petroleum Products sub-section for continuity of all

petroleum-related rules.

Petroleum Products. Compliance was 93.3% for the protection of steam and soil resources from petroleum

product pollution. There were 567 total applications of three rules in this sub-section. These rules were

evaluated for each of the 189 units surveyed. Compliance was 97.9% with the requirement to prevent the

leaking of petroleum products (620-100 (1)), with four noncompliant practices due to oil leaks on the

ground. No petroleum products were found delivering to WOS, but these cases were potential threats for

future water quality. Compliance was 100% for rule 620-100 (2) requiring adequate precaution be taken to

ensure no petroleum products enter WOS during the operation. The lowest compliance in this section was

with removal of all petroleum-related products from units. Compliance with this rule (630-400 (3)) was

82.0%. Noncompliant practices consisted of oil filters, oil containers, or grease-tubes found on 34 units,

mainly at landings. None of these were found near WOS, but were considered to be concerns for future

water quality.
BMP Compliance Report.doc/Jaz B 19

Table 9. Compliance Results for Petroleum-Related Rules

# Rule Percent NC: Pot. NC:

 Rule Number Rule Description Applications Compliant Impact Impact

629-620- 100 1 Petroleum Leaks Prevented 189 97.9 4 0

629-620- 100 2 Petroluem Delivery to WOS Prevented 189 100.0 - 0

629-630- 400 3 Petroleum-Related Waste Removed 189 82.0 34 0

 Compliance of All Sub-Section Rule Applications 567 93.3 38 0

Chemical Applications. Compliance was 98.4% for all rule applications in this sub-section. There were 129

total applications of three rules evaluated for the protection of waters of the state when applying chemicals

(620-400 (1, 2, and 5)). These rules applied to 43 units surveyed with herbicide applications (Table 10).

Compliance was 100% with protection requirements for both RMA vegetation and specified water

resources. Two noncompliant practices were observed, however, with adherence to product label

requirements (95.3% compliance). These were both from the direct application of herbicide to open small

wetlands and resulted in vegetation damage.

Table 10. Compliance Results for Chemical Application Rules

# Rule Percent NC: Pot. NC:

 Rule Number Rule Description Applications Compliant Impact Impact

629-620- 400 1 WOS Protected and Label Followed 43 95.3 - 2

629-620- 400 2 RMA Vegetation Protected 43 100.0 - 0

629-620- 400 5 Veg. w/in 10' of Specified WOS Protected 43 100.0 - 0

 Compliance of All Sub-Section Rule Applications 129 98.4 - 2

Road Construction and Maintenance (OAR 629-625)

Compliance was 97.6% for all applications of road construction and maintenance rules. There were 2,495

total applications of 33 rules in this section. These rules were evaluated for 80 units with new road

construction and 171 units with new or existing roads. New roads are those that were constructed

specifically to access the operation being surveyed following the 1996 road regulation revisions and were

generally constructed 1-3 years prior to survey.

In total, 148.4 miles of existing road and 38.5 miles of new road were surveyed for BMPs that establish

standards for effective road surface drainage. New roads, stream crossings, and rockpits were also

evaluated for location, design, construction, and stabilization BMPs relating to providing the maximum

practical protection of water quality and fish habitat.

Across all road rules, there were 61 noncompliant practices observed on 41 units. Of these, 23 had no

observed impact on riparian or channel conditions, but had the potential to impact resources (unstable

material or drainage maintenance issues). The remaining 38 noncompliant practices had observed impacts

due to erosion of fill or waste material (13), ineffective surface drainage design (12), inadequate drainage

maintenance (10) and machine activity in a channel (3). Resulting resource impacts were sediment

delivery (36) and stream channel disturbance (2). The compliance rates of specific road rules are detailed

in the road sub-section discussions which follow.

Road Location. Compliance was 100% for rules requiring roads be located to minimize stream crossings

and disturbance to water resources (Table 11). There were 240 total applications of three road location

rules. Each of these rules applied to the 80 units with new road construction.
BMP Compliance Report.doc/Jaz B 20

Table 11. Compliance Results for Road Location Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-625- 200 2 Disturbance to WOS Minimized 80 100.0 0 0

629-625- 200 3 Layout in Resource Areas Avoided 80 100.0 0 0

629-625- 200 4 Stream Crossings Number Minimized 80 100.0 0 0

 Compliance of All Sub-Section Rule Applications 240 100.0 0 0

New and existing road lengths were documented by the location categories shown in Table 12. This shows

the distribution of road locations surveyed and does not reflect compliance, as road construction can be

allowed in some resource areas if done properly and alternative locations do not exist. The location

descriptors are ordered from left to right by highest general potential to impact on water resources. Roads

in the “other” category are areas least likely to impact stream resources. Road location distribution was

similar for new and existing roads, with the greatest differences being in newly constructed road length

within RMAs and on slopes over 65%.

Table 12. Percent of New and Existing Road Lengths in Each Location

 Percent of Total Road Length Located in Each Category

Highest Res. Impact Lowest Res. Impact

Road Age

Number

of Units

Total

Length

(ft)

Percent

of Total

Length

High

Risk Site

High

Water

Seeps

Springs RMA

Slopes

>65% Other

New

Roads 80 203,100 21% 0.6% 0.0% 0.6% 0.0% 3.1% 95.6%

Existing

Roads 144 783,500 79% 0.6% 0.1% 0.1% 1.4% 1.2% 96.6%

Road Prism Design. Compliance was 99.4% for all applications of road prism design rules. There were 320

total rule applications of four rules evaluated for long-term road stability on 80 units with new road

construction (Table 13). Compliance was 100% for requirements minimizing road prism in resource areas

(625-310 (1)) and the end-hauling of construction waste material on steep slopes (625-310 (2)). There was

one potential resource impact noncompliance for the requirement that road widths be minimized (625-310

(3)), and noncompliance with the requirement for the stable design of road fills (625-310 (5)), resulting in

sediment delivery to a stream channel.

Table 13. Compliance Results for Road Prism Design Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-625- 310 1 Road Prism in Resource Areas Minimized 80 100.0 0 0

629-625- 310 2 Waste Material End-Hauled 80 100.0 0 0

629-625- 310 3 Road Width Minimized 80 98.8 1 0

629-625- 310 5 Road Fill Design Stabilize 80 98.8 0 1

 Compliance of All Sub-Section Rule Applications 320 99.4 1 1

Stream Crossing Design. Compliance was 94.1% for all rule applications in this sub-section. There were

204 total applications of five stream crossing design rules, four of which applied to each of the 51 new

crossings surveyed (Table 14). There were no temporary road crossings on any of the units surveyed. Fill

volume was minimized for all crossings (655-320 (1bA)), but stability of fill (625-320 (1bC)) was found to be
BMP Compliance Report.doc/Jaz B 21

an issue, with only 84.3% compliance. Unstable fill at eight crossings resulted in sediment delivery to the

stream channel. Sediment delivery also occurred from one crossing not designed to pass the 50-year peak

flow (625-320 (2a)) and three crossings with excess channel disturbance during installation (625-430 (1)).

Table 14. Compliance Rates for Road Stream Crossing Design Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-625- 320 1bA Design - Minimum Fill Volume 51 100.0 0 0

629-625- 320 1bC Design - Prevent Erosion of Fill/Channel 51 84.3 0 8

629-625- 320 2a Design - Pass 50-Year Peak Flow 51 98.0 0 1

629-625- 430 1 Construct. - Min. Machine Activity in Channels 51 94.1 0 3

629-625- 430 5 Temporary Road Crossings Removed 0 - - -

 Compliance of All Sub-Section Rule Applications 204 94.1 0 12

Because of their location, road stream crossings have the potential to greatly impact water quality. A

variety of numeric and categorical data were collected on a total of 157 existing stream crossings as well as

51 new stream crossings (installed under 1995 amended rules). This information, summarized in Table 15,

describes conditions for both new and existing crossings and does not necessarily represent compliance.

Table 15. Characteristics of 208 Road Stream Crossings Surveyed

Crossing Characteristics (sample size) Number of

Crossings

Percent of

Crossings

Stream Class (n=208)

 Small N 171 82%

 Small D 3 1%

 Small F 23 11%

 Medium F 10 5%

 Large F 1 1%

Feature Type (n=208)

 Round Pipe 179 86%

 Pipe Arch 4 2%

 Log Puncheon 2 1%

 Bridge 4 2%

 Ford 19 9%

Fill Depth (n=185 no fords or bridges)

 Less than 15’ 167 91%

 Greater than 15’ 18 9%

Fill Stabilization (n=185, no fords or bridges)

 Effectively Vegetated 106 57%

 Effectively Armored 57 31%

 None - Not Needed 11 6%

 Fill Unstable 11 6%

Road Drainage Design. Compliance was 97.3% for all rule applications in this sub-section. There were

993 total applications of eight road drainage design rules, most of which applied to both new and existing

roads (Table 16). Stream channel diversions were avoided (625-330 (2)) on all 80 units with new road

construction. Compliance was also 100% for ditches kept clear of slash and debris (625-420 (1)), the

construction of effective crossdrains (625-420 (2)), and the removal of road berms (625-420 (5)) on all 171

units with either new or existing roads.
BMP Compliance Report.doc/Jaz B 22

Table 16. Compliance Rates for Road Drainage Design Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-625- 330 1 Design - Effective Surface Drainage 171 86.5 14 9

629-625- 330 2 Design - Diversion of Streams Avoided 80 100.0 0 0

629-625- 330 3 Design - Effective Filtering at Stream Crossings 51 98.0 0 1

629-625- 330 4 Design - Effective Seeps/Springs Drainage 171 99.4 0 1

629-625- 330 5 Design - Drainage to Unstable Areas Avoided 7 71.4 2 0

629-625- 420 1 Condition - Ditches Cleared of Slash/Debris 171 100.0 0 0

629-625- 420 2 Condition - Effective Crossdrains Provided 171 100.0 0 0

629-625- 420 5 Condition - Road Berms Removed 171 100.0 0 0

 Compliance of All Sub-Section Rule Applications 993 97.3 16 11

The majority of road drainage design noncompliant practices were with the installation of an effective

overall road surface drainage design (625-330 (1)). Compliance with this rule was 86.5% for the 171 units

with roads. Roads in 14 units had the potential to impact riparian and channel conditions, and nine had

observed sediment delivery to a channel. Sediment delivery also resulted from noncompliant practices for

ineffective filtering of road ditchflow at one stream crossing (625-330 (3)) and one ineffective drainage

design of a road through a seep (625-330 (4)).

The lowest sub-section compliance was with avoiding drainage discharge to high risk, or landslide-prone,

slopes (625-330 (5)). Compliance with this rule was 71.4%, with noncompliant practices on two of the

seven units with new roads on high risk slopes. These were considered potential resource issues, with no

erosion or soil instability evident. Complicating compliance evaluation for this rule is the fact that one of

these two discharge sites was actually deemed to have been the best option for long-term water quality

protection. Given the specifics of this situation, the design of a road surface drainage relief point at this

particular high risk slope was considered less likely to cause slope or fill instability issues than would the

routing of this drainage water down the road surface.

Table 17. Distribution of Road Drainage Design Installed

Surface Drainage

Design Ditch/Culvert Outsloped Waterbars None Installed

Length (Miles) 79.2 73.0 31.1 3.5

Percent of Total 42% 39% 17% 2%

Because it is often directly connected to the stream system, installation of an effective road drainage

system is critical to reducing surface erosion, sediment delivery to channels, and landslide risk. The road

surface drainage design type installed was documented for 187 miles of new and existing road on 171 units

(Table 17). Drainage design was categorized for each 100-foot station as: ditch with culvert (42%),

outsloped road surface (39%), waterbars (17%), and no drainage installed (2%). These data are

summarized here to show the distribution of road surface drainage methods used and do not reflect

compliance rates, which is detailed above.

Spacing was also evaluated for 424 cross-drain culverts on roads that used a ditch and culvert drainage

method. Of these, spacing was considered likely to be inadequate for six cross-drains. The distance

between these culverts and the nearest uphill cross-drain or drainage break was great enough to likely

cause future erosion and stability issues.
BMP Compliance Report.doc/Jaz B 23

The dispersal of drainage water before it enters waters of the state is also critical to reducing sediment

delivery. One factor influencing the likelihood of sediment delivery is the unfiltered ditch length at stream

crossings. This is the length of road ditch draining directly into a channel without being filtered through

vegetation of the forest floor. This length was documented for the 51 new stream crossings surveyed and

represents the longer of the two lengths of unfiltered ditch approaching the crossing. This length averaged

41 feet per crossing, with 33 crossings having no unfiltered ditch draining to the channel and none greater

than 400 (Table 18).

Table 18. Unfiltered Ditch Length Draining to Channel at New Stream Crossings

Unfiltered Ditch

Length (Feet) 0 1 to 100 101 – 200 201 – 400 > 400

Number of

Crossings 33 12 3 3 0

Percent

of Total 65% 24% 6% 6% 0%

Road Drainage Maintenance. Compliance was 96.7% for all rule applications in this sub-section. There

were 369 total applications of three road drainage maintenance rules, each of which applied to all new and

existing roads surveyed (Table 19). Ineffective maintenance of road surface drainage (625-600 (2)) had

the lowest compliance rate of these rules at 94.2%. Noncompliant practices were observed on 10 units;

two were potential resource issues and eight had already resulted in sediment delivery to WOS. The

requirement to place removed ditch waste in a stable location (625-600 (7)) was also noncompliant on

two units, both resulting in sediment delivery. The openings of all 27 non-ford crossings on Type F streams

surveyed were free of significant obstructions (625-600 (8)). Compliance with fish passage and flow

capacity design requirements of new stream crossing structures was evaluated with a separate

methodology (Please see ODF Technical Report 14, Compliance with Fish Passage and Peak Flow

Requirements at Stream Crossings for results, online at http://www.odf.state.or.us/FP/fpmp/default.htm).

Table 19. Compliance Rates for Road Drainage Maintenance Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-625- 600 2 Maintenance - Surface Stability/WOS Protected 171 94.2 2 8

629-625- 600 7 Maintenance - Ditch Waste in Stable Location 171 98.8 0 2

629-625- 600 8 Fish Passage Maintained 27 100.0 0 0

 Compliance of All Sub-Section Rule Applications 369 96.7 2 10

As with drainage design, proper maintenance of the road drainage system is a critical means of reducing

surface erosion, channel sediment delivery, and landslide risk. Categorical data on drainage maintenance

condition was recorded for every 100-foot station for 187 miles of new and existing road on 171 units. This

data is summarized here to show the distribution of drainage maintenance conditions and does not reflect

compliance, which is detailed above. These surveys were conducted during the summer while Forest

Practice Rules require effective road drainage be maintained only during the wet season. Because of this,

compliance evaluations were based on evidence of drainage conditions and issues as they appeared to

have existed during the previous wet season and not those that had not yet weathered runoff. The impact

of hauling during wet weather is currently being evaluated through a separate study.
BMP Compliance Report.doc/Jaz B 24

Effective drainage conditions (functional ditch, outsloped road, and functional waterbars) made up 97% of

total road length. The remaining 3% was made up of ineffectively-maintained drainage conditions (rutted

road surface, bermed road with no drainage, eroding ditch, non-functional waterbars, and filled ditch),

shown in Table 20.

Table 20. Distribution of Road Drainage Maintenance Condition

Surface Drainage

Condition

Functional

Drainage Rutted Berms/NoDrainage

Eroding

Ditch

Non-Funct.

Waterbars

Filled

Ditch

Length (Feet) 957,400 9,900 8,500 4,200 3,500 3,100

Percent of Total 97.0% 1.0% 0.9% 0.4% 0.4% 0.3%

Road Waste and Stabilization. Compliance was 97.1% for all rule applications in this sub-section. There

were 258 total applications of four rules evaluated for the stabilization of exposed and potentially unstable

material (Table 21). These rules applied to 80 units with new road construction and 18 waste areas. There

were three noncompliant practices of unstable road debris (625-410) and four of exposed material not

stabilized (625-440 (1)). Sediment delivery to WOS resulted from one and three of the noncompliant

practices of these two rules, respectively. No logs or slash were found incorporated into any newly

constructed road fills (625-440 (3)) and all road waste areas were located on stable sites (625-340).

The frequency of roads with unstable conditions was tallied numerically by 100-foot stations with greater

than 2 feet of sidecast on slopes greater than 65% (potentially unstable sidecast), and the length of road

with unstable fill or cutslopes. Results show that the occurrence rate of these conditions is quite low, with

unstable sidecast, fillslopes, and cutslopes found along only 0.1%, 0.2%, and 0.2% of newly constructed

road length, respectively.

Table 21. Compliance Results for Road Waste and Stabilization Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-625- 410 - Debris/Waste Located to Protect WOS 80 96.3 2 1

629-625- 340 - Waste Areas Located on Stable Sites 18 100.0 0 0

629-625- 440 1 Exposed Material Stabilized 80 95.0 1 3

629-625- 440 3 Logs/Slash in Fill Avoided 80 100.0 0 0

 Compliance of All Sub-Section Rule Applications 258 97.3 3 4

Vacated Roads. Compliance was 96.2% for the one rule in this sub-section (Table 22). Vacated roads

surveyed on 26 units were required to be effectively drained and blocked following the operation (625-650

(2)). There was one noncompliant practice for a vacated road not adequately blocked and drained,

allowing vehicle traffic and potential water resource impacts.

Table 22. Compliance Rates for Vacated Road Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-625- 650 2 Vacated Roads Effectively Drained and Blocked 26 96.2 1 0

Rock Pits. Compliance was 100% for all rock pit rules. There were 85 total applications of five rules

relating to stability, location, waste, erosion, and vacation on 17 rock pits surveyed (Table 23).
BMP Compliance Report.doc/Jaz B 25

Table 23. Compliance Rates for Rock Pit Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-625- 500 1 Unstable Slopes and Water Quality Protected 17 100.0 0 0

629-625- 500 2 Location - Outside of Channels 17 100.0 0 0

629-625- 500 3 Petroleum Products/Waste in WOS Prevented 17 100.0 0 0

629-625- 500 4 Surface Erosion and Landslides Prevented 17 100.0 0 0

629-625- 500 5 Rock Pits Properly Vacated 17 100.0 0 0

 Compliance of All Sub-Section Rule Applications 85 100.0 0 0

Harvesting (OAR 629-630)

Compliance was 98.1% for all applications of harvesting rules. There were 6,876 total applications of 34

rules surveyed in this sub-section. These rules establish standards for harvesting practices designed to

minimize soil and debris from entering waters of the state and protect wildlife and fish habitat. Rules were

evaluated on a unit-wide basis for sub-sections dealing with harvesting practices (general yarding

practices, cable yarding near WOS, ground equipment near WOS, harvesting waste, and felling and

harvesting slash) for each unit surveyed. Rules were evaluated on an individual feature basis for subsections dealing with constructed features (landings, skid trails, and temporary crossings).

There were 45 noncompliant practices in this division with a potential resource issue, and 86 with an

observed impact. Of those with an impact, 45 were slash accumulations below a high water line, 32 were

sediment delivery, and nine were physical bed or bank disturbances. A more detailed discussion of

compliance and resource impacts for each harvesting sub-section is given below.

General Yarding Practices. Compliance was 99.5% for all rule applications in this sub-section. There were

407 total applications evaluated for three rules, each dealing with yarding practices related to slope (Table

24). Rules requiring soil protection for yarding on slopes over 35% (630-100 (2)) and uphill yarding

whenever practical (630-100 (6.1)) were evaluated for all 189 units surveyed. Soil protection requirements

for yarding on high risk slopes (630-100 (6.2)) applied to 29 units. There were only two noncompliances in

this sub-section, both with rule 630-100 (2), where deep yarding gouges on slope over 35% resulted in

sediment delivery to stream channels.

Table 24. Compliance Rates for General Yarding Practices Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-630 100 2 Soil Protected for Yarding on >35% Slopes 189 98.9 0 2

629-630- 100 6.1 Uphill Yarding Whenever Practical 189 100.0 0 0

629-630- 100 6.2 Soil Protected for Yarding on HR Sites 29 100.0 0 0

 Compliance of All Sub-Section Rule Applications 407 99.5 0 2

Felling and Harvesting Slash. Compliance was 92.0% for all rule application in this sub-section. There

were 722 total applications of four rules governing the felling of trees near WOS and the removal of

excessive slash accumulations below high water lines (Table 25).

Compliance with protection requirements on all 189 units for felling near WOS or on steep slopes (630-600

(2)) was relatively low at 83.1%. There were 32 noncompliant felling practices observed, 29 along small
BMP Compliance Report.doc/Jaz B 26

Type N streams and three along Type F streams. Of this total, 15 had a potential resource issue and 17

had an impact. Impacts were 15 slash accumulations below high water lines, one disturbance of stream

channel bed or banks, and one sediment delivery.

Compliance was also low (83.9%) for the removal of excessive slash from Type N streams (630-600 (3b)).

There were 155 units with Type N streams surveyed; three with accumulation considered potential

resource issues and 22 with slash accumulations below the high water line. Excessive slash in Type N

streams is described in the rule guidance manual as covering greater than 50% of the channel such that it

is difficult to walk up the channel or when stream function is impaired. Compliance with the removal of

slash accumulations on Type F and D streams and significant wetlands (630-600 (3a)) was much higher,

however, with only one noncompliant practice on 109 applicable units. All slash removed from WOS was

placed above high water lines (630-600 (3c)) for all 189 units surveyed.

Table 25. Compliance Rates for Felling and Harvesting Slash Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-630- 600 2 Felling - Stream Bed and Bank Protection 189 83.1 15 17

629-630- 600 3a Slash - Removed from F/D or S. Wetland 109 99.1 0 1

629-630- 600 3b Slash - Type N Stream Accums. Limited 155 83.9 3 22

629-630- 600 3c Slash - Placed Above High Water Line 189 100.0 0 0

 Compliance of All Sub-Section Rule Applications 722 92.0 18 40

Cable Yarding Near WOS. Compliance was 99.7% for all rule applications in this sub-section. There were

376 total applications of five rules evaluated for the protection of WOS related to cable yarding on 93 units

(Table 26). Compliance was 100% for soil and vegetation protection when cable yarding near WOS (630-700

(1)), minimizing cable yarding across WOS (630-700 (2)), minimizing the width of yarding corridors across

streams (630-700 (3.1)), and protection of channels and RMAs when yarding across Type N streams (630-

700 (5)). The lone noncompliant practice in this sub-section was with logs not completely suspended (630-

700 (4)) for 1 of the 10 Type F stream yarding corridors, resulting in sediment delivery to the channel.

Table 26. Compliance Rates for Cable Yarding Near WOS Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-630- 700 1 RMAs and Specified WOS Protected 93 100.0 0 0

629-630- 700 2 Yarding Across WOS Minimized 93 100.0 0 0

629-630- 700 3.1 Corridors - Number and Width Minimized 93 100.0 0 0

629-630- 700 4 Corridors - Type F/D Channel/RMA Protected 10 90.0 0 1

629-630- 700 5 Corridors - Type N Chan./RMA Protected 87 100.0 0 0

 Compliance of All Sub-Section Rule Applications 376 99.7 0 1

Ground Equipment Near WOS. Compliance was 99.2% for all rule applications in this sub-section. There

were 624 total applications of four rules evaluated for the protection of WOS related to ground-based

yarding equipment on 156 units (Table 27). The operation of this equipment in a stream channel (630-800

(2)) resulted in one noncompliant practice causing a potential resource issue and two causing sediment

delivery to a stream. There was also one potential resource issue resulting from a unit with excessive

stream crossings (630-800(3)) and sediment delivery resulting from excessive soil disturbance from

harvesting equipment operated near a stream (630-800 (7)).
BMP Compliance Report.doc/Jaz B 27

Table 27. Compliance Rates for Ground Equipment Near WOS

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-630- 800 1 RMAs and Specified WOS Protected 156 100.0 0 0

629-630- 800 2 Stream Channels Avoided 156 98.1 1 2

629-630- 800 3 Stream Crossings Number Minimized 156 99.4 1 0

629-630- 800 7 Disturbance Near Specified WOS Minimized 156 99.4 0 1

 Compliance of All Sub-Section Rule Applications 624 99.2 2 3

Harvesting Waste. Compliance was 96.5% for all rule application in this sub-section. There were 567 total

applications of three rules evaluated for general harvesting waste compliance at all 189 units (Table 28).

Compliance was 90.5% for the requirement that all debris, slash, and sidecast be placed to prevent entry

into WOS (630-400 (1)). There were 18 noncompliant practices with this rule, mainly from upslope

harvesting slash accumulations not stabilized following harvest. Seven of these had a potential resource

issue, seven had resulted in slash delivering to a stream, and four had resulted in delivery of sediment.

Soils exposed during harvesting were not stabilized on two units (630-400 (2)), resulting in one potential

resource issue and one instance of sediment delivery. No waste metal was found in WOS on any of the

units (630-400 (4)).

Table 28. Compliance Rates for Harvesting Waste Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-630- 400 1 Waste/Slash Prevented from Entering WOS 189 90.5 7 11

629-630- 400 2 Exposed Soils Stabilized 189 98.9 1 1

629-630- 400 4 Waste Metal Removed from WOS 189 100.0 0 0

 Compliance of All Sub-Section Rule Applications 567 96.5 8 12

Landings. Compliance was 99.8% for all rule applications in this sub-section. There were 3,472 total

applications of four landing rules (Table 29). These rules applied to the design, location, waste stability,

and drainage of 868 landings. No issues were found with the minimization of landing design size (630-200

(1)). One landing was located on an unstable slope (630-200 (2)), resulting in a potential resource issue.

Landing waste was not stabilized above WOS (630-200 (5)) for two landings, and drainage was not

effective (630-300 (4)) on five landings, all considered potential resource issues.

Table 29. Compliance Rates for Landing Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-630- 200 1 Design - Minimum Landing Size 868 100.0 0 0

629-630- 200 2 Location - Stable Sites Used 868 99.9 1 0

629-630- 200 5 Waste - Stablized to Protect WOS 868 99.8 2 0

629-630- 300 4 Drainage - Effective 868 99.4 5 0

 Compliance of All Sub-Section Rule Applications 3472 99.8 8 0

Skid Trails. Compliance was 96.4% for all rule applications in this sub-section. There were 636 total

applications of six rules governing location and drainage practices for skid trails on 106 units (Table 30).
BMP Compliance Report.doc/Jaz B 28

Compliance was 99.1% for rules requiring both sidecast stability and stable skid trail location (630-100 (3)

and (4), respectively). The only noncompliant practices were one case of sediment delivery to a stream

from unstable sidecast and one potential resource issue from an unstable skid trail location. Compliance

was 91.5% for avoiding skid trial location within 35 feet of Type F streams (630-800 (8)), with three

potential resource issues and six sediment delivery noncompliant practices. Compliance was 92.5% for

avoiding skid trails in stream channels (630-800 (9)), with channel disturbance but no sediment delivery

resulting from skid trails in Type N streams on eight units.

Drainage compliance was measured through two broad rule requirements. Compliance was 97.2% for

filtering of drainage before entering waters of the state (630-300 (2)). Poor filtering caused one potential

resource issue and two sediment deliveries. Compliance was 99.1% for effective skid trail surface drainage

(630-300 (3)), with one trail drainage segment with potential resource issue.

Table 30. Compliance Rates for Skid Trail Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-630- 100 3 Location - Minimum/Stable Sidecast 106 99.1 0 1

629-630- 100 4 Location - Stable Sites Used 106 99.1 1 0

629-630- 300 2 Drainage - Filtered Before WOS 106 97.2 1 2

629-630- 300 3 Drainage - Effective 106 99.1 1 0

629-630- 800 8 Location - 35' from Type F/D Streams 106 91.5 3 6

629-630- 800 9 Location - Outside of Stream High Water 106 92.5 0 8

 Compliance of All Sub-Section Rule Applications 636 96.4 6 17

As with roads, skid trails were surveyed by tallying categorical location and drainage condition data for

each 100-foot station. This was done for 69.0 total miles of skid trail on 106 units. These data are

summarized here to show the distribution of skid trail locations and drainage types and do not reflect

compliance rates, which were detailed above. Of the total length, 96.3% was categorized as “Other”

location (not associated with a potential water resource impact) and 3.7% was located in water resourcerelated areas with potential impacts (Table 31). Results were similar for skid trail drainage conditions, with

97.5% of total length having functional drainage and 2.5% with a potential resource concern related to

drainage condition (Table 32).

Table 31. Skid Trail Location Distribution

Percent of Total Road Length Located in Each Category

Highest Impact Lowest Impact

Number

Of Units

Total

Length

(Miles)

Type F

Channel

Type N/D

Channel

Unstable

Slopes

WetLandW/in 35’

Type F RMA

Slopes

>35% Other

106 69.0 0.0% 0.5% 0.1% 0.6% 0.2% 0.8% 1.6% 96.3%

Table 32. Skid Trail Drainage

% of Total Skid Trail Length in Each Category

Highest Impact Lowest Impact

Number

Of Units

Total

Length

(Miles) Rutting

Excessive

Spacing

Significant

Ponding Functional

106 69.0 1.4% 0.7% 0.4% 97.5%
BMP Compliance Report.doc/Jaz B 29

Temporary Stream Crossings. Compliance was 90.8% for all rule applications in this sub-section. There

were 152 total applications of five rules dealing with design, location, fill removal, and sediment barriers for

41 temporary crossings (Table 33). Compliance was 100% for the three rules which addressed temporary

crossing design and location. All 41 crossings surveyed were designed to minimize sediment delivery to

WOS (630-800 (4a)) located to minimize channel disturbance (630-800 (4b)), and all six crossings on Type

F streams were designed so as to not impair juvenile fish passage (630-800 (4d)).

Compliance was only 47.8%, however, for the proper removal of the 23 temporary crossings which used fill

material (630-800 (4e)). Only 11 of these crossings had fill material fully removed and placed in a stable

location following completion of the operation. Sediment delivery to the stream channel resulted from five

crossing structures not removed at all, three with fill material only partially removed from the channel, and four

with fill material removed but located so that it re-entered the stream channel. Potential resource issues were

identified for two crossings with removed fill located such that it was likely to re-enter the stream channel.

Compliance was 95.1% for the installation of effective sediment barriers at all 41 temporary crossings (630-

800 (6)). Effective sediment barriers were not installed at two crossings; one resulting in a potential

resource issue and one resulting in sediment delivery to the channel. This rule applied only to the proper

routing and filtering of the skid trail surface drainage at the approach to the crossing. It did not apply to

drainage or erosion issues related to the storage of removed fill material, which is discussed above for rule

630-800 (4e).

Table 33. Compliance Rates for Temporary Crossing Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-630- 800 4a Design - Minimum Sediment To WOS 41 100.0 0 0

629-630- 800 4d Design - Provide Fish Passage 6 100.0 0 0

629-630- 800 4b Location - Minimum Cut/Fill/Disturbance 41 100.0 0 0

629-630- 800 4e Fill Removal - Timing and Location 23 47.8 2 10

629-630- 800 6 Sediment Barriers - Effectively Installed 41 95.1 1 1

 Compliance of All Sub-Section Rule Applications 152 90.8 3 11

Vegetation Retention Along Streams (OAR 629-640)

Compliance was 96.4% for all applications of streamside vegetation retention rules. There were 833 total

applications of 24 rules in this sub-section. Of these, there were six noncompliant practices resulting in a

potential resource issue, and 24 that resulted in streamside vegetation damage. Vegetation retention

compliance and resource impacts are detailed below by stream type sub-sections.

The purpose of streamside vegetative requirements is to produce the desired future conditions for the wide

range of stand types, channel conditions, and disturbance regimes that exist throughout forestlands in

Oregon. The desired results vary depending on the site conditions but, in general, the goal is to grow and

retain stands that mimic mature forest conditions on fish-bearing streams. The goal along non-fish bearing

streams is to support the functions and processes that are important to downstream fish and domestic

uses, and to protect water quality.

Compliance was measured through detailed RMA transect and cruise surveys. These were conducted on 65

RMAs with neither fish nor domestic use (Type N), six RMAs with domestic water supply use (Type D), and

182 RMAs with fish use (Type F), broken out in Table 34. The small Type N RMAs listed here are those

which meet the georegion-specific criteria of this rule division (see Table 5 of the Oregon Forest Practice Rule

and Statutes). These numbers do not represent all Type F RMAs found on the units surveyed. A total of 210

Type F RMAs were observed on all units, but due to time constraints, detailed RMA transect and cruise

surveys could only be conducted on 182 of these. RMAs were randomly ordered within a unit so that there
BMP Compliance Report.doc/Jaz B 30

was no bias to which RMAs were surveyed within time constraints (see ODF Best Management Practices

Compliance Monitoring Project Protocol for sampling design and detailed survey methods).

Table 34. Number of Streams, Total Length, and RMA Width by Stream Size and Type Class

RMA Class

Number of RMAs

Surveyed

Total Length of RMA

Surveyed (Feet)

RMA Width

(Feet)

 Small Type N 65 Unknown 10

 Small Type D 6 2.350 20

 Small Type F 76 72,895 50

 Medium Type F 62 82,465 70

 Large Type F 45 53,720 100

Vegetation Retention for Type F RMAs. Compliance was 96.1% for all rule applications in this sub-section.

There were 750 total applications of 16 Type F RMA vegetation retention rules (Table 35). The surveys

conducted on these RMAs also provide a detailed quantitative measure of the level of resource impacts as

well as of compliance. Both vegetation retention compliance and resource impacts for specific rules are

detailed below for three areas: the 10-foot “no-touch” zone, the 20-foot “no-cut” zone, and tree retention for

the entire RMA.

Table 35. Compliance Rates for Vegetation Retention Rules for Type F RMAs

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-640- 100 2a General - Vegetation within 10' of hwl Retained 182 96.7 0 6

629-640- 100 2b General - Trees within 20' of hwl Retained 174 97.1 0 5

629-640- 100 3 General - RMA Down Wood Retained 182 98.9 0 2

629-640- 100 5 Gen. Rx - Reqd. Live Trees/1000' Retained 21 95.2 0 1

629-640- 100 6a Gen. Rx - Standard Target BA Retained 62 93.5 0 4

629-640- 100 6b No-Harvest Rx - RMA Conifers Retained 93 96.8 0 3

629-640- 100 12 Island Rx - Tree Retention 0 - - -

629-640- 110 11 Active Man. Rx - Required Trees/1000' Retained 0 - - -

629-640- 300 2 Conv. Rx Application - RMA < 1/2 Standard Target 6 66.7 2 0

629-640- 300 4c.1 Conv. Rx Layout - Conversion Blocks < 1/2 RMA 6 66.7 2 0

629-640- 300 4c.2 Conv. Rx Layout - Conversion Blocks < 500' Long 8 75.0 2 0

629-640- 300 4c.3 Conv. Rx Layout - Conversion Blocks 200' Apart 2 100.0 0 0

629-640- 300 4dA Conv. Rx Conv. Blocks - Veg. w/in 10' of hwl Ret. 8 100.0 0 0

629-640- 300 4eA Conv. Rx Ret. Blocks -Conifers w/in 50' for Large F 5 80.0 0 1

629-640- 300 4eB Conv. Rx Ret. Blocks - Conifers w/in 30' for Med. F 1 0.0 0 1

629-640- 300 4eC Conv. Rx Ret. Blocks -Conifers w/in 20' for Small F 0 - - -

 Compliance of All Sub-Section Rule Applications 750 96.1 6 23

• 10-Foot “No-Touch” Zone: The first level of Type F RMA vegetation retention requirements is that all

vegetation within 10 feet of the high water line be retained (640-100 (2a)). This 10-foot “no-touch”

buffer was fully retained on 176 of the 182 Type F RMAs surveyed (96.7% compliance). Although six

RMAs had a noncompliant practice of harvesting-related vegetation disturbance within 10 feet of the

high water line, most of the area of these “no-touch” buffers was undisturbed. Overall, 99.6% of the

total 10-foot “no-touch” buffer area surveyed (Total Type F RMA length X 10 feet) was undisturbed.

• 20-Foot “No-Cut” Zone: The second level of Type F RMA vegetation retention requirements is for the

retention of all trees within 20 feet of the high water line (640-100 (2b)). This 20-foot “no-cut” buffer
BMP Compliance Report.doc/Jaz B 31

was fully retained on 169 of the 174 applicable Type F RMAs surveyed (97.1% compliance). This

requirement did not apply to the eight conversion blocks discussed below. Although there were five

noncompliant practices for harvesting within 20 feet of the high water line, the majority of the area of

these “no-cut” buffers was uncut. Overall, 99.9% of the total 20-foot “no-cut” buffer area surveyed

(Total applicable Type F RMA length X 20 feet) had no trees cut.

• The third level of Type F RMA vegetation retention requirements is for tree retention in the entire RMA

and depend on the harvesting prescription applied. There is a variety of RMA prescription options

available within the Forest Practice Rules depending on stand conditions and harvest type. The

majority of RMAs surveyed were treated with a no-harvest buffer or a basal area prescription; some

were treated with a conifer restoration alternative prescription or a site-specific prescription (Table 36).

Compliance and tree retention levels for these four prescriptions are detailed below. The retention of

down wood in the RMA is required for all prescriptions (640-100 (3)) and was compliant on 180 of the

182 RMAs surveyed (98.9%).

Table 36. Harvest Prescriptions for Type F RMAs Surveyed

(RCR = Riparian Conifer Restoration.)

RMA

Prescription

Number of RMAs

Surveyed

Total Length of RMA

Surveyed (Feet)

Percent of Total

Type F Length

 No-Harvest 93 124,495 60%

 Basal Area 62 69,630 33%

 Site-Specific 7 7,475 4%

 RCR Conversion 8 3,150 2%

 RCR Retention 6 4,330 2%

For ownership class (industrial, non-industrial and other), the most common RMA prescription was a noharvest buffer (51%, 45%, and 61%, respectively), followed by standard basal area target (39%, 41%, and

22%, respectively). Site-specific plans (4%, 5%, and 6%, respectively), riparian conifer restoration (RCR)

conversion blocks (4%, 5%, and 11%, respectively), and RCR retention blocks (3%, 5%, and 6%,

respectively) were used less often (Figure 6).

Figure 6. Riparian Prescription and Ownership Class

RCR = Riparian Conifer Restoration.

0

1 0

2 0

3 0

4 0

5 0

6 0

7 0

8 0

No-Harvest

Buffer

Standard BA

Target

Site Specific RCR

Conversion

RCR Retention

RMA Prescription

Total Number

Industrial

Non-industrial

Other
BMP Compliance Report.doc/Jaz B 32

• No-Harvest Buffer: When RMA stocking levels are between 50 and 100% of the standard target,

operators are required to leave all conifers in the RMA unharvested (640-100 (6b)). Compliance for this

prescription was 96.3% for 93 surveyed RMAs to which it was applied. Noncompliance resulted from

RMA conifers harvested on three of these RMAs, all large Type F RMAs with a 100-foot uncut conifer

buffer required. These three RMAs had minimum uncut conifer buffer widths of 50, 45, and 85 feet,

and averaged 67, 82, and 99 feet, respectively.

The uncut conifer buffers for the 52 clear-cut RMAs harvested with this prescription were an average of

117% of the required width (RMA width). The average uncut buffer widths for these RMAs are shown

in Figure 7. Within a substantial portion of these RMAs, stocking levels were actually high enough to

have allowed for the harvesting of some conifers under the basal area prescription. This no-RMAharvest approach and leaving of unit wildlife trees within and along an RMA were common practices by

landowners seeking to provide stream protection beyond the minimum rule requirements or to simplify

harvesting adjacent to these streams.

• Basal Area Prescription: When RMA stocking levels exceed the standard target (shown in Tables 2

and 3 of Oregon Forest Practice Rules and Statutes (ODF, 2000A)), operators may be able to harvest

trees within the RMA. Application of this prescription and harvesting depend on RMA conifers,

hardwoods, and snag distribution; stream size; georegion; and harvest type (detailed in OAR 629-640-

100). Sixty-eight of the Type F RMAs surveyed were harvested using this prescription, 62 of which

were cruised for qualifying basal area retention under project time constraints. The basal area

retention rates relative to the required standard target for all 62 of these RMAs are shown in Figure 8.

The standard target was retained for 58 of these (93.5% compliance with rule 640-100 (6a)). The basal

areas retained for the four noncompliant RMAs were 45%, 93%, 94%, and 95% of the standard target.

The basal area measured in one of these four RMAs was within the range of measurement error

reported in the Quality Assurance and Quality Control section on page 12 of this report.

Twenty-two of these RMAs were on large and medium Type F streams, which have minimum tree

count requirements in addition to basal area requirements (640-100 (5)). The minimum tree count was

retained on 20 of these 21 RMAs, for a compliance rate of 95.2%. The retained tree count for the

noncompliant RMA was 78% of required. The tree-count retention rates for these 22 RMAs are shown

in Figure 9.

Qualifying basal area retained in these 62 RMAs averaged 202% of the standard target. Tree counts

for the 21 large and medium applicable RMAs averaged 258% of the requirements. For some RMAs,

the basal area and tree count minimums were exceeded due to the compound requirements of these

two rules and the 20-foot “no-cut” zone. In many of these RMAs, conditions were such that additional

trees could have been harvested. Discussions with landowners revealed that requirements were

exceeded because of a landowner’s desire to provide additional stream protection and the election to

retain unit wildlife trees within the RMA.
BMP Compliance Report.doc/Jaz B 33

Figure 7. Buffer Retention for No-Harvest Prescription RMAs

Bars represent average distance of nearest cut tree to high water line for Type F RMAs with no-harvest prescriptions on clear cut units. White bars are small RMAs, grey bars are

medium RMAs, and black bars are large RMAs. Dotted line represents the required uncut width (RMA width). Average width show for noncompliant RMAs.

9 9

8 2

6 7

0

50

100

150

200

250

13579

111315171921232527293133353739414345474951

RMAs

Uncut Buffer (Ft)
BMP Compliance Report.doc/Jaz B 34

Figure 8. Relative Retention for Basal Area Prescription RMAs

Bars represent retained basal area for Type F RMAs as a percent of standard target. White bars are small RMAs, grey bars are medium RMAs, and black bars are large RMAs.

Relative basal area retention is shown for noncompliant RMAs.

94 9 5

45

93

0 100 200 300 400 500 600

147

101316192225283134374043464952555861

RMAs

BA Retained as % of Target
BMP Compliance Report.doc/Jaz B 35

Figure 9. Tree Count Retention for Basal Area Prescription RMAs

Bars represent qualifying trees retained within each RMA as a percent of required. Rule applies only to medium (grey bars) and large (black bars) Type F RMAs. Relative tree

count retention shown for noncompliant RMA.

78

0

50

100

150

200

250

300

350

400

450

500

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

RMAs

Trees Retained as % of Required
BMP Compliance Report.doc/Jaz B 36

• Conifer Restoration Alternate Prescription: This prescription consists of the application of conversion

and retention blocks and is aimed at shifting alder-dominated near-stream areas into conifer stands

with greater long-term stream benefits (detailed in OAR 629-640-300). This prescription was applied

along one medium and five large Type F streams surveyed, with eight conversion blocks and six

retention blocks in total. Operators may chose to apply this riparian conifer restoration (RCR)

prescription when the stocking level along the entire stream length bordering the harvest unit is less

than 50% of the standard target (640-300 (2)). There was enough retained basal area (> 50% of the

standard target) in two of these six stream segments (66.7% compliance) to indicate that this

prescription should not have been used. Conversion blocks must also be limited to less than half the

total length of stream along the harvest unit (640-300 (4c.1)). This was compliant on four of the six

(66.7%) applications of this prescription. The first noncompliance was for 420 feet of conversion block

out of 780 feet of total stream length, and the second had 600 feet of conversion block out of 1150 feet

of total stream length.

Conversion blocks are alder-dominated RMA segments which can be harvested down to 10 feet from

the high water line so that they may be replanted with conifer. Retention of all trees within this 10-foot

zone (640-300 (4dA)) was complied with on all eight (100% compliance) of the conversion blocks

surveyed. The requirement that conversion blocks be less than 500 feet long (640-300 (4c.2)) was

complied with for six of eight blocks (75%). The two noncompliant conversion blocks were 530 and

600 feet long. The conversion blocks on the two surveyed stream segments with multiple conversion

blocks were separated by the required 200 feet (640-300 (4c.3)) in both cases.

Retention blocks are portions of these prescriptions with wider required buffers and are laid out

adjacent to or between conversion blocks. These are designed to be the riparian segments with higher

existing conifer stocking. Retention blocks have a required conifer no-cut width of 50, 30, and 20 feet

from the high water line for large, medium, and small Type F streams, respectively. These widths were

fully retained for four of the five retention blocks (80% compliance) on large streams (640-300 (4eA))

and not fully retained on the one retention block (0% compliance) on a medium stream (640-300

(4eB)).

The ODF has conducted a variety of monitoring projects in recent years that have evaluated the

application and effectiveness of the RCR prescription. Data now exists on compliance, stream

temperature, riparian stand structure, and stream shade. A separate report is being developed to

examine the interaction of these factors relative to resource protection for this prescription.

• Site-Specific Prescriptions: Operators may create a harvesting prescription which deviates from those

outlined in the rules when it is better suited to the specifics of the RMA, will provide equal or greater

immediate and long-term environmental benefits, and with approval of the ODF. Site-specific

prescriptions were used for seven RMAs surveyed so that trees within an RMA that were hazards to

roads, powerlines, or irrigation pipes could be removed. Because of the nature of these RMAs,

compliance was evaluated only for the 10-foot “no-touch” and 20-foot “no-cut” buffers described at the

beginning of this sub-section, and for the prior approval requirement reported in the “Administrative

Requirements” section.

Vegetation Retention for Type N and D Streams. Compliance was 98.8% for all rule applications in this

sub-section. There were 83 total applications of eight rules applying to six small Type D RMAs and 65
BMP Compliance Report.doc/Jaz B 37

small Type N RMAs. (Table 37). These small Type N RMAs are those that meet the georegion-specific

criteria of this rule division (see Table 5 of the Oregon Forest Practice Rule and Statutes).

Compliance with the vegetation protection requirement for qualifying small Type N streams was 98.5%.

Operations along these 65 streams were required to retain all understory vegetation and non-merchantable

conifer trees within 10 feet of the high water line (640-200 (6)). There was one noncompliant practice for

this rule, where harvesting along a small Type N stream resulted in understory vegetation removal.

Compliance was 100% for the vegetation protection requirements surveyed in six Type D RMAs. The

requirements for both Type D and N RMAs are similar to those for Type F streams. These rules required

the retention of all vegetation within 10 feet of the high water line (640-200 (2a)), retention of all trees within

20 feet of the high water line (640-200 (2b)), and the retention of all conifers within the RMA when preharvest stocking is below the standard target (640-200 (7b)).

Table 37. Compliance Rates for Vegetation Retention Rules for Type N and D RMAs

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-640- 200 2a Type D - Veg. within 10' of hwl Retained 6 100.0 0 0

629-640- 200 2b Type D - Trees within 20' of hwl Retained 6 100.0 0 0

629-640- 200 5 Type D - Reqd. Live Trees/1000' Retained 0 - - -

629-640- 200 6 Small Type N - Veg. w/in 10' of hwl Retained 65 98.5 0 1

629-640- 200 7a Type D/N - Standard Target BA Prescription 0 - - -

629-640- 200 7b Type D - No-Harvest Buffer 6 100.0 0 0

629-640- 200 7cB Type D/N - Default Prescription 0 - - -

629-640- 200 13 Type D/N - Island Tree Retention 0 - - -

 Compliance of All Sub-Section Rule Applications 83 98.8 0 1

Protection Measures for Significant Wetlands (OAR 629-645)

Compliance with all rule applications in this division was 88.1%. There were 42 total applications of six

rules outlining protection requirements for significant wetlands (those greater than 8 acres) and their RMAs

within or adjacent to harvest units (Table 38). These rules are designed to minimize impacts to the

vegetation and soils which could impair water quality, hydrologic function, and soil productivity. Seven

significant wetlands and 15,350 total feet of RMA were surveyed.

The retention of 50% of RMA trees by size class and species (645-010 (1)) was compliant for six of the

seven (85.7%) significant wetlands surveyed. No harvesting took place within five of these RMAs and

limited harvesting on the sixth met this requirement. The noncompliant RMA had 50% of trees retained for

only 1 of the 23 tree species and size classes present. Compliance was 100% for minimizing soil

disturbance (645-030 (1)) and avoiding draining wetlands (645-030 (3)). Retention of significant wetland

border trees (645-010 (2)) was complied with five times (71.4%). Minimization of understory vegetation

disturbance (645-040 (2)) and retention of all snags and down wood (645-050 (1)) was compliant on six of

the seven (85.7%) significant wetlands surveyed. All noncompliant practices were considered to have a

resource impact due to vegetation damage or removal.
BMP Compliance Report.doc/Jaz B 38

Table 38. Compliance Rates for Significant Wetland Protection Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-645- 010 1 Tree Retention - Tree Count Retained 7 85.7 0 1

629-645- 010 2 Tree Retention - Border Trees Retained 7 71.4 2 0

629-645- 030 1 General - Soil and Water Quality Protected 7 100.0 0 0

629-645- 030 3 Draining Avoided 7 100.0 0 0

629-645- 040 2 General - Understory Vegetation Retained 7 85.7 0 1

629-645- 050 1 General - Snags/Down Wood Retained 7 85.7 1 0

 Compliance of All Sub-Section Rule Applications 42 88.1 3 2

Riparian Management Areas and Protection Measures for Lakes (OAR 629-650)

There were no lakes associated with any of the 189 units surveyed for BMP compliance. The rules

described in this division are designed to protect the values and functions of lakes and include live tree

retention (650-010), soil and hydrologic function (650-020), and understory vegetation retention (650-030).

Protection Measures for Other Wetlands (OAR 629-655)

Compliance was 69.8% for the one rule surveyed in this division (Table 39). As with streams and

significant wetlands, “other” wetlands are afforded a level of protection by Oregon’s Forest Practice Rules.

Rules 655-000 (2a & 3) state that when harvesting along wetlands less than 8 acres in size, “operators

shall protect soil and understory vegetation from disturbance that results in reduced water quality,

hydrologic function, or soil productivity.” These criteria were evaluated for 96 wetlands smaller than 8

acres. Activities around 19 of these wetlands were considered to have a potential resource impact, while

activities around 10 others were deemed to have had an observable impact to the resource. Of these

wetland impacts, two were adverse accumulations of slash, two were significant vegetation removal, and

six were sedimentation from harvesting machinery alterations of wetland banks and soil.

Table 39. Compliance Rates for Other Wetland Protection Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-655- 000 2a,3 Soil and Water Quality Protected 96 69.8 19 10

Miscellaneous Water Protection Rules (OAR 629-660)

Compliance was 100% for the one rule surveyed in Division 629-660 (Table 40). This rule applied to the

186 surveyed units that had streams associated with them. The requirement of this rule (660-040 (2)) is

that operators do not add or remove any soil or rock to/from streams, except as allowed for approved

construction and improvement projects.

Table 40. Compliance Rates for Miscellaneous Water Protection Rules

# Rule Percent NC: Pot. NC:

Rule Number Rule Description Applications Compliant Impact Impact

629-660- 040 2 Soil/Rock Stream Input or Removal Avoided 186 100.0 0 0

Administrative Requirements (From All Divisions)

Compliance was 83.0% for all rule applications related to ensuring proper rule application, documentation,

and public record and review opportunities. There were 1,088 total applications of 28 rules in this section.

These administrative requirements are located throughout nearly all rule divisions, but have been compiled
BMP Compliance Report.doc/Jaz B 39

here so that administrative compliance can be reviewed collectively and separate from direct resource

protection rules. Compliance with individual rules is discussed below in Notification, Prior Approval, and

Written Plan sub-sections.

While these rules are associated with forest activities and features which may potentially impact water

quality (road construction, RMA harvesting, etc), they deal only with the notification, prior approval, and

written plan requirements of these activities. Noncompliance with any rule in this section is therefore

considered a “procedural” or “administrative” infraction and does not speak to compliance or resource

protection rates for those forest activities on the ground. Meeting requirements for prior approval or written

plan documentation did not appear to be a significant indicator of whether or not practices were compliant

in the field. Compliance and resource protection rates for forest activities (detailed in previous sections)

were generally quite high, even when compliance with the administrative rule requirements for those

activities was low.

Notification. Compliance was evaluated for two rules requiring notification for chemical applications within

100 feet of Type D streams. This activity occurred on two units and both rules applied to each (Table 41).

The ODF notified downstream water-rights holders (ORS 527.670 (6)) for one of these two applications and

the operator notified the community water manager (620-800 (3)) for both applications.

Table 41. Compliance Rates for Notification Rules

# Rule Percent NC:

Rule Number Rule Description Applications Compliant Admin.

ORS 527.670 (6) Type D - Downstream Holders Notified 2 50.0 1

629-620- 800 3 Type D - Community Water Manager Notified 2 100.0 0

 Compliance of All Sub-Section Rule Applications 4 75.0 1

Prior Approval. Compliance was 90.2% for all rule applications in this sub-section. There were 491 total

applications of 14 rules requiring written prior approval of the ODF for several harvest operation activities,

described below (Table 42).

Three of these rules related to approval of planned operations. Compliance was 98.4% for notification at

least 15 days before commencement of the operation (605-150 (1)), with three noncompliant practices on

189 units surveyed. Compliance was 95.9% for notification of activities within 100 feet of 216 Type F or D

streams (605-170 (1a)), with nine noncompliant practices. Compliance was 62.5% for the notification of

activities within 300 feet of significant wetlands (605-170 (1c)), with failure to notify on three of the eight

applicable activities.

One prior approval rule related to reforestation and was 100% compliant. This rule required prior approval

for exemptions from reforestation requirements because of land use changes (610-090 (1)) and applied to

three units.
BMP Compliance Report.doc/Jaz B 40

Table 42. Compliance Rates for Prior Approval Rules

# Rule Percent NC:

Rule Number Rule Description Applications Compliant Admin.

629-605- 150 1 Planning - 15-Day Waiting Period 189 98.4 3

629-605- 170 1a Planning - Activity w/in 100' Stream/Lake 216 95.9 9

629-605- 170 1c Planning - Activity w/in 300' Significant Wetland 8 62.5 3

629-610- 090 1 Reforestation - Land Use Change Exemption 3 100.0 0

629-625- 100 2b Road Construction - Machinery in Type F or D 12 75.0 3

629-625- 100 2c Road Construction - RMA Road Construction 1 0.0 1

629-625- 100 3 Road Construction - High Risk Road Location 1 0.0 1

629-625- 100 4 Road Construction - Stream Crossing Fill >15' 3 66.7 1

629-625- 100 5 Road Construction - Stream Enhancement 4 100.0 0

629-630- 200 3 Harvesting - RMA Landings 8 37.5 5

629-630- 500 1 Harvesting - High Risk Site Harvest 29 48.3 15

629-630- 700 3.2 Harvesting - Type F Yarding Corridors 10 60.0 4

629-640- 110 3 Stream Veg. Retention - Active Management Rx 0 - -

629-640- 400 3 Stream Veg. Retention - Site Specific Plans 7 57.1 3

 Compliance of All Sub-Section Rule Applications 491 90.2 48

Five of the prior approval rules evaluated related to road construction activities. Prior approval for machine

activity associated with road construction within Type F or D streams (625-100 (2b)) was obtained for 9 of

12 occurrences (75% compliance). The construction of new roads within an RMA (625-100 (2c)) and on

high risk slopes (625-100 (3)) each occurred once, both without prior approval being obtained (0%). Four

new stream crossings with fill greater than 15 feet deep (625-100 (4)) were also constructed, with required

prior approval obtained for two of these three fills (66.7%). Prior approval was obtained for all four stream

enhancement activities undertaken (625-100 (5)).

Prior approval was evaluated for three rules relating to harvesting practices. Prior approval was obtained

for three of eight landings (37.5%) located within RMAs (630-200 (3)) and 14 of 29 operations (48.3%) on

high risk sites (630-500 (1)). Six of 10 (60.0%) yarding corridors across Type F streams (630-700 (3.2))

had prior approval.

Prior approval was also obtained for four of the seven RMAs harvested with site-specific plans (640-400

(3)), for a compliance rate of 57.1%.

Written Plans. Compliance was 77.1% for all BMPs in this sub-section. There were 593 total applications

of 12 written plan rules. These rules require operators to provide detailed information to the ODF in an

approved written plan for a variety of harvesting activities which could potentially impact waters of the state,

described below (Table 43). These rules address many of the same activities requiring prior approval, but

differ in that they require specific details about vegetation and stream protection, feature design,

construction methods, or sediment prevention rather than simple approval.

The first rule in this sub-section requires that operators comply with all provisions of a written plan once it

has been approved (605-170 (5)), as these effectively become amended Forest Practice Rules governing

the operation. Compliance with this rule was 79.3%, with all provisions being complied with for 88 of 111

operations with written plans.

For the planning of forest operations, written plans that describe three aspects of stream resource protection

near harvesting activities must be submitted. The first is inclusion of detailed information on felling and
BMP Compliance Report.doc/Jaz B 41

bucking activities in protected stream areas (605-170 (6)), and was 83.1% compliant. This rule applied to 219

Type F and D RMAs as well as felling across three Type N streams where the activity was deemed compliant

but should have been documented in a written plan. The second is the inclusion of detailed information of the

RMA prescriptions being applied (635-130 (1)), and was 77.3% compliant for 216 Type F and D RMAs. The

third written plan requirement is the documentation of sediment prevention details for activities near Type D

RMAs (635-130 (2)), and was done for four of the six Type D RMAs surveyed (66.7% compliance).

Table 43. Compliance Rates for Written Plan Rules

# Rule Percent NC:

Rule Number Rule Description Applications Compliant Admin.

629-605- 170 5 Planning - Compliance with Approved WP 111 79.3 23

629-605- 170 6 Planning - Required Stream Protection Details 219 83.1 37

629-615- 300 3 Treatment of Slash - RMA Burning Details 0 - -

629-625- 320 1bB Road Const. - Stream Crossing Fill >15' Details 3 66.7 1

629-630- 500 2 Harvesting - High Risk Site Protection Details 29 41.4 17

629-630- 800 4c Harvesting - Temporary Crossing Fill >8' Details 2 0.0 2

629-635- 130 1 Activities Near Listed WOS - RMA Prescription 216 77.3 49

629-635- 130 2 Type D Streams - Sediment Prevention Details 6 66.7 2

629-645- 030 2a Significant Wetlands - Filling Details 0 - -

629-645- 030 2b Significant Wetlands - Machine Activity Details 0 - -

629-645- 030 2c Significant Wetlands - Road Construction Details 0 - -

629-645- 040 3 Significant Wetlands - < 300' Site Prep. Details 7 28.6 5

 Compliance of All Sub-Section Rule Applications 593 77.1 136

Road construction written plan details were required for the design and drainage of stream crossing fills

greater than 15 feet deep (625-320 (1bB)). Three newly-constructed crossings were surveyed with fills 18,

20, and 22 feet deep, only two of which were addressed in a written plan (66.7% compliance).

Compliance was low for two written plan requirements related to harvesting practices. Written plan details

on soil protection methods for harvesting on high risk slopes (630-500 (2)) were provided for only 12 out of

29 units with high risk site harvesting (41.4% compliance). The details of fill construction, design, and

removal timing for temporary crossings with fill greater than 8 feet deep (630-800 (4c)) was not included in

a written plan for either of the two crossings for which it was required (0% compliance).

The final written plan requirement reviewed was for details on soil protection methods for site preparation

within 300 feet of significant wetlands (645-040 (3)). Compliance with this rule was only 28.6%, with written

plan details provided for only three of seven significant wetlands.

FINDINGS

Monitoring Question 1: Compliance Rates. How often did operators comply with BMPs described in

the forest practice rules pertaining to water protection, road construction and maintenance, harvesting, and

high risk sites?

Unit-Level Compliance

Compliance rates for individual units ranged from 78.8% to 100% (Figure 10) and averaged 96.1%. The

majority of units (76%) had at least one noncompliant practice of some sort, and 40% had at least one

noncompliant practice that resulted in an impact to riparian and channel conditions.
BMP Compliance Report.doc/Jaz B 42

Figure 10. Frequency Distribution of Unit-Level Compliance Rates

The results of this project appear to compare favorably with those reported in other states, although they

cannot be compared directly because state rule requirements differ and survey methodologies varied.

Oregon’s Forest Practice Rules are one of the most detailed and extensive sets of mandatory forestry

BMPs in the nation. While it was common to find compliance issues when units were evaluated strictly, it

would be an oversimplification to rate compliance solely on existence of a compliance issue of any kind on

a unit. An accurate representation of compliance must account for the high numbers of BMPs applied to

each unit (average of 71), the specific sources of noncompliance, and impacts to riparian and channel

conditions (units had an average of 98.7% of practices with no impact).

Rule-Level Compliance

Compliance was 96.3% for all of the 13,506 BMP applications reviewed across all 189 units. Of the 502

total noncompliant practices surveyed, 185 (1.4%) were with administrative rules only, 147 (1.1% of all

applications) were potential resource issues, and 170 (1.2%) had an impact to riparian or channel

resources. These applications were broken into 11 rule sections (Table 44), with section compliance

ranging from 69.8% for protection measures for other wetlands, to 100% for rules related to reforestation

and operations near waters of the state (WOS).

Table 44. Compliance Rates for Rule Sections

Rule Division Section Description Compliance Rate

629-610 Reforestation (RMA reforestation only) 100.0

629-615 Treatment of Slash 98.2

 629-620* Chemicals and Petroleum Products 94.3

629-625 Road Construction and Maintenance 97.6

629-630 Harvesting 98.1

629-640 Vegetation Retention Along Streams 96.4

629-645 Protection Measures for Significant Wetlands 88.1

629-655 Protection Measures for Other Wetlands 69.8

629-650 Protection Measures for Lakes N/A

629-660 Operations Near WOS 100.0

All Administrative Requirements 83.0

 *Includes rule 630-400 (3)

1

0

1

0 0 0

1

2

1

4

5

2

9

4

13

1 0

15

1 7

14

23

21

46

0

5

1 0

1 5

2 0

2 5

3 0

3 5

4 0

4 5

5 0

7981838587899193959799

Unit Compliance Rate (%)

Number of Units 

n = 189
BMP Compliance Report.doc/Jaz B 43

Monitoring Question 2: Stream Crossing Fish Passage and Peak Flow. Have stream crossing

structures on newly constructed and/or reconstructed roads been designed and installed according to ODF

guidelines regarding fish passage and the 50-year peak stream flow event?

These issues could not adequately be evaluated by the sampling design and survey constraints of this

project. A supplemental study was implemented concurrently with this to more accurately address peak

flow capacity and juvenile fish passage for newly constructed or reconstructed stream crossings. Results

of this project are detailed in ODF Technical Report 14, Compliance with Fish Passage and Peak Flow

Requirements at Stream Crossings (ODF, 2002A). This document can be found online at

http://www.odf.state.or.us/FP/fpmp/default.htm.

Monitoring Question 3: Compliance Rates and FPF Inspections. How do the statistical sample results

compare with results based on forest practice foresters (FPF) inspections? Is there a correlation between

number of FPF inspections and compliance rates? How statistically representative are the results of this

project?

Forest Practices Forester (FPF) Inspections

The Forest Activities Computerized Tracking System (FACTS) and a civil penalties database were queried

for inspection and citation rates for the period of 1995 through 2001. These data are based on the number

of citations issued relative to the number of operations that have been inspected by an FPF. Inspection

compliance rates during this period showed little fluctuation, with 96.3 to 98.2% of annual operations

inspected receiving a citation during this period (Figure 11). The power of these data is in the sheer

number of operations assessed. For example, around half of the roughly 18,000 operations completed

each year received at least one FPF inspection.

While these results provide a gage for the level of compliance during this period, they cannot be directly

compared to compliance rates identified by this study for several reasons. The sample of operations inspected

by an FPF consists of prioritized operations within significant time and resource limitations. Conversely, the

sample for this project was completely randomly selected and stratified by stream and ownership classes, with

an access denial rate of around 4%. FPF inspections also include all applicable forest practice rules, not just the

water-related rules that were the focus of this project. It is also important to note that this project had three

people collecting data to evaluate operations at a very strict and technical level of rule compliance. Many of the

practices considered noncompliant may not have necessarily warranted a citation.

Although direct correlation between FPF inspections and findings from this project could not be measured

with this data, the similar overall compliance rates support the effectiveness of FPF inspections relative to

the findings of this study.

Figure 11. 1987-2000 Compliance Rates

(Rates are based on operations inspected and citations issued for 1987 through 2000.)

95

96

97

98

99

87 88 89 90 91 92 93 94 95 96 97 98 99 00

Year

% Compliance
BMP Compliance Report.doc/Jaz B 44

Statistical Representation

The precision level of the unit-level compliance results can now be calculated with the equation originally

used to determine the needed sample size. Using sample size (n), population size (N), and unit-level

compliance rate (P), the equation (Freese, 1962) can be solved to give the precision level (E) of these

results:

 1 

 n = E2 + 1 or E = ((1/n-1/N)*4*P*(1-P))^1/2

 (4) (P) (1-P) N

With a sample size of 189 units surveyed, a population of 4,075 notifications, and an average unit-level

compliance rate of 96.1% for the units sampled, the precision level is 0.028. The average compliance rate

of the sampled units is therefore representative of the entire population with 97.2% confidence. This

confidence level is actually somewhat higher than 97.2% because the identified population greatly

overestimates the number of qualifying units. Qualified units were completed operations with a 1998

notification, harvested under the forest practice rules, and associated with some waters of the state. About

one-half of the identified notifications reviewed during site selection either did not meet these criteria or did

not actually occur.

As well as meeting these criteria, units were selected based on ownership class and stream type

stratifications. These results are likely not representative of units selected with different criteria or

stratifications. As well, confidence levels cannot be calculated for individual rules surveyed, as this siteselection process likely influenced the sampling rate and distribution of specific practices.

Monitoring Question 4: Areas of Highest and Lowest Compliance. Are there particular rules that

consistently have a higher or lower level of compliance? If the latter, can the guidance and/or rule

language be modified to improve compliance? Are there educational and training opportunities/materials

regarding those rules?

Compliance and Sample Size

It is important to first note the role of sample size when assessing the significance of compliance rates for

individual rules. It is difficult to assess the scope of a compliance issue in cases where a BMP was applied

so few times that one or two noncompliant practices resulted in a low compliance rate. Closer examination

shows that average compliance results were highly correlated to sample size, with average compliance

much higher for those BMPs applied more often (Table 45). Rules with 1 to 10 total applications (37 rules)

had an average rule compliance of 72%, while rules with 11 to 100 total applications (49 rules) had an

average rule compliance of 94%, and rules with more than 100 total applications (43 rules) had an average

rule compliance of 96%.

Table 45. Average Compliance Rates for Rules Based on Number of Times Applied

Number of Times

Rule Applied Number of Rules Total Number ofRule Applications

Average Rule

Compliance

1-10 37 194 72%

11-100 49 2,685 94%

>100 43 10,627 96%

This trend is encouraging for two reasons: the low compliance results for some rules with small sample

sizes is possibly not representative of the larger population, and proper understanding, interpretation, and
BMP Compliance Report.doc/Jaz B 45

administration of forest practice rules appears to improve the more they are conducted, as those practices

most frequently applied to the landscape were generally most likely to meet BMP compliance.

Areas of Higher Compliance

Given the sample size considerations discussed above, these results still allow for the identification of

areas of higher and lower compliance. There were 50 individual rules (39%) with 100% compliance and 72

rules (56%) with 98% or higher compliance. Because of these high numbers, high compliance is identified

below for rule groups which have 98% or higher compliance.

• RMA Reforestation Timing (610-040): 100% compliance for two rules (36 applications)

• Chemical Applications (620-400): 98.4% compliance for three rules (129 applications)

• New Road Location (625-200): 100% compliance for three rules (240 applications)

• New Road Prism Design (625-310): 99.4% compliance for seven rules (320 applications)

• Rock Pits (625-500): 100% compliance for five rules (85 applications)

• General Yarding Practices (630-100): 99.5% compliance for three rules (407 applications)

• Cable Yarding near WOS (630-700): 99.7% compliance for five rules (376 applications)

• Landings (630-200): 99.8% compliance for four rules (3,472 applications)

• Vegetation Retention for Type N and D Streams (640-200): 98.8% compliance for eight rules

(83 applications)

The general vegetation retention rules for Type F streams (640-100) are not listed above, but are worth

mentioning here. Compliance was 97.1% for these six rules, however, the average rates of retention of

RMA vegetation were quite high. All 41 no-harvest prescription Type F RMAs in partial cut units had at

least 100% of the required buffer retained. The 52 Type F RMAs with this prescription in clear-cut units

had an average of 117% of the required buffer retained. The 62 RMAs with a basal area prescription had

an average of 202% of the standard target retained (although only a portion of the basal area above the

standard target was likely harvestable; see page 32). These prescriptions made up 93% of the total length

of Type F RMA surveyed.

Areas of Lower Compliance

There were also 10 specific BMPs identified as having the most significant compliance issues (less than

96% compliance and five or more noncompliant practices). These were: slash piling near WOS, removal of

petroleum-related waste, stream crossing fill stability, road surface drainage, felling of trees into small Type

N streams, skid trails near WOS, removal of temporary crossings, protection of other wetlands, prior

approval requirements, and written plan requirements. These are detailed individually below in order of rule

number. Opportunities to improve compliance (training, guidance language, enforcement, etc) are detailed

in the Recommendations section, which follows.

• Mechanical Slash Piling near WOS (615-200 (4)). The placement of mechanically-piled slash in WOS

or where it can enter WOS was an issue on 8 of the 77 applicable units (89.6% compliance). Five of

these noncompliant practices were slash piled within or on the banks of small Type N streams and

three were slash piled in “other” wetlands less than 8 acres in size. Discussions with operators over

the course of implementing this project revealed that non-compliance resulted from two factors:

operators did not realize that these protection requirements extended to small Type N streams and

“other” wetlands, or operators had difficulty identifying small, ephemeral features during the dry season.

Discussions of these results with ODF field staff, landowners, and operators have already begun to

raise awareness of this issue.
BMP Compliance Report.doc/Jaz B 46

• Stream Crossing Fill Stability (625-320 (1bC)). The design of new stream crossings so that fill and

erosion to a channel are prevented was not achieved for 8 of the 51 new crossings surveyed (84.3%

compliance). Fill erosion on those eight crossings was attributed to two design issues: over-steepened

fills, which enter the channel through ravel or shallow failures, and drainage-caused rutting over

ineffectively stabilized fill material.

• Road Surface Drainage (625-330 (1) and 625-600 (2)). Road surface drainage designs that effectively

disperse runoff and minimize erosion and proper maintenance of that road surface drainage are critical

for resource protection. Compliance with these rules was 86.5% (drainage design) and 94.2%

(maintenance), with 31 total noncompliant practices on 171 units with roads. These two rules were

considered together because distinguishing compliance issues between ineffective drainage designs

and maintenance levels was often extremely difficult. Non-compliance was generally due to a

combination of ineffectively designed drainage systems that broke down quickly and did not receive the

subsequent required maintenance. These conditions resulted in routing of excessive runoff across the

road surface for great distances, causing erosion and instability. There were 11 cases of sediment

delivery attributed to poor drainage design and 10 attributed to a lack of maintenance.

• Removal of Petroleum-Related Waste (630-400 (3)). The removal of petroleum-related waste from the

unit following completion of the operation was noncompliant on 34 of the 189 units surveyed (82.0%

compliance). These materials (oil filters, grease tubes, and motor and bar oil containers) were

generally located at landings, and while none were found to have delivered to WOS, they represent a

possible risk to future soil and water quality. Noncompliance was considered to be the result of poor

post-operation clean-up practices.

• Felling of Conifers into Small Type N Streams (630-600 (2)). Compliance for felling conifers away from

streams and preventing damage to channels was 83.1% on 189 units. The 32 noncompliant practices

surveyed were nearly all from the felling of conifers across or into small Type N channels or, to a lesser

extent, felling into small wetlands. Fifteen of these resulted in significant slash in WOS, one to channel

bed and bank disturbance, and one to sediment delivery to a WOS. Low compliance rates for limiting

slash accumulations in Type N steams (630-600 (3b)) and leaving slash where it will not enter WOS

(600-400 (1)) were considered to generally result from these noncompliant felling practices. Discussion

with operators and ODF field staff while implementing this project revealed that noncompliance was

generally associated with interpretation of this rule’s application to small Type N streams and other

wetlands, especially those which were dry during the time of harvest. Discussion of these results with

ODF field staff, landowners, and operators has already begun to raise awareness of this issue.

• Removal of Temporary Crossings (630-800 (4e)). The removal of temporary crossing structures

following completion of an operation and placement of fill material where it will not enter WOS was

done properly for only 11 of 23 temporary crossings surveyed (47.8% compliance). Non-compliant

practices include five crossings with fill not removed, two with fill only partially removed, and five with fill

material removed but placed where it eroded back into the stream channel. Non-compliance was

considered to be simply the result of poor post-operation clean-up practices.

• Skid Trails Near WOS (630-800 (8) and 630-800 (9)). Harvesting rules also require that skid trails on

106 units not be located within 35 feet of Type F streams (91.5% compliance) and be located so that

stream water will not flow onto the skid trail (92.5% compliance). Noncompliant practices consisted of
BMP Compliance Report.doc/Jaz B 47

nine units with skid trails located within 35 feet of a Type F stream and eight units with skid trails

located within a length of a small Type N stream channel. These resulted in eight cases of channel

bed or bank disturbance and six cases of sediment delivery to WOS. Discussion with operators

indicated that noncompliance was generally the result of skid trail location rules not adhered to

because of operational concerns.

• Protection of Other Wetlands (655-000 (2a & 3)). This rule required protection of soil and water quality

for activities along 96 wetlands less than 8 acres (“other” wetlands), seeps, or springs. Compliance

was 69.8%, with 29 noncompliant practices in the form of harvesting machinery driven through

wetlands, wetlands used as landing areas, trees yarded through wetlands, and slash piled in wetlands.

Discussion with landowners, operators, and ODF field staff over the course of implementing this project

revealed that noncompliance was generally the result of interpretation of this rule’s application to these

small wetlands and their identification during the dry season. These discussions have already begun to

raise awareness of this issue.

• Prior Approval Requirements. Compliance was evaluated for 13 rules in several divisions requiring

department approval for a variety of specified activities (see Table 42). No written prior approval

documentation was found for 48 of the 492 activities for which it was required (90.4% compliance).

Noncompliance with these requirements was strictly an administrative issue and was not an indicator of

compliance for related resource-protection rules. Discussions with landowners, operators, and ODF

field staff revealed that the practices addressed by these rules were often considered or discussed with

ODF personnel during the operation, with the compliance shortcoming simply being one of written

documentation. Compliance also appears to be closely related to how familiar operators and

landowners are with the requirements in question. The two most commonly applied prior approval

rules averaged 203 applications each and 97.2% compliance. The remaining 11 rules averaged only

eight applications each and 55% compliance.

• Written Plan Requirements. Compliance was evaluated for eight rules in several divisions requiring that

detailed information be documented in a written plan for a variety of specified activities (see Table 43).

Documentation of adequate information in a written plan was lacking for 136 of 593 total activities for

which it was required (77.1%). Noncompliance with these requirements was strictly an administrative

issue and not an indicator of compliance for related resource protection rules. Discussions with

landowners, operators, and ODF field staff revealed that these requirements were often considered or

discussed with the FPF during or before the operation, with the compliance shortcoming being one of

written documentation. Noncompliance also occurred in many cases where a written plan was submitted

but did not contain a sufficient level of detail to describe activities in question. Compliance issues

generally appeared to be the result of a lack of clear understanding of what specific details are required to

be in a written plan (This was especially true for providing fish passage (ODF, 2002A)).

Monitoring Question 5: Resource Impacts of Noncompliance. When BMP compliance is inadequate,

to what extent are quality and function of riparian areas, stream channels and/or fish habitat compromised?

Of the 502 total noncompliant practices surveyed, 185 (37%) were with administrative requirements not

directly affecting riparian and channel conditions, 147 (29%) had the potential to impact riparian and channel

conditions in the future, and 170 (34%) had an observed impact to riparian and channel conditions. The 170

observed impacts resulted from noncompliant practices associated with a range of forest practice rules
BMP Compliance Report.doc/Jaz B 48

(Table 46). Each of these instances was categorized as one of four types: significant harvesting slash

accumulations below a high water line, significant damage or removal of riparian vegetation, physical

alterations of channel bed or banks without sediment delivery, or sediment delivered below a high water line.

Slash Accumulations

Fifty-three noncompliant harvesting slash accumulations were deemed significant enough to impair the water

quality of a stream or wetland. These accumulations resulted from trees not felled directionally away from

small Type N streams and small wetlands (40), slash on slopes above streams was not disposed of or placed

to prevent it from entering the channel after harvest (7), or mechanically-piled slash was placed below a high

water line (6). In all these cases, the loading of fine harvesting slash greatly exceeded natural levels.

Table 46. Riparian and Stream Channel Impacts of Noncompliant Practices

Slash = Significant accumulations below a high water line, Vegetation = significant damage or removal of riparian

vegetation, Alteration = physical alterations of channel bed or banks without sediment delivery; Sediment Delivery to

WOS numeric columns are categorical estimates of volume of sediment delivered in cubic yards.

Sediment Delivery to WOS (yd3)

 Rule Sub-Section Slash Vegetation Alteration 0-1 1-10 10-100 >100

Reforestation (RMAs only)

Treatment of Slash 6 1 1

Chemical and Other Petroleum Products

Chemical Applications 2

Petroleum Products

Road Construction and Maintenance

Road Location

Road Prism Design 1

Steam Crossing Design 2 8 2

Road Drainage Design 4 7

Road Waste and Stabilization 4

Road Drainage Maintenance 5 4 1

Road Vacating

Rock Pits

Harvesting

General Yarding Practices 1 1

Felling and Harvesting Slash 38 1

Cable Yarding Near WOS 1

Ground Equipment Near WOS 2 1

Harvesting Waste 7 2 3

Landings

Skid Trails 8 4 4 1

Temporary Crossings 5 5 2

Vegetation Retention Along Streams

Vegetation Retention - Type F RMAs 23

Veg. Retention - Type N and D RMAs 1

Significant Wetlands 2

Other Wetlands 2 2 2 3 1

Stream Channel Changes

 Total 53 30 11 28 34 12 2

The beneficial and detrimental effects of this material on water quality and channel dynamics is not yet fully

understood or quantified. It is believed, however, that large accumulations of fine organic material in

streams and wetlands can have the following potential impacts: elevated water temperatures due to

artificially widened channels and slowed flows, reduced dissolved oxygen as material decomposes,
BMP Compliance Report.doc/Jaz B 49

alteration of channel hydrology and increased erosion, reduced potential for vegetation establishment,

short-term retention of sediment, and elevated debris torrent hazard. Research on clear-cut first- and

second-order streams in western Washington (Jackson et al., 2001) found several significant short-term

effects of heavy slash loading. These include large increases in the amount of fine sediment retained in

these channels, shading of channels from direct solar radiation, and reduction of amphibian populations.

Riparian Vegetation Damage

Thirty of the noncompliant practices surveyed resulted in significant damage or removal of riparian

vegetation that was required to be retained by the forest practice rules. The retention of vegetation along

streams and wetlands is required to maintain water quality, fish and wildlife habitat, and bank stability. The

majority of these (23) were failures to fully meet the vegetation retention requirements when harvesting in

Type F RMAs. Other noncompliances were for aerial chemical applications to riparian vegetation (2) and

with vegetation retention requirements when harvesting along significant wetlands (2), other wetlands (2),

and a Type N RMA (1).

Alteration of Bed or Banks

Eleven noncompliant practices resulted in channel alterations with no observable sediment delivery to a

stream or wetland. This physical alteration of channel beds or banks can result in immediate and long-term

impacts to water quality through altered hydrology, soil compaction, and elevated erosion potential. Most

were associated with machinery operated within a channel, either from ground skidding of logs (8) or

excessive activity within a channel while constructing a stream crossing (2). The remaining alteration was

the result of trees felled into a small Type N streambed.

Sediment Delivery

Seventy-six observations of sediment delivered to a stream or wetland resulted from a wide range of

noncompliant practices (Figure 12). The impacts of sediment delivery vary greatly depending on the

volume of delivery, stream size, channel morphology, and other site conditions, but in some cases can

cause severe resource impacts. These situations can mean unstable slopes and the loss of forest soils, as

well as impaired water quality through increased stream temperatures and lowered dissolved oxygen,

hindered fish migration and feeding ability, mortality of aquatic invertebrates, and deposition of fine

materials which can alter channel hydrology and bury spawning gravels.

Because these surveys were conducted during the dry season, observations of past sediment delivery and

estimations of delivery volume were likely to be under-representative of actual erosion rates. The volume

of sediment delivered to WOS was estimated within broad categories. Of the total (76), 28 were estimated

to be less than 1 cubic yard, 34 were 1 to 10 cubic yards, 12 were 10 to 100 cubic yards, and two were

greater than 100 cubic yards (Figure 13). The first of these two largest cases was from poor yarding

practices on steep slopes that caused several large shallow failures. The second (on the same unit) was

from improper ground skidding within a wetland.

It is important to note that the estimated volume of delivered sediment is not necessarily a measurement of

the magnitude of impact that this delivery may have had on the stream channel. The degree to which a

volume of delivered sediment will impact a channel can vary greatly depending on the presence of fish and

other aquatic species, stream size, channel morphology, habitat conditions, delivery timing, and other

factors. The two cases of sediment delivery of greater than 100 cubic yards, for example, were to a small

Type N stream and a wetland of less than one acre. Neither of these streams had fish populations,

however, such large amounts of sediment delivery to these small features have drastic hydrology and

morphology impacts, such as long-term aggradation of the channel downstream.
BMP Compliance Report.doc/Jaz B 50

The greatest source areas of sediment delivery were from 36 noncompliant road construction and

maintenance practices. Specific sediment source areas were ineffective road drainage design (11),

inadequate road drainage maintenance (10), eroding stream crossing fill (10), unstabilized road waste (4),

and an unstable road prism design (1). The other main sources of sediment delivery were from 32

noncompliant harvesting practices. Specific source areas were poorly-removed temporary crossings (11),

ineffectively drained skid trails near streams (9), unstablized harvesting waste (5), harvesting equipment

operated in stream channels (3), yarding gouges on steep slopes (2), trees felled into a channel (1), and

trees yarded through a stream channel (1). The remaining delivery observations were from infractions of

small wetland protection requirements (6), and slash-piling machinery operated in WOS (2).

Figure 12. Distribution of Sediment Delivery Volumes from Noncompliant Practices

Figure 13. Distribution of Sediment Delivery Sources

0

2

4

6

8

10

12

Temp.

Crossings

Road Drainage

Design

Steam

Crossing

Design

Road Drainage

Maint.

Skid Trails Other

Wetlands

Harvesting

Waste

Road Waste

and Stab.

Ground Equip.

Near WOS

Treatment of

Slash

General Yard.

Practices

Road Prism

Design

Cable Yard.

Near WOS

Source of NC Sediment Delivery 

Number of Deliveries

0

5

10

15

20

25

30

35

40

0 - 1 1 - 10 10 - 100 > 100

Estimated Delivered Volume (Cubic Yards)

Number of Deliveries
BMP Compliance Report.doc/Jaz B 51

RECOMMENDATIONS

Raise Awareness and Understanding of Key Findings

The results of this project demonstrate very encouraging rates of overall compliance with Forest Practice

Rules related to water quality, as well as identify those areas of consistent compliance issues. Efforts to

raise awareness of those areas of low compliance and greatest resource impact with landowners,

operators, and ODF field staff are likely to greatly increase compliance and resource protection.

Identification and discussion of many of these issues over the course of implementing this project have

already begun to help clarify interpretations and applicability of some rules and lead to efforts by alert

landowners to correct specific problems in the field.

This information should continue to be disseminated to forest operators, landowners, ODF staff and the

public. Opportunities to raise awareness of findings in the near future include ODF Area Forest Practices

conferences in the spring of 2002, Association of Oregon Loggers training workshops, the Oregon Logging

Conference, Oregon Forest Industries Council meetings, and potential roads training seminars in the fall of

2002. Training should focus on the causes of compliance issues for the 10 areas of low compliance

identified in the Findings section of this paper, especially those directly related to stream and wetland

protection. Specific priorities for future training include (in no particular order):

• Although road construction and design practices have improved over time, there is still a need for

training that addresses effective drainage design, maintenance, and road surface and stream crossing

fill stability. These efforts should be based on the criteria described in the Forest Practices Rule and

Statute Guidance Manual (ODF, 1997) and the Forest Road Management Guidebook (ODF, 2000B).

Specific focus should be given to durable road surfacing, design and maintenance of frequent surface

and ditch relief points, disconnection of road drainage from the stream network, drainage filtering or

relief before stream crossing approaches, and effective stabilization of stream crossing fills. This

training need is also identified in Recommendations F and L of the Report of the Forest Practices

Advisory Committee (FPAC) (ODF, 2000C).

• Increased awareness and understanding of the protection requirements for small Type N streams is

needed. A number of rules require that these streams be provided the same level of protection as fishbearing streams relative to slash piling, felling, bucking, yarding, road drainage, and all machinery

activities. Accumulations of felling slash in small Type N streams should be below “quantities that

threaten water quality or increase the potential for mass debris movement." It is believed that improved

compliance with felling and slash piling requirements would likely result in effective protection against

such slash accumulations.

• Increased awareness and understanding of the protection requirements for “other” wetlands, seeps and

springs is needed. A number of rules require that these features, when larger than one-quarter acre,

be provided the same level of protection as fish-bearing streams relative to felling, bucking, yarding,

road drainage, and all machinery activities. For wetlands of any size, the piling of slash is prohibited

and accumulations of felling slash should be below “quantities that threaten water quality or increase

the potential for mass debris movement.” It is believed that compliance with felling and slash piling

requirements would likely result in effective protection against such slash accumulations.
BMP Compliance Report.doc/Jaz B 52

• The identification of small Type N streams and “other” wetlands appears to be a major cause for lack of

protection of the features. Proper identification is made even more difficult by the fact that these

features are often dry during the summer months when many forest activities occur. Training should

be provided which focuses on identification of obligate plant species, soil characteristics, and

geomorphic evidence of small channels and wetlands during dry periods.

• Increased awareness of the requirements for many activities that prior approval be obtained and/or

written plan be approved by the ODF is needed. Low compliance rates generally appear to result from

incomplete documentation or a lack of required detail. ODF staff should provide a complete list of all

activities which require prior approval or a written plan, the level of detail required, and the need for

written documentation of all required information.

Update Rules and Guidance

Some changes to the Forest Practices Rule and Statute Guidance Manual (ODF, 1997) can be identified

which could help increase understanding of the rule goals and objectives, and ultimately increase proper

rule implementation:

• Administrative compliance could be improved with the creation of uniform and detailed checklists of

prior approval and written plan requirements. These forms could be located in the guidance for

reference, in published ODF newsletters or updates, or included with notifications to assist operators,

landowners, and FPFs in identifying and documenting all required information. Sample forms of

required information are included in Appendix B.

• The rules or guidance should be revised to incorporate Recommendation F of the Report of the FPAC.

This recommendation calls for language detailing the objectives and installation criteria for effective

road surface drainage so that:

1. Road surfaces are protected from erosion and water retention,

2. Erosion of the roadside ditch is minimized,

3. Ditch water is not discharged onto unstable slopes, and

4. Ditch water (and associated sediment) discharging directly into a stream is minimized.

• The Forest Practice Rules or guidance should be updated as significant rule interpretations are clarified

and future monitoring and research results identify areas for language, requirement, and methodology

improvement.

Provide for Administration and Enforcement

Uniform administration and enforcement is a critical aspect of ensuring proper implementation of the Forest

Practices Act. This role is filled by department staff and 52 forest practice foresters who perform unit

inspections as well as work with landowners and operators in a more preventative role. The identification

of these areas of consistent compliance and resource protection concerns will help FPFs and other ODF

staff to prioritize their efforts accordingly.

Effective administration of forestry operations is greatly limited by workload and budgetary constraints at

the current time. For example, FPFs were able to perform a site inspection on only 49% of the 107,488

forestry operations completed for the period of 1995 to 2000. The current extended vacancy of several

FPF and Civil Penalties positions will likely reduce inspection rates and citation administration even further.
BMP Compliance Report.doc/Jaz B 53

Maintenance of this program at the designed staffing level and beyond would help to better address those

areas of concern. These include opportunities for FPFs to work with interested landowners before issues

arise (e.g., RMA layout, stream crossing location, road drainage design, etc.), provide technical assistance

to small landowners, pursue specific resource concerns, re-visit operations during phases or weather

conditions when resource impacts are most likely, or inspect many operations.

Consider Related Monitoring

The results of this study suggest several areas where there is a need for related future monitoring efforts.

The potential future monitoring topics identified below are specific areas for which supplemental

compliance monitoring or effectiveness monitoring and research is needed. Supplemental compliance

monitoring is needed for those rules with potential compliance and resource protection concern but which

had relatively small sample sizes. Effectiveness monitoring and research is needed to fully understand and

quantify the resource implications for those areas where sediment, slash, vegetation damage, or channel

disturbance impacts to riparian and channel conditions were identified. These and other topics are

currently being evaluated and prioritized in the Forest Practices Monitoring Program Strategy (ODF,

2002B), and as they relate to the recommendations in the Report of the FPAC. 

• Roads and Chronic Erosion. While the focus of this study is on compliance, some data were provided

on erosion and sediment delivery to streams. Noncompliance with road-related BMPs, especially

drainage and maintenance, was identified as the largest source of sediment delivery to stream

channels. Because these surveys were performed during the dry season, they also likely

underestimated the number of sediment delivery sources and total eroded volume.

Outside research results have also identified road drainage and maintenance issues as the major

source of forestry-related sediment delivery to stream channels. Luce and Black (1999) found

sediment production to be heavily correlated with road surface and unvegetated ditch and cutslope

lengths draining to a channel. Skaugset and Allen (1998) identified the relief of road drainage at

stream crossings as the most common source of sediment delivery in western Oregon. This study also

found that 25% of surveyed road length delivered drainage and sediment directly to a stream channel.

Many other recent studies in western Oregon have identified even higher levels of road drainage

connectivity with the stream network, as well as other major factors which affect sediment production,

such as surfacing material or traffic levels.

More quantitative information is needed on the effectiveness of current policy in terms of the volume of

chronic sediment being delivered to streams. Sediment production, delivery, and transport need to be

monitored in the winter to determine the effectiveness of Forest Practice Rules in minimizing sediment

impacts on streams. This need is also addressed by Recommendation K of the Report of the FPAC,

and is identified as a top priority in the Forest Practices Monitoring Program Strategy. The ODF is

currently implementing a project to evaluate the impacts of forest road surfacing materials and hauling

rates on stream turbidity during wet weather, as per Recommendation G of the Report of the FPAC.

• Slash in Small Type N Streams and Wetlands. This study found slash accumulation in Type N streams

and “other” wetlands a common result of some noncompliance practices. Improved compliance with

felling and site preparation practices near all WOS will likely reduce occurrence of this issue, although

some accumulation of slash within small Type N streams and wetlands will inevitably occur. Research

is needed to identify the specific resource effects associated with these accumulations of organic
BMP Compliance Report.doc/Jaz B 54

material of different sizes and, subsequently, the approaches to slash management which would

provide the greatest protection to these resources.

• Oregon Plan Measures. While many Oregon Plan for Salmon and Watersheds measures include

Forest Practices regulatory requirements, this project did not track the many volunteer efforts

conducted in accordance with this plan (see Appendix D). Monitoring of the rate of landowner

application of these measures and their effectiveness at achieving restoration and protection goals is a

top priority in the Forest Practices Monitoring Program Strategy.

• Significant Wetlands. Seven of the units surveyed had activities within 300 feet of a significant wetland,

but only two had activities within 100 feet. While compliance rates were generally low for significant

wetland protection BMPs, further evaluation of activities near a larger sample of significant wetlands is

needed to more fully evaluate compliance with these rules. This survey could be conducted along with

an effectiveness evaluation of current standards for protecting wetland habitat and function. Both of

these wetland monitoring needs are currently identified as high priorities in the Forest Practices

Monitoring Program Strategy.

• High Risk Site (Landslide-Prone Locations) Activities. Sample sizes were low for BMPs related to

activities on high risk sites and may have also been under-represented due to a site selection

stratification that was biased towards units with Type F streams. This study found high compliance

rates with harvesting BMPs on high risk sites and the Storm Impacts and Landslides of 1996 (ODF,

1999) study answered many questions about these areas. However, this remains an area of high

concern for potential resource damage and public safety and new rules being adopted later this year.

Further monitoring is needed to evaluate the effectiveness of these evolving BMPs at protecting soil

productivity and slope stability. The need for this is also identified by Recommendation Q of the Report

of the FPAC.

• Reforestation. Evaluation of reforestation rules dealt only with replanting within harvested portions of

RMAs (34). Replanting and free-to-grow requirements on a unit-wide basis are topics for potential

future monitoring because they were not addressed by this project. Reforestation issues were the

source of 25% of the citations issued from 1990 to 1999 (ODF, 2000D), and current public opinion in

Oregon is that effective reforestation following harvest does not occur (Davis and Hibbitts, Inc., 2001).

A survey of reforestation compliance could be coupled with monitoring of units not reforested due to

conversion to other land uses.

• Riparian Conifer Restorations. While compliance rates were generally low with rules relating to riparian

conifer restorations, this small sample size made it difficult to draw reliable conclusions from these

results. Although rarely used, this prescription has potentially very large and long-lasting effects on

stream and riparian conditions and monitoring is needed on the effectiveness of meeting its intended

goals. Over the past 5 years, the ODF has collected data on stream temperature, shade, compliance,

and riparian structure for several stream reaches on which this prescription was applied. Plans are

currently being developed to analyze these data collectively to provide effectiveness and compliance

evaluation of this management option.
BMP Compliance Report.doc/Jaz B 55

REFERENCES

Austin, Samuel H. 1997. The Virginia Forestry Sediment Yield Trend. Virginia Department of Forestry,

Charlottesville, Virginia 22903. 4 pp.

Burroughs, Edward R. Jr. and John G. King. 1989. Reduction Of Soil Erosion On Forest Roads. Gen.

Tech. Rep. INT-264. Ogden, UT. US Department of Agriculture, Forest Service, Intermountain

Research Station. 21 pp.

California Department of Forestry. 1999. Hillslope Monitoring Program: Monitoring Results From 1996

Through 1998. California Department of Forestry, Sacramento, California. 69 pp.

Davis and Hibbits, Inc. June 2001. A Forestry Program for Oregon: Public Opinion About Forests and

Forest Management in Oregon. Davis and Hibbitts, Inc., 921 SW Morrison Avenue, Suite 434,

Portland, Oregon, 97205. 30 pp.

Dent, Liz. 1997. Forest Practices Monitoring Program Strategic Plan. Oregon Department of Forestry,

Forest Practices Program. 2600 State Street, Salem, Oregon, 97310. 22 pp.

Dent, Liz. 1998. Oregon Department of Forestry’s Best Management Practices Compliance Audit Project,

Version 3.0. Oregon Department of Forestry, 2600 State Street, Salem, Oregon, 97310. 69 pp.

Dent, Liz. 1998. The Oregon Department of Forestry’s Stream Crossing Monitoring Protocol: Fish

Passage and Stream Flow Design. A Supplement to the Oregon Department of Forestry’s Best

Management Practices Compliance Audit Project. Version 2.1. Oregon Department of Forestry,

2600 State Street, Salem, Oregon, 97310. 14 pp.

Egan, A.F., R.D. Whipkey, and J.P. Rowe. 1998. Compliance with Forestry Best Management Practices in

West Virginia. National Journal of Forestry, Vol. 15, No. 4. 5 pp.

Ellefson, P.V., M.A. Kilgore, and M.J. Phillips. 2001. Monitoring Compliance with BMPs: The Experience

of State Forestry Agencies. Journal of Forestry, January 2001. 7 pp.

EPA. 1996. The Volunteer Monitor Guide to Quality Assurance Project Plans. United States

Environmental Protection Agency, Office of Wetlands, Oceans and Watersheds, 4503F, EPA 841-

B-96-003, September 1996. 59 pp.

Fortunate, Norm, P. Heffernan, K. Sanger, and C. Tootell. The 1998 Forestry BMP Audit Rport. Montana

Department of Natural Resources and Conservation. Missoula, Montana. 40 pp.

Frank, Gary. 1994. Montana Forestry Best Management Practices Implementation Monitoring, The 1994

Forestry BMP Audits Final Report. Montana Department of State Lands Forestry Division,

Missoula, Montana, 59801-3199. 31 pp.

Freese, Frank. December 1962. Elementary Forest Sampling. Agriculture Handbook No. 232. USDA

Forest Service. 87 pp.
BMP Compliance Report.doc/Jaz B 56

Hairston-Strang, Anne B. and Paul W. Adams. 1997. Oregon’s Streamside Rules, Achieving Public Goals

on Private Land. Journal of Forestry, Vol. 95, No. 7. 5 pp.

Idaho Department of Health and Welfare Division of Environmental Quality. 1997. Forest Practices Water

Quality Audit 1996. Idaho Department of Health and Welfare Division of Environmental Quality,

1410 North Hilton Street, Boise, Idaho, 83706. 32 pp.

Jackson, C.R., C.A. Strum, and J.M. Ward. 2001. Timber Harvest Impacts on Small Headwater Stream

Channels in the Coast Range of Washington. Journal of the American Water Resources

Association, Vol. 37, No. 6. 17 pp.

Koehn, Steven W. and Jeffrey D. Grizzel. 1995. Forestry Best Management Practices: Managing to Save

the Bay. Maryland Department of Natural Resources, Forest Service, Annapolis, Maryland. 32 pp.

Luce, C.H. and T.A. Black. 1999. Sediment Production from Forest Roads in Western Oregon. Water

Resources Research, Vol. 35, No. 8. 10 pp.

Macdonald, Lee H. and Alan Smart. 1993. Beyond The Guidelines: Practical Lessons For Monitoring.

Environmental Monitoring And Assessment, Vol. 26. 15 pp.

Mathieus, George. The 1996 Forestry BMP Audits Final Report. Montana Department of Natural

Resources and Conservation. Missoula, Montana. 36 pp.

Megahan, W.F. and G.L. Ketcheson. 1996. Predicting Downslope Travel Of Granitic Sediments From

Forest Roads In Idaho. Water Resources Bulletin, Vol. 32, No. 2. 10 pp.

Oregon Department of Forestry. December 1998. Forest Practice Rule and Statute Guidance Manual.

Oregon Department of Forestry, 2600 State Street, Salem, Oregon, 97310.

Oregon Department of Forestry. May 1997. Forest Practices Rule and Statute Guidance Manual. Oregon

Department of Forestry, 2600 State Street, Salem, Oregon, 97310. 519 pp.

Oregon Department of Forestry. 1999. Storm Impacts and Landslides of 1996. ODF Technical Report 4.

Oregon Department of Forestry, 2600 State Street, Salem, Oregon, 97310.

145 pp.

Oregon Department of Forestry. 2000A. Oregon Forest Practice Rules and Statutes. Oregon Department

of Forestry, 2600 State Street, Salem, Oregon, 97310. 200 pp.

Oregon Department of Forestry. 2000B. Forest Management Guidebook. Oregon Department of Forestry,

2600 State Street, Salem, Oregon, 97310. 32 pp.

Oregon Department of Forestry. 2000C. Report of the Forest Practices Advisory Committee on Salmon

and Watersheds to the Oregon Board of Forestry. Oregon Department of Forestry, 2600 State

Street, Salem, Oregon, 97310.
BMP Compliance Report.doc/Jaz B 57

Oregon Department of Forestry. 2000D. Civil Penalties Program Administration Report. Oregon

Department of Forestry, 2600 State Street, Salem, Oregon, 97310. 10 pp.

Oregon Department of Forestry. 2002A. Compliance with Fish Passage and Peak Flow Requirements at

Stream Crossing. ODF Technical Report 14. Oregon Department of Forestry, 2600 State Street,

Salem, Oregon, 97310. pp.

Oregon Department of Forestry. 2002B. Forest Practices Monitoring Program Strategy. Oregon

Department of Forestry, 2600 State Street, Salem, Oregon, 97310. 32 pp.

Oregon Forest Practices Act. 1971 (with more recent revisions). Oregon Secretary of State, State Capital,

Salem, Oregon, 97310. 25 pp.

Oregon Plan for Salmon and Watersheds. Oregon Road/Stream Crossing Restoration Guide: Summer

1998 Draft. 1998. Governor’s Watershed Enhancement Board. 255 Capital St. N.E., Salem, OR,

97310-0203. 52 pp.

Phillips, Michael J. 2000. Monitoring the Implementation of the Timber Harvesting and Forest

Management. Minnesota Department of Natural Resources, 500 Lafayette Road, St. Paul, MN,

55155-4040. 48 pp.

Robison, E. George. 1995. Interim Fish Passage Guidance at Road Crossings. June 16, 1995, ODF

Memorandum. Oregon Department of Forestry, 2600 State Street, Salem, Oregon, 97310. 14 pp.

Robison, E. George. 1997. Interim Fish Passage and Culvert/Bridge Sizing Guidance for Road Crossings.

June 27, 1997, ODF Memorandum. Oregon Department of Forestry, 2600 State Street, Salem,

Oregon, 97310. 14 pp.

Robison, E. George, Keith Mills, Jim Paul, Liz Dent, Arne Skaugset. 1999. Storm Impacts and Landslides

of 1996. Oregon Department of Forestry, 2600 State Street, Salem, Oregon, 97310. 150 pp.

Skaugset, Arne, and Marganne M. Allen. 1998. Forest Road Sediment and Drainage Monitoring Project

Report for Private and State Lands in Western Oregon. Oregon Department of Forestry, 2600

State Street, Salem, Oregon, 97310. 20 pp.

Southern Group of State Foresters. 1994. Regional BMP Compliance Monitoring. USDA Forest Service,

Southern Region. Regency Suites Hotel, Atlanta, Georgia. 5 pp.

Timber, Fish and Wildlife. 1991. 1991 Forest Practices Compliance Report. State of Washington Timber,

Fish and Wildlife. 25 pp.

Vowell, Jeffery. 2000. Using Best Management Practice Monitoring as a Measure of Forest

Resource Sustainability. http://www.srs.fs.fed.us/sustain/conf/abs/vowell.htm.

December 13, 2001.
BMP Compliance Report.doc/Jaz B 58

APPENDIX A

Unit Compliance Data
BMP Compliance Report.doc/Jaz B 59

Table A-1. Unit Compliance Data

Number of Rules Surveyed, Number of Rule Applications, and Compliance Rate for All Rule Applications

for Each Unit. Also shown are the number of non-compliant rule applications by category: Admin. =

infraction of administrative requirements, Pot. Impact = potential future impact to water quality, and Res.

Impact = observed impact to water quality.

# Rules # Applications % Applications Non-Compliance Type:

Site Surveyed Surveyed Compliant Admin. Pot. Impact Res. Impact

1 44 70 97.1 1 0 1

2 61 101 95.0 0 2 3

3 42 47 95.7 0 1 1

4 49 71 97.2 2 0 0

5 44 44 100.0 0 0 0

6 34 34 100.0 0 0 0

7 38 66 97.0 0 0 2

8 33 33 78.8 0 1 6

9 56 56 94.6 0 0 3

10 67 112 95.5 0 2 3

11 68 83 97.6 0 1 1

12 48 55 96.4 2 0 0

13 36 41 92.7 0 1 2

14 21 21 100.0 0 0 0

15 41 41 100.0 0 0 0

16 17 17 100.0 0 0 0

17 76 99 99.0 0 1 0

18 40 40 100.0 0 0 0

19 66 152 98.7 0 1 1

20 35 60 98.3 0 1 0

21 59 64 87.5 4 1 3

22 45 60 98.3 1 0 0

23 45 47 97.9 0 0 1

24 64 107 94.4 4 1 1

25 55 70 91.4 1 2 3

26 67 89 94.4 3 1 1

27 40 60 100.0 0 0 0

28 29 29 96.6 0 0 1

29 50 55 100.0 0 0 0

30 39 46 91.3 2 0 2

31 42 42 97.6 1 0 0

32 37 57 94.7 0 2 1

33 38 41 100.0 0 0 0

34 41 56 98.2 1 0 0

35 43 63 98.4 1 0 0

36 23 23 100.0 0 0 0

37 42 43 86.0 4 1 1

38 54 64 100.0 0 0 0

39 57 82 93.9 0 1 4

40 30 40 100.0 0 0 0

41 40 40 97.5 0 1 0

42 45 62 85.5 5 1 3

43 37 37 91.9 3 0 0

44 54 63 93.7 2 2 0

45 47 87 98.9 0 1 0
BMP Compliance Report.doc/Jaz B 60

Table A-1 Continued

# Rules # Applications % Applications Non-Compliance Type:

Site Surveyed Surveyed Compliant Admin. Pot. Impact Res. Impact

46 45 65 96.9 0 1 1

47 43 43 100.0 0 0 0

48 53 88 93.2 2 2 2

49 34 34 100.0 0 0 0

50 67 73 97.3 0 0 2

51 46 85 96.5 2 1 0

52 53 53 92.5 3 1 0

53 48 48 97.9 1 0 0

54 55 92 98.9 0 1 0

55 32 37 94.6 2 0 0

56 72 104 99.0 0 1 0

57 60 145 97.9 0 1 2

58 37 42 100.0 0 0 0

59 26 26 88.5 0 2 1

60 29 29 100.0 0 0 0

61 43 63 87.3 2 3 3

62 44 44 88.6 2 1 2

63 64 99 94.9 3 1 1

64 53 78 100.0 0 0 0

65 48 58 94.8 0 0 3

66 53 84 88.1 1 2 7

67 24 24 100.0 0 0 0

68 37 37 89.2 0 3 1

69 28 33 90.9 2 1 0

70 58 76 92.1 1 2 3

71 55 79 88.6 0 7 2

72 41 41 100.0 0 0 0

73 59 110 99.1 0 1 0

74 41 53 92.5 3 0 1

75 66 123 88.6 8 6 0

76 52 62 95.2 0 0 3

77 50 65 90.8 0 3 3

78 65 106 99.1 0 1 0

79 79 118 95.8 0 3 2

80 62 81 96.3 0 2 1

81 61 108 90.7 3 3 4

82 52 74 98.6 0 1 0

83 63 100 97.0 1 0 2

84 45 45 97.8 0 1 0

85 73 95 92.6 3 2 2

86 35 40 100.0 0 0 0

87 44 44 93.2 0 1 2

88 62 88 94.3 3 0 2

89 65 123 98.4 0 0 2

90 80 112 94.6 4 0 2

91 55 60 100.0 0 0 0

92 63 150 97.3 3 0 1

93 30 35 97.1 0 1 0
BMP Compliance Report.doc/Jaz B 61

Table A-1 Continued

# Rules # Applications % Applications Non-Compliance Type:

Site Surveyed Surveyed Compliant Admin. Pot. Impact Res. Impact

94 43 55 100.0 0 0 0

95 61 90 100.0 0 0 0

96 59 87 97.7 2 0 0

97 68 148 94.6 4 4 0

98 26 33 100.0 0 0 0

99 51 75 98.7 0 1 0

100 58 76 89.5 0 3 5

101 27 27 96.3 1 0 0

102 55 104 88.5 3 3 6

103 39 69 98.6 0 0 1

104 54 69 88.4 1 5 2

105 50 70 100.0 0 0 0

106 49 49 89.8 1 0 4

107 65 148 100.0 0 0 0

108 41 66 100.0 0 0 0

109 35 35 100.0 0 0 0

110 44 59 100.0 0 0 0

111 55 78 100.0 0 0 0

112 44 54 92.6 0 4 0

113 60 90 98.9 0 1 0

114 65 95 95.8 1 3 0

115 26 26 80.8 5 0 0

116 51 81 93.8 0 3 2

117 53 68 95.6 2 1 0

118 47 62 98.4 0 1 0

119 37 47 95.7 2 0 0

120 56 56 96.4 1 0 1

121 56 89 91.0 8 0 0

122 56 61 98.4 0 1 0

123 39 51 94.1 3 0 0

124 60 77 100.0 0 0 0

125 53 65 98.5 0 1 0

126 45 50 94.0 0 2 1

127 67 72 100.0 0 0 0

128 53 64 98.4 0 1 0

129 50 58 94.8 0 0 3

130 45 78 96.2 0 1 2

131 41 76 97.4 0 0 2

132 49 54 92.6 0 0 4

133 36 41 100.0 0 0 0

134 45 70 98.6 1 0 0

135 59 69 98.6 0 1 0

136 56 88 92.0 6 1 0

137 68 81 96.3 0 3 0

138 48 58 93.1 2 0 2

139 64 99 92.9 0 4 3

140 36 46 100.0 0 0 0

141 37 57 100.0 0 0 0
BMP Compliance Report.doc/Jaz B 62

Table A-1 Continued

# Rules # Applications % Applications Non-Compliance Type:

Site Surveyed Surveyed Compliant Admin. Pot. Impact Res. Impact

142 37 44 95.5 2 0 0

143 62 72 100.0 0 0 0

144 54 81 100.0 0 0 0

145 59 84 94.0 5 0 0

146 56 59 98.3 1 0 0

147 44 44 97.7 1 0 0

148 50 50 100.0 0 0 0

149 44 419 99.8 0 1 0

150 30 35 100.0 0 0 0

151 45 115 100.0 0 0 0

152 30 60 98.3 0 0 1

153 60 85 95.3 3 1 0

154 56 98 94.9 0 1 4

155 48 78 98.7 0 0 1

156 41 131 100.0 0 0 0

157 51 61 98.4 0 1 0

158 71 109 97.2 0 1 2

159 46 61 93.4 2 0 2

160 62 138 99.3 0 1 0

161 26 26 100.0 0 0 0

162 59 97 97.9 0 0 2

163 73 96 94.8 2 1 2

164 67 112 96.4 2 0 2

165 65 91 98.9 0 1 0

166 46 78 98.7 0 1 0

167 67 107 98.1 1 1 0

168 60 94 96.8 0 0 3

169 56 66 93.9 1 0 3

170 40 55 92.7 4 0 0

171 52 72 97.2 0 2 0

172 21 21 90.5 2 0 0

173 46 71 98.6 1 0 0

174 46 66 98.5 1 0 0

175 47 57 91.2 2 1 2

176 49 69 95.7 3 0 0

177 42 97 97.9 2 0 0

178 42 42 95.2 2 0 0

179 44 74 93.2 2 2 1

180 43 54 96.3 2 0 0

181 28 28 92.9 1 1 0

182 46 92 85.9 11 2 0

183 48 55 96.4 0 1 1

184 42 42 95.2 0 1 1

185 48 53 100.0 0 0 0

186 55 85 100.0 0 0 0

187 37 112 100.0 0 0 0

188 37 197 100.0 0 0 0

189 49 110 90.9 3 5 2

 Average Compliance Per Site 96.1 185 149 168
BMP Compliance Report.doc/Jaz B 63

APPENDIX B

 Sample Checklists of Administrative Rule Requirements Related to WOS
BMP Compliance Report.doc/Jaz B 64

Written Prior Approval Required For: Activity Associated

with Notification?

Activities within 100 feet of Type F or D stream or large lake Yes No

Activities within 300 feet of significant wetland Yes No

Request for land use change exemption to reforestation requirements Yes No

Machine activity conducted within a Type F or D stream, lake, or significant

wetland Yes No

Road construction within riparian management area Yes No

Road construction on high risk site in northwest or southern Oregon areas Yes No

Construction of stream crossing fill over 15 feet deep Yes No

Placement of large wood or boulders in stream channels for enhancement Yes No

Location of landing within a riparian management area Yes No

Harvesting on high risk site in northwest or southern Oregon areas Yes No

Yarding across Type F or D streams, large or medium Type N streams, lakes,

or significant wetlands Yes No

Placement of conifer logs or down trees in Type F streams for basal area

credit Yes No

Site specific vegetation retention prescription for a riparian management area Yes No

Figure B-1. Draft Checklist for Activities Associated with WOS Requiring Prior Approval. The

following activities related to protection of waters of the state require written prior approval with the Oregon

Department of Forestry.

Detailed Information Required in an Approved Written Plan: Activity Associated

with Notification?

Stream and riparian management area protection measures Yes No

RMA protection for burning within 100’ of Type F or D stream, 100’ of large

lake, or 300’ of significant wetland Yes No

Fill and drainage structure design for stream crossing fills over 15’ deep Yes No

Minimization of impacts to soil and water resources when harvesting on high

risk sites Yes No

Construction, passage of water, and duration for temporary crossing fills over

8’ deep Yes No

Sediment protection of Type D streams for activities within 100’ Yes No

Prescription used for harvest within or adjacent to a riparian management area Yes No

Filling within wetlands Yes No

Machine activity within wetlands Yes No

Road construction within wetlands Yes No

Protection of understory vegetation during harvest or site preparation within

300’ of significant wetlands Yes No

Figure B-2. Draft Checklist for Activities Associated with WOS Requiring an Approved Written Plan.

The following information for activities related to waters of the state is required in a written plan approved

by the Oregon Department of Forestry.
BMP Compliance Report.doc/Jaz B 65

APPENDIX C

Quality Assurance and Quality Control
BMP Compliance Report.doc/Jaz B 66

Table C-1. Repeated Measurement of Road Location Classification

Site # Location

Category

1st Visit

(Feet)

2nd Visit

(Feet)

Difference

(Feet)

1 Other 1100 900 200

2 >65% Slope 400 400 0

2 Other 2500 2400 100

3 Other 200 200 0

Table C-2. Repeated Measurement of Road Drainage Classification

Site # Drainage

Category

1st Visit

(Feet)

2nd Visit

(Feet)

Difference

(Feet)

1 Outsloped 1100 900 200

2 Functional Ditch 2900 2800 100

3 Outsloped 200 200 0

Table C-3. Repeated Measurement of RMA Widths

RMA # 1st Visit

(Avg. Width Feet)

2nd Visit

(Avg. Width Feet)

Difference

(Feet)

1 100 100 0

2 100 100 0

3 100 100 0

4 10 10 0

5 20 20 0

6 10 10 0

7 20 20 0

8 20 20 0

9 20 20 0

10 100 100 0

Table C-4. Repeated Measurement of RMA Tree Counts

Site # 1st Visit

(# Trees)

2nd Visit

(# Trees)

Difference

(# Trees)

1 16 16 0

2 3 4 1

3 9 10 1

4 37 42 5

Table C-5. Repeated Measurement of RMA Retained Basal Area

Site # 1st Visit

(Sq. Ft. BA)

2nd Visit

(Sq. Ft. BA)

Difference

(Sq. Ft. BA)

1 25.5 21.8 3.7

2 7.7 9.2 1.5

3 19.9 24.5 4.6

4 74.8 71.8 3.0
BMP Compliance Report.doc/Jaz B 67

APPENDIX D

Oregon Plan for Salmon and Watersheds Voluntary Measures
BMP Compliance Report.doc/Jaz B 68

OWEB

Activity # Voluntary Measure Description

ODF 1S Road Erosion and Risk Project

ODF 8S Conifer Restoration

ODF 19S Additional Conifer Retention Along Fish-Bearing Streams

ODF 20S Increased Riparian Management Area for Small Type N Steams

ODF 21S Active Placement of Large Wood During Forest Operations

ODF 22S 25 Percent In-Unit Leave Tree Placement and Additional Voluntary Retention

ODF 62S Voluntary No-Harvest Riparian Management Areas

Figure D-1. Oregon Plan Voluntary Measures. OWEB = Oregon Watershed Enhancement Board.