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Oregon Department of Forestry

Forest Practices Compliance Audit

2013

Paul Clements

Compliance and Training Specialist

Jeremy Groom

Monitoring Coordinator

John Hawksworth

Monitoring Specialist
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Acknowledgements

The assistance and cooperation of private landowners and Oregon Department of Forestry 

(ODF) field staff were instrumental in designing and implementing this project.

Jerry Clinton and Mike Thompson were also instrumental in the study design and 

implementation of this project. 

The external and internal review committee also provided valuable input. The authors would 

like to thank all the Stewardship Foresters who provided input on the draft field protocols,

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

support the field team.
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COMMITTEES AND COORDINATORS

This study has oversight by external and internal review committees. The committees’ main

functions were to review and provide feedback on the study design, field protocols and reports. 

This input was utilized by the Oregon Department of Forestry (ODF) in carrying out the study 

and completing the report. The committees met throughout the development of the project 

and will continue to meet as needed.

Internal Review Committee

Kristin Cotugno, Assistant District Forester, Central Oregon District

Mark Reed, Stewardship Forester, Forest Grove District

Marvin Vetter, Stewardship Forester, South Cascades District

Rick Wagner, Stewardship Forester, Northeast Oregon District

Stephen Wetmore, Stewardship Forester, Southwest Oregon District

Kyle Williams, Unit Forester, West Oregon District

External Review Committee

Wayne Auble, Oregon Department of Forestry – State Forests Program

Scott Gray, Stimson Lumber Company & Sustainable Forestry Initiative

Jim James, Oregon Small Woodlands Association

Chris Jarmer, Oregon Forest Industries Council

Joe Holmberg, Oregon Tree Farm Program

Adrian Miller, Olympic Resource Management

Tally Patton, Weyerhaeuser Company

Kevin McElwee, International Paper

Lee Fledderjohann, Collins Pine & Forest Stewardship Council

Josh Seeds, Oregon Department of Environmental Quality

Rex Storm, Associated Oregon Loggers

Project Coordinators

Marganne Allen, Field Support Manager

Paul Clements, Compliance and Monitoring Specialist

Jeremy Groom, Monitoring Coordinator
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Compliance Audit Report: 2013

Executive summary

In 2011 the Oregon Legislature directed the Oregon Department of Forestry (ODF) to conduct 

an audit of timber harvest practices regulated under the Oregon Forest Practices Act 

(FPA). ODF was specifically directed to contract with a third party to conduct the 

audit. Because of this requirement, protocols needed to be finalized well before the beginning 

of the study and only quantifiable rules were selected for evaluation. The 2013 compliance 

audit focused on harvest and road rules, and water protection rules. Contractors collected data 

at 200 sites harvested between 2010-2012 and provided ODF with compliance data, 

photographs, and notes. ODF used database and Geographic Information System (GIS) software 

to analyze the data and make calls of “apparent” compliance or non-compliance. Analysis of 

compliance rates focused on events causing impacts to resources. 

For purposes of this analysis, the state was subdivided geographically into FPA administrative 

areas (Eastern Oregon Area, Northwest Oregon Area, and Southern Oregon Area). Additionally 

ownership was divided into Private Industrial, Private Non-industrial, and Other classes. The 

Other class was comprised of governmental entities, including state and county forests.

The 2013 compliance audit resulted in an overall rule-level compliance rate of 97% (95% 

confidence interval = 96% - 97%). Compliance was highest in the Northwest Oregon Area and in 

the Other ownership type. Relative compliance between FPA areas and ownership types varied 

by rule.

Percent compliant

Overall 96% (96% – 97%)

FPA Area

Eastern Oregon Area 96%

Northwest Oregon Area 98%

Southern Oregon Area 95%

Ownership Class

Other 98%

Private Industrial 96%

Private Non-industrial 94%
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At a rule division basis, compliance was generally high. The highest compliance was found with 

rules dealing with vegetation retention along streams. The lowest compliance was for 

protection of “Other Wetlands”. This may indicate a need for further emphasis on small 

wetlands, although this rule division had a small sample size. Some rules for written plans also 

had lower compliance rates. This may be due to the operation covering a different area than 

expressed in the notification, mapping errors or an altered scope of operation, the affected 

resource triggering a written plan was not recognized by operators, or due to ODF database 

inaccuracies.

Rule Division

Percent 

Compliant

Several Written plans 75%

625 Road Construction and Maintenance 97%

630 Harvesting 95%

640 Vegetation Retention Along Streams 98%

655 Protection for “Other Wetlands” 72%

660 Operations Near Waters of the State 99%
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Introduction:

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

means of the Forest Practices Act Statutes and Rules. Landowners and operators are subject to 

the Forest Practices Act Statutes and Rules when they conduct any commercial activity related 

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)

Forest Practice Rules were developed to implement the objective of the FPA and are contained 

in Oregon Administrative Rules chapter 629. The ODF Private Forests Program is responsible 

for administering and monitoring the Forest Practice Rules. Compliance monitoring is used by 

ODF to assess the degree to which landowners and timber operators are following the 

provisions of the Forest Practice Rules. The results of compliance monitoring are used to 

inform ODF training programs and administration of Forest Practice Rules on the ground. 

History of Compliance Monitoring 

Between 1998 and 2000, the ODF Forest Practices Monitoring Program implemented the BMP 

Compliance Monitoring Project (BMPCMP). This was a three-year project designed primarily to 

look at how ODF, landowners, and operators were implementing the Forest Practice Rules 

related to water quality. 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 were needed. This 

project was conducted entirely by ODF employees. Results were summarized in a 2002 report1.

In 2011, the Oregon Legislature (2011 Legislative Session-Budget Note #1) directed ODF to audit 

rates of compliance with Forest Practices Act standards. In contrast with the BMPCMP study, 

this work was to be conducted by contractors. These contractors were to be responsible for 

 

1 Oregon Department of Forestry Best Management Practices Compliance Monitoring Project: Final Report. April 

2002. 75 pp. http://www.oregon.gov/odf/privateforests/docs/bmpfinaltr15.pdf. 
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collecting field data, but were not to make compliance calls in the field. ODF retained 

responsibility for interpreting field data collected by the contractors.

Methods:

The 2013 compliance audit focused on harvest and road rules. The study design was prepared 

to answer the following monitoring questions:

1. How often did operators comply with the Forest Practice Rules pertaining to harvesting, 

road construction and maintenance, and water protection?

2. How does compliance vary by FPA Administrative Area (Area) and landowner type?

3. Which rules have relatively high and low compliance rates?

4. What is the scale of resource impacts resulting from non-compliance?

5. How do compliance patterns compare to those stated in the 2002 report?

Contractors collected data at 200 sites in all three Areas (Figure 1). The number of sites chosen 

from each Area were proportional to the total number of units for which notifications of 

proposed forest operations were received. This resulted in 45% of units being chosen in each 

of the Northwest and Southern Oregon Areas, while 10% of units were chosen from the Eastern 

Oregon Area (Table 1). 
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Figure 1. Locations of units surveyed for 2013 compliance audit.

The number of sites chosen from each Area were also stratified by ownership class (Table 1). 

Ownership was classified into three groups: 

1. Private Industrial (PI), private entities owning >5,000 acres of land);

2. Private Nonindustrial (PNI), private entities owning <5,000 acres of land; and 

3. Other (OTH), generally public entities such as state and county forests.
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Area Total 

units 

visited

Landowner Class

PI PNI Other

Eastern Oregon 20 8 6 6

Northwest 

Oregon

90 32 18 40

Southern 

Oregon

90 38 17 35

Total 200 78 41 81

Table 1. Units surveyed by Area and ownership class. PI – private industrial, PNI – private non-industrial, Other –

other public entities such as state or county.

Notification numbers were randomly chosen from the Forest Activities Notification System 

(FACTS) database for each Area and ownership class. Landowners were then contacted for 

access permission. Approximately 54% of landowner contacts resulted in access permission to 

suitable sites. When a site was found to be unsuitable, or landowner permission could not be 

obtained, replacement sites were chosen using the same random process. Sites were deemed

unsuitable if landowners refused access or did not respond to ODF inquiries, harvest did not 

occur or was currently underway, or other reasons (Table 2). These other reasons included 

notification for non-commercial harvests, ownership changes, and land conversions. Data for 

Table 2 may be incomplete due to changes in information retention following alterations of 

permission procedures. 

Ownership Number of 

Inquiries

Permission 

Granted No Response Landowner Refusal

Did Not 

Operate 

Active 

Harvest

Other 

Reasons

PI 114 77 (60%) 5 (4%) 5 (4%) 9 (6%) 2 (2%) 16 (14%)

PNI 142 42 (30%) 32 (23%) 16 (11%) 20 (14%) 1 (1%) 31 (22%)

Other 128 88 (69%) 5 (4%) 5 (4%) 9 (7%) 4 (3%) 17 (13%)

Total 384 207 (54%) 42 (11%) 26 (7%) 38 (10%) 7 (2%) 64 (17%)

Table 2. Landowner permission success and failure rates by landowner type. More than 200 permissions were 

obtained but only 200 permissions were used in the study.
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The directive to use contractors for fieldwork affected project design. ODF selected a subset of 

quantifiable rules for evaluation, and then designed a field protocol that emphasized 

quantitative measurements and identification of specific conditions. The contractors submitted

raw data to ODF. ODF monitoring team members then conducted a quality control field check 

on 10% of surveyed units. Once data quality met acceptable standards, ODF used database and 

GIS software to analyze the data. The software performed logical queries to determine the 

number of applications (landings, stream segments, road segments) at which rules applied and 

whether observed practices appeared to be noncompliant. The audit assesses “apparent 

compliance” with rules; contractors provided data on measured site conditions and ODF used 

those data to assess rules. 

In practice, ODF Stewardship Foresters assess actual compliance or non-compliance with rules

and respond in a variety of ways to what they find on a given site. Reported compliance rates 

should be interpreted in this document as apparent compliance rates.

Apparent noncompliance was generally assessed based on unsatisfactory conditions (e.g., road 

gullying) that also appeared to be causing resource impacts. These impacts included the 

following conditions:

1. Ongoing or imminent delivery of sediment or organic debris to Waters of the State. This 

was the criterion used in most rules.

2. Metallic waste and petroleum products in Waters of the State. 

3. Petroleum products left in the forest.

4. Stream channel disturbance.

5. Loss of shade or other riparian functions.

6. Disrupted hydrology.

Some forest operations trigger the need for a written plan to be submitted with the 

notification. Written plans provide Stewardship Foresters with the opportunity to comment of 

potential resource impacts. A denial of this opportunity is considered sufficient to establish 

noncompliance in these cases. This would be administrative noncompliance as opposed to 

noncompliance linked to actual natural resource impacts.

A list of the assumptions used in determining apparent noncompliance and applicable 

populations is given in Appendix 1.

Once the list of noncompliant events and applicable populations was determined, numbers 

were summarized by total number of applications and by unit. Statistical calculations were 

performed based on the total number of applications.
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Results:

Rule level compliance

Rule-Level compliance rates are given in Table 2. Rules in this case were pooled together, with 

the total number of noncompliant applications over all sites and rules being divided by the 

number of total applications. On this basis, compliance is 97%, with a 95% confidence interval 

between 96% and 97%. Rule level compliance is highest in the Northwest Oregon Area. At an 

individual rule level, these geographical relationships seem to hold up, with the Northwest 

Oregon Area generally showing higher compliance than the Southern Oregon Area for most 

rules (Appendix 2). The Eastern Oregon Area is quite variable, and interpretation is often 

complicated by small sample size.

Number of Rule Applications

Not Proportion

Compliant Applicable Compliant

Overall 1948 55,575 96%

Eastern Oregon Area 132 3461 96%

Northwest Oregon Area 565 26,835 98%

Southern Oregon Area 1251 25,279 95%

Table 2. Rule level compliance based on pooled data (total number of times a rule applied).

Differences between the Northwest Oregon Area and Southwest Oregon Area were especially 

pronounced on rules dealing with roads on steep slopes (OAR 629-625-310(2) and 310(4)), 

equipment in streams (OAR 629-630-800(2)), and filtering of skid trail drainage (OAR 629-630-

300(2)). 

Compliance rates are broken down by ownership class in Table 3. Rule level compliance is 

highest for the Other ownership class. Although the pooled data in this table shows the Private 

Nonindustrial class as having the lowest compliance rate, the picture at an individual rule level 

was much more variable. On specific rules, the Private Nonindustrial class often had the 

highest compliance rate. As with FPA administrative Area, small sample size frequently 

complicated comparisons between the Private Nonindustrial and other ownership classes.
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 Number of Rule Applications

Not Proportion

Compliant Applicable Compliant

Overall 1948 55,575 96%

Other 479 21,905 98%

Private Industrial 1213 29,176 96%

Private Nonindustrial 256 4,494 94%

Table 3. Rule level compliance by ownership class.

Differences between the Other and Private Industrial classes were especially pronounced for 

rules dealing with slash in and near streams (OAR 629-630-600(3)(b) and (3)(c)). This may be 

explained by the larger buffers left on State Forest land, which composes 52% of the Other 

class. The Other class also had higher compliance with placement of effective cross drains (OAR 

629-625-420(2)).

Table 3 shows compliance totals broken down by rule division. (Section 605 is assessed 

separately in the section devoted to written plan rules and administrative compliance.) 

Although compliance rates are high for most rule divisions, they are notably lower for “other 

wetlands”. Signs of operational activity were frequently observed in very small wetland areas 

much smaller than 1⁄4 acre in size. However, the sample size for this rule division was much 

smaller than for most others.

Number of Rule Applications

Rule 

Division Description Noncompliant Total

Proportion

Compliant

625

Road Construction and 

Maintenance 582 20,941 97%

630 Harvesting 1251 25,371 95%

640

Vegetation Retention Along 

Streams 13 844 98%

655

Protection for “Other 

Wetlands”

13 46

72%

660

Operations Near Waters of 

the State 81 8276 99%

Table 3. Compliance by rule division.

Rules in Division 625, road construction and maintenance, had a relatively high compliance rate 

of 98%. Rule subsection 500, dealing with rock pits, had perfect compliance, but with a small 

sample size. Rules dealing with road drainage generally exceeded 98% compliance. However, 

drainage structures were not as functional as this statistic implies. Gullies were observed on 
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26% of road segments, while 43% of culverts were partially or completely blocked. Only those 

roads and culverts that connect to streams were considered in the compliance rates. The 

lowest compliance rate for division 625 (20%) had to do with removal of temporary crossings at 

roads. Another road drainage rule with low compliance (74%) was OAR 629-625-330(4), which 

specifies effective filtering at stream crossings. Road design rules dealing with end hauling of 

waste material and stable cuts and fills also had relatively low compliance levels (Appendix 2). 

Division 630, harvesting, had a compliance rate of 95%. Relatively high compliance (99%+) was 

found for drainage dispersal at landings and for keeping waste metal out of waters of the state. 

The lowest compliance was found for rules dealing with skid trail temporary stream crossings. 

These had a composite compliance rate of 61%. Rules dealing with slash in non-fish bearing 

(Type N) streams and petroleum waste at landings also had relatively low compliance. 

Petroleum waste, such as grease tubes, was commonly found at units that were otherwise 

compliant.

Division 640, vegetation retention, had a high compliance rate of 98%. Compliance focused on 

tree retention within 20 feet of the stream; no riparian areas were cruised to assess compliance 

with basal area retention standards. Tree retention along Type F (fish-bearing) streams 

exceeded that along Type D and Large and Medium Type N streams, but all exceeded 96% 

compliance.

Division 655, protection for Other Wetlands, had the lowest compliance rate of any Division. 

Compliance with rules prohibiting machinery entry into wetlands <1/4 acre was particularly low 

at 68%.

Division 660, operations near waters of the state, received a high compliance rate of 99%. This 

was largely a function of the large number of stream segments in the applicable population. 

While there were 81 cases of small N streams that had been relocated or had soil material 

added or removed, these were a small proportion of all surveyed stream segments.

Appendix 2 shows tables broken down by individual rule. There is increased variability in 

compliance rates at the individual rule level relative to the average of all rules in a Division as 

described by the preceding tables. 

Administrative Compliance: Written plans

Compliance rates for written plans are given in Table 4. Written plans were evaluated for each 

condition that triggered a rule requiring a written plan. Thus, a single written plan could satisfy 

one rule while failing to address another. Overall, 75% of applications requiring written plans 

were compliant. 
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Several rules governing operations within 100 feet of a stream were coded similarly on our data 

sheet, and thus were grouped together in analysis. These rules composed the majority of 

written plans, and had an overall compliance rate of 83%. The absence of a written plan in 

these cases appeared to be due to one of two reasons: 

1. The operation covered a different area than expressed in the notification. This may be the 

result of poor mapping or an altered scope of operation; or

2. The affected resource was not recognized by operators or due to ODF database inaccuracies.

Rules Type WP 

compliant

No WP/does 

not address 

issue

% Compliant

629-605-170-1a

629-625-100-2b

629-625-100-2c

Operations within 100 

feet of certain WOS

40 8 83%

629-630-200-3 Landing in RMA 0 4 0%

629-625-430-2 New stream crossings 3 0 100%

629-625-320-1b(B) Stream crossings >15 feet 1 2 33%

629-630-800-4c Temp crossings >8 feet 0 1 0%

629-630-700-3.2 Yarding in RMA 1 0 100%

Table 4. Compliance with written plans. One compliance application was possible for each rule type relevant to a 

given unit. WOS – Waters of the state.

Sample size on other rules was too small to draw definitive conclusions on compliance rates. 

This condition was complicated by the fact that road construction was often performed using a 

different notification number than the timber harvest. Additionally, non-statutory written 

plans may be waived at the Stewardship Forester’s discretion. ODF staff associated with the 

compliance audit may not have had records of these waivers.

Unit-level compliance. 

Compliance was summarized for each of the surveyed units. Unit compliance rates were 

calculated as the total number of times a unit complied with the rules divided by the total 
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number of rule applications. Figure 2 shows the number of units that achieved a given 

compliance level. For example, 82 units ranged from 96-100% compliance. 

Compliance rates for individual units ranged from 81%-100% and averaged 97%. Median 

compliance was 98%. Thirty percent of units fully complied with all pertinent rules. 

Figure 2. Frequency distribution of unit compliance rates

Scale of resource impacts

The scale of resource impacts caused by sediment delivery was generally quite small. Of 313 

events contributing sediment to Waters of the State, 75% contributed less than 1 cubic yard of 

sediment (Figure 3). These events frequently involved trace amounts of sediment found in or 

adjacent to streams. The five events that contributed more than 10 cubic yards of sediment 

were associated with roads. The one event exceeding 100 cubic yards was associated with a 

sidecast failure on a steep slope. 

The bulk of this delivery was to small water bodies. In 94% of these cases, sediment was 

delivered to Small N streams. Delivery to wetlands <1/4 acre accounted for another 3%. Less 

than 2% of sediment events happened in all fish-bearing waters combined. Each of these 

events contributed less than 1 cubic yard of sediment.
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Figure 3. Size of events delivering sediment to Waters of the State

Like sediment delivery, impacts from organic material in streams were concentrated in smaller 

water bodies. Ninety eight percent of compliance issues related to slash in or near streams 

occurred on Small N streams. Many of these were seasonal streams with high gradients. 

Wetlands under 1⁄4 acre were responsible for another 1% of slash events. On only one occasion 

was slash observed in a fish-bearing body of water. This occurred on a small fish-bearing lake.

Grease tubes and other petroleum containers were left on 8% of landings. These were 

generally found on landings far from any Waters of the State. Potential short-term impacts to 

these Waters were of low concern. Nevertheless, these containers are considered petroleum 

waste and their removal is required by the Forest Practice Rules.

Comparison with 2002 figures

Because of methodological differences, it is difficult to quantitatively compare the 2013 findings 

with those from the 2002 report. However, qualitative comparison indicates that many of the 

compliance issues identified in 2002 continue to have relatively low compliance in 2011 and 

2012. These include issues related to removal of temporary crossings, slash piling near Waters 

of the State, removal of petroleum-related waste, protection of Other Wetlands, and fill erosion 

at stream crossings. Missing and inadequate written plans were an administrative concern in 

both studies. Road surface drainage issues continued to be a concern in the 2013 study, 

although they generally did not result in resource damage. 

Certain rules that exhibited high compliance rates in the 2002 report typically continued to 

score highly in 2013. These rules included vegetation retention for Type N and D streams and 

235

72

4 1

0

50

100

150

200

250

0-1 1-10 10-100 >100

Number of events

sediment delivery (cubic yards)
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rules related to rock pits. There were two areas where compliance either gained or lost ground 

in 2013. The one rule governing cable yarding near Waters of the State that we examined (OAR 

629-630-700(4)) scored at the median value of 98% in 2013 versus 90% in 2002. Rules related 

to road prism design became areas of relatively low compliance, varying from 90-93% 

compliance versus 99% compliance in 2002.

Sediment delivery is far more skewed toward low-volume events than was reported in 2002. 

This may indicate that the current survey methodology is more prone to pick up low volume 

events than was the previous study. Alternatively, there may be a reduction in size of the 

average sediment producing event. This could reflect improved forest practices that, while not 

reducing the number of sediment events, is reducing the impacts from those events. During 

quality control field checks, ODF staff frequently observed sediment control structures that 

were partially effective at keeping sediment from Waters of the State. Improvements in design 

and construction of sediment control structures may be sufficient to bring future operations 

into compliance.

Discussion:

The data presented in this report reflect a significant period of change for the forest industry 

and the Department due to the last economic recession. The units surveyed during the 2013 

compliance audit reflect a period of forest activity when the number of Stewardship Foresters 

was only beginning to recover from sharp staff reductions in 2009. The low number of 

Stewardship Foresters resulted in a reduced capacity to conduct field inspections. Recent 

increases in the numbers of Stewardship Foresters, along with organizational changes, have

resulted in an increase in the number of inspections. There is a need to educate new 

Stewardship Foresters in consistent and effective application of these rules. To meet that need, 

the ODF Private Forests Division hired a training coordinator in 2012 and training activities are 

underway. In particular, the Department has a goal of integrating Compliance Audit field visits 

with Stewardship Forester training. The demands of completing quality assurance checks and 

contractor payments in a timely fashion has made it challenging to fully integrate training into 

this process. The 2014 audit will afford another opportunity to explore an improved model of 

integrating training into the audit process. Particular focus will be given to priority areas 

discussed below. 

While the Stewardship Forester can provide input on field application of Forest Practice Rules,

information on effective BMP design may also be conveyed to landowners and operators by 

educational institutions and professional organizations. ODF will utilize existing partnerships 
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with OSU, AOL, and other professional groups to provide classes on the priority areas identified 

in this report. 

Emphasis areas for educational activities include the following:

 Identification of small water bodies.

o Small N streams. Many operations occur near stream initiation points. These 

streams may not be recognized, particularly under dry conditions. Improved 

standardization of methods for determining stream initiation is important. 

o Small wetlands. Increased education and awareness of the presence of wetlands 

less than 1⁄4 acre may reduce their susceptibility to mechanical entry. 

 Effective removal of temporary crossings on roads. Although attempts were usually 

made to remove these crossings, they generally retained some steep fill, or the postremoval banks had over steepened side slopes. Improvements could be made where 

erosion control measures were warranted on remaining fill materials. 

 Effective removal of temporary crossings on skid trails. Skid trails often crossed very 

small Type N streams but exhibited lower compliance rates. 

 Effective drainage and filtration techniques upslope of stream crossings. In many cases, 

efforts at drainage ditches and waterbars were made, but these were often constructed 

ineffectively. 

 Effective road maintenance and construction techniques on steep terrain. Unstable 

sidecast and fill was frequently observed in steep terrain, particularly in Southwest 

Oregon. Increased emphasis on practices related to endhauling and construction of 

stable fills could reduce the sidecast failures observed in this terrain.

Other areas that can reduce the potential risk to waters of the state include: 

 Removal of petroleum products from the forest. Grease tubes were commonly found at 

landings. Although they did not pose an immediate water quality hazard, they could 

potentially have long-term impacts. 

 Road maintenance. Gullies and blocked drains were frequently observed on the forest. 

Although these usually did not contribute sediment to streams, effective road 

maintenance is necessary to prevent future resource impacts.
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On a final note, one of the largest problems in assessing compliance with written plan 

requirements was finding the proper notification for road building activities that applied to a 

given timber harvest unit. This difficulty occurred because road construction was often 

performed using different notifications than was the harvest. A spatially based notification 

system (FERNS) is being developed by ODF. This is likely to improve the management of 

notification information for statewide projects like the Compliance Audit.