1 

## Oregon Department of Forestry Forest Practices Compliance Audit

2013

Paul Clements Compliance and Training Specialist

Jeremy Groom Monitoring Coordinator

John Hawksworth Monitoring Specialist2 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 als o 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, c ontacted landowners, and arranged logistics to support the field team.3

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 proje ct 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 F orests 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 Coordinator4 

# 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 q uantifiable 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

- 201 2 and provided ODF with complianc e data, photographs, and notes. ODF used database and G eographic I nformation S ystem (GIS) software to analyze the data and make calls of “apparent” compliance or non

- compliance. Analysis of compliance rates focused on e vents 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 Pri vate Industrial, Private Non

- industrial, and Other classes. The Other class was comprised of governmental entities, including state and county forests.

The 2013 compliance audit r esulted 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 % (9 6 %

– 97%)
FPA Area E astern Oregon Area 96 %
N orthwest Oregon Area 98 %
S outhern Oregon Area 95 % Ownership Class Other 98 %
P rivate Industrial 96 %
Private Non

- industrial 94 %5

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 emph asis 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 %6



### Introduction: The Oregon Department of Forestry (ODF) regulates forestry o perations 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 harves ting 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 mai ntenance 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 Oregonian s . (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 Administrativ e 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 provision s 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 Mo nitoring 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 c onducted entirely by ODF employees. Results were summarized in a 2002 report 1

.
In 2011, t he Oregon Legislature (2011 Legislative Session

- Budget Note #1) directed ODF to audit rates of compliance with Forest Practices Act standards. In contrast with the B MPCMP study,

t his work was to b e 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

.7

collecting field data, but were not to make compliance ca lls 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 con struction 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 si tes in al l three Areas ( Figure 1 ). The number of sites chosen
from each A rea 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 eac h of the Northwest and Southern Oregon Areas, while 10% of units were chosen from the Eastern Oregon Area ( Table 1)

.8

Figure 1. Locations of units surveyed for 2013 compliance audit

.
The nu mber of sites chosen from each A rea 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.9

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.

N otification numbers were randomly chosen from the Forest Activities Notification System ( FAC TS ) database for each Area and ownership class

. Landowners were then contacted for access permission. Approximately 54% of landowner contacts resulted in access permission to
suitabl e 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. Site s were deemed
unsuitab le if landowner s refus ed access or did not respond to ODF inquiries , ha rvest 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 re tention 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.10

The directive to use contractors for fi eldwork affected project design . ODF selected a subset of quanti fiable rules for evaluation, and then designed a field protocol that emphasi zed quantitative measurements and identifi cation 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 stand ards, ODF used database and
GIS softwa re to analyze the data. The software perform ed logical queries to determine the number of applications (landings, stream segments, road segments) at which rules applied and
whether observed practices appeared to be no ncompliant

. 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 Forester s 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 n oncompliance was generally assessed based o n unsatisfactory conditions (e.g ., roa d gullying) that also appeared to be causing resource impacts

. These impacts included the following conditions:

1. O ngoing or imminent delivery of sediment or organic debris to Waters of the State . This
was the criterion used in most rules.
2. Metallic waste a nd petroleum p roducts 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 wi th the notification. Written plans provide Stewardship Forester s 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 applicab le populations was determined, numbers
were summarized b y total number of applications and by unit. Statistical calculations were performed based on the total number of applications.11



### Results: Rule level compliance

Rule

- Level compliance rates are given in Table 2

. Rules in this case were pooled together, with
the tot al number of noncompliant applications over all sites and rules being divid ed by the number of total applications . On this basis, compliance is 97 % , with a 95% co nfidence 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 t he 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
C ompliant A pp licable C omp liant
Overall 19 48 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 o wnership 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 varia ble. On specific rules, the Private Nonindustrial class often had the highest co mpliance rate. As with FPA administrative Area, small sample size frequently complicated comparisons between the Private Nonindustrial and other ownership classes.12 Number of Rule Applications
Not Proportion
C ompliant A pplicable C omp liant 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.

Dif ferences 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 h igher 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 compli ance 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 on13

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
lowes t compliance rate for division 625 (20%) had to do with removal of temporary crossings at
roads. A nother road drainage rule with low compliance (74%) was OAR 629

- 625

- 330 ( 4 ) , which specifies effective filtering at stream crossings. Road design rules dealing wit h 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 la ndings 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 %. Compl iance 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, o perations 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 t here were 81 cases of small N streams that had been relocated or had soil material
added or removed , these were a small pr oportion 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 al l 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.14

Several rules governing operations wi thin 100 feet of a stream were coded similarly on our data

s heet, 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 cov ered 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 N o 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. Addit ionally, 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 surve yed units. Unit compliance rates were calculated as the total number of times a unit complied with the rules divided by the total15

number of rule applications. Figure 2 shows the number of units that achieved a given compliance level. For example, 82 uni ts ranged from 96

- 100% compliance.

Compliance rates for individual units ranged from 81 %

- 100% and averaged 9 7 %. 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 sedime nt events happen ed in all fish

- bearing waters combined

. Each of these

events contributed less than 1 cubic yard of sediment.16

Figure 3 . Size of events delivering sediment to Waters of the State

Like sediment delivery, impacts from organic material in stream s were conce ntrated 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 oc casion
was slash observed in a fish

- bearing body of water. This occurred on a s mall f ish

- bearing l ake.

Grease tubes and other petroleum containers were l eft on 8% of landings

. These were generally found on landings f ar fro m any Waters of the State. P otential 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

c ompliance issues identified in 2002 continue to have relatively low compl iance 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 w ritten 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)17

rules related to rock pits. There were t wo areas where compliance either gained or lost ground
in 2013. T he one rule g overning cable yarding n ear 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

. R ules related to road prism design became areas of relatively low compliance , varying from 90

- 93% complianc e 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. Altern atively, 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 fiel d 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 operat ions 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 Forester s

was only beginning to recover from sharp staff reductions in 2009 . The low number of Stewardship Forester s resulted in a reduced capaci ty to conduct field inspections. Recent increases in the numbers of Stewardship Forester s, along with organizational changes, have resulted in an increase in the number of inspections. T here is a need to educate new Stewardship Forester s in consistent and effective application of these r ules

. T o meet that need,
the O DF Private Forests Division hired a t rain ing c oordinator in 2012 and t raining 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 integrat ing training into the audit process. Particular focus will be given to priority areas
discussed below.

While the Stewardship Forester ca n provide input on field application of Forest Practice Rules

, information on effective BMP design may also be convey ed to landowners and operators by educational institutions and professional organizations. ODF will utilize existing partnerships18

with OSU, AOL, and other professional groups to provide classes on the priority areas identified in this report

.

E mphasis a reas for educational activities include the following:

 Identification of small water bodies.

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

s tream s may not be recognized, particularly under dry conditions. Improved
standardi zation of methods for determining stream initiation is important.

o Small wetlands. Increased education and awareness of the presence of w etlands
less than 1⁄4 acre may reduce their susceptib ility to mechanical entry

.

 E ffective removal of temporary crossings on roads . Although attempts were usually made to remove these crossings, they generally retained some st eep fill, or the post

removal banks had over steepened side slopes. Improvements could be made where

e rosion control measures were warranted on remaining fill material s.

 E ffective removal of temporary crossings on skid trails. Skid trails ofte n crossed very small Type N streams but exhibited lower compliance rates

.

 E ffective drainage and filtration techniques upslope of stre am 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 observe d 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 wat ers of the state include:

 R emoval 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.

 R oad maintenance. Gullies and blocked drains were frequently observ ed on the forest. Although these usually did not contribute sediment to streams, effective road maintenance is necessary to prevent future resource impacts

.19

On a final note, o ne of the largest problems in a ssessing 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 notific ations than was the harvest. A spatially based notification
system (FERNS) is being developed by ODF. Th is is likely to improv e the management of
notification information for statewide projects like the Compliance Audit.