CONSTITUTION HALL • 525 WEST ALLEGAN STREET • P.O. BOX 30028 • LANSING, MICHIGAN 48909-7528

www.michigan.gov/dnr • (517) 284-MDNR(6367)

STATE OF MICHIGAN

DEPARTMENT OF NATURAL RESOURCES

LANSING

RICK SNYDER

GOVERNOR

DR. WILLIAM E. MORITZ

DIRECTOR

March 24, 2016

Mr. Prasad Chumble

U.S. Environmental Protection Agency Headquarters

1200 Pennsylvania Avenue, N.W.

Office of Water

Office of Wastewater Management

Mail Code: 410M

Washington, D.C. 20460

Dear Mr. Chumble:

Subject: State Programs for Protection of Water Quality from Forest Road Discharges

I write with an understanding that the U.S. Environmental Protection Agency is 

interested in receiving additional information regarding accountability measures for 

noncompliance with state Forestry Best Management Practices (BMP) programs.

Michigan has adopted and used a BMP guide for Sustainable Soil and Water Quality 

Practices on Forest Land since 1994, with the most recent update published in 2009. 

The use of the BMPs is voluntary in Michigan, but compliance does enable responsible 

parties to meet pertinent environmental regulations, including the federal Clean Water 

Act; Part 31, Water Resources Protection, of the Natural Resources and Environmental 

Protection Act, 1994 PA 451 as amended (NREPA); Part 91, Soil Erosion and 

Sedimentation Control, of NREPA; Part 301, Inland Lakes and Streams, of NREPA; and 

Part 303, Wetlands Protection, of NREPA.

The advent of forest certification programs has elevated the awareness and 

implementation of forestry BMPs over the past decade. Forest certification programs 

presently function as an effective accountability measure for compliance with BMPs in 

that the programs require that certificate holders meet or exceed the recommended 

BMPs and that BMP monitoring takes place (e.g. SFI 2015-2019 Forest Management 

Standard, Objective 3 – Protection and Maintenance of Water Resources).

Approximately 5.9 million acres of public and private forestland in Michigan is certified 

under the forest management standards of the Forest Stewardship Council®, 

Sustainable Forestry Initiative®, and the American Tree Farm System, all of which 

specifically require compliance with forestry BMP and are regularly audited for 

conformance.

Michigan Department of Natural Resources (DNR) has been conducting BMP 

compliance audits on both certified and non-certified forest lands since 1996. As of 

2011, the audits were conducted under the auspices of the of Michigan Sustainable
Mr. Prasad Chumble

Page Two

March 24, 2016

Forestry Initiative®– Implementation Committee. The most recent BMP audit was 

conducted in 2014, and assessed BMP compliance on 36 sites (with a total of evaluated 

1,250 BMPs) located on national forest lands, state forest lands, industrial private 

(corporate) forest lands, and non-industrial private (family) forest lands.

Results of the 2014 audit showed that 93.7% of BMPs on the audited lands were being 

applied correctly or in an acceptable manner; 3.6% were being applied incorrectly; and 

only 2.7% were needed but not applied.

Forest certification also influences the operations of forest producers (logging 

companies and sole proprietors) that operate on both certified and non-certified forest 

ownerships. The SFI 2015-2019 Forest Management Standard (Objective 11 – Training 

and Education) and Fiber Sourcing Standard (Objective 6 – Training and Education) 

require SFI Implementation Committees to provide a program for core and continuing 

education (including BMPs for protection of water quality, streamside management, and 

road construction, maintenance, and retirement) for designation as a Qualified Logging 

Professional (QLP). The verification of a responsible QLP is required for execution of 

timber sale contracts on SFI certified forest lands, and is also required for sourcing from 

both SFI certified and non-SFI certified forestlands to SFI certified primary mills.

Through the SFI – Implementation Committee, Michigan also maintains an Inconsistent 

Practices Reporting 1-800 telephone number by which the public may report any 

observed instances of improper logging operations by SFI QLPs. Such reports are 

promptly investigated by the SFI – Implementation Committee.

I hope that this information proves useful for the purpose of U.S. EPA assessment of 

state programs for protection of water quality from forest road discharges. 

If you have any questions regarding this matter, please contact Mr. David Price, Forest 

Planning and Operations Manager, Forest Resources Division, at 517-284-5891; 

priced1@michigan.gov; or Department of Natural Resources, P.O. Box 30452, Lansing, 

Michigan 48909; or you may contact me.

Sincerely,

William O’Neill

Natural Resources Deputy Director

517-284-5810

cc: Mr. David Price, DNR