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# Introduction The Virginia Department of Forestry Best Management Practices Implementation Audit Program is based primarily on the Southern Group of State Foresters published framework for state forestry agencies (http://www. southernforests.org/publications/SGSF%20Regional%20 BMP%20Framework%20Protocol%20publication_2007. pdf/view). This standardized protocol was intended to ensure that data collected by southern states could be combined into one report. That report is periodically compiled, prepared and submitted to the USDA Forest Service Region 8, as well as USEPA in Atlanta by the Southern Group of State Foresters. However, this protocol is sufficiently flexible to be applied to each state’s individual BMP guidelines. At the direction of the State Forester, Virginia is monitoring 240 harvested tracts each year and compiling an independent annual report based on this protocol. These data are submitted periodically for the Southern Group five-year report (http://www. southernforests.org/publications). 

# Methods Every quarter of every year, 60 tracts are selected randomly from harvests that received a VDOF final inspection two quarters previous to the audit quarter. This allows approximately six months between BMP implementation and the audit field visit. This timing allows for an assessment of how BMP integrity changes over time and provides for a modest sampling of silvicultural practices, such as site preparation, tree planting and weed control. VDOF is randomizing within each of the three administrative regions (Eastern, Central and Western) with the number of selected tracts proportional to the number of harvests for each sample quarter. This concentrates BMP audits in areas where most harvesting is occurring. In this, the fifth audit cycle (1st – 4th quarter, 2014), there are 240 total audits completed and the regional breakdown is displayed in Table 1. Each audit tract will result in a “% Yes” score for each BMP category. That percentage describes what proportion of audit questions in that category that were applicable to that tract were positively fulfilled by the operator in the field. The audit questions are evaluated and answered during a field visit by one of four water quality engineers and/or nine water quality specialists who are full-time VDOF personnel. Every auditor is regularly trained in a group setting to maintain accuracy and consistency across the state. This enables VDOF to evaluate audit results generally by BMP category or type. Each of the 240 tracts audited is treated as a discreet unit, and the average and median tract scores are reported as the “harvest average or median score.” Each audit is comprised of 117 questions in 10 categories (Appendix A). These data are also combined across all tracts and all question responses are averaged together as a single data set by audit category and reported as the “BMP average.” This is the average percentage of “Yes” responses when all audit questions are considered together without regard for the individual tract audits. This approach attempts to more accurately describe the overall BMP condition as a whole in Virginia. This BMP average also assigns greater importance to audits that have more applicable questions. These data consist of 28,080 total questions of which 20,218 were deemed not applicable, 964 were answered “No” and 6,898 were answered ”Yes.” These categories and questions relate directly to the major recommendations outlined in the BMP manual entitled Virginia’s Forestry Best Management Practices for Water Quality, 5th Edition. This technical manual is available online Table 1. Number of BMP audits completed by VDOF administrative region during the audit cycle for the 2014 calendar year. Region Number of Audits Central 103 Eastern 80 Western 57Page 2 (http://www.dof.virginia.gov/water/index-BMP-Guide.htm). In most cases, a large portion of the questions may not apply to any specific tract. Questions or entire categories that do not apply to a tract are given a non-applicable (N/A) status and are not included for calculation of final results. This ensures that calculated averages do not reflect missing items that do not apply to the harvest. Each individual question in the audit process is also tracked over time to determine which BMP issues in the BMP Manual are in need of improvement. This information is particularly valuable to the SHARP Logger program, which is an SFI industry-sponsored logger training program at Virginia Tech (http://sharplogger.vt.edu/) as it can help guide future educational efforts. These data also will assist VDOF, industry and consulting personnel as they inspect tracts and assist operators on the ground. 

# Results The data for the 2014 audit are displayed as a series of tables and charts. Table 2 displays overall BMP average data for the entire state by BMP category. Confidence in the data is reported as a 95 percent margin of error and was calculated according to the SGSF protocol and generally accepted statistical procedures. While Table 2 shows statewide results, Table 3 shows the BMP average values by VDOF administrative region. These averages (Tables 2 and 3) are the result of combining questions in the categories across all 240 audits as a single complete set and averaging those questions by category. This is the best method to evaluate overall BMP issues across the state. It is important to note that when all individual harvest audit scores were simply averaged together (harvest average) the value calculated is somewhat different and in this case is approximately 88.3 percent statewide. The averages in Tables 2 and 3 address the overall BMP condition as indicated by all audits combined while the average value of the tract audits (88.3 percent) ignores the fact that not all audits are the same with regard to number of pertinent issues (non-N/A questions) involved and assumes all audits are of the same weight. Both values are useful and correct as long as the user understands the difference as stated above and in the previous “Methods” section. These data indicate that very little site preparation (fire, mechanical and chemical) is taking place up to six months after harvest, and it is for this reason that caution should be used when considering the importance or value of the site Table 2. Statewide data for the BMP audit by BMP category. These data represent statewide averages for Virginia for the 2014 audit cycle. BMP CategoryNumber of TractsYes (%)Margin of Error (%) Chemicals 4 100.0

– Crossings 108 89.8 +/- 5.8 Decks 237 94.0 +/- 3.1 Fires 2 76.0

– Mechanical 1 83.3

– Planning 240 85.9 +/- 4.5 Roads 195 83.7 +/- 5.3 Skidding 237 84.5 +/- 4.7 SMZs 157 89.2 +/- 5.0 Wetlands 6 97.3 +/- 13.2 All 240 87.7 +/- 4.2 Logging 240 87.8 +/- 4.2

Table 3. Regional data for the BMP audit by BMP category. These data represent regional averages for all three regions for the 2014 audit cycle. BMP Category Central (% Yes)Eastern (% Yes)Western (% Yes) Chemicals 100.00 100.0 N/A Crossings 95.1 90.2 77.8 Decks 92.4 97.3 92.8 Fires 76.0 N/A N/A Mechanical 83.3 N/A N/A Planning 89.0 97.0 64.4 Roads 82.6 90.1 81.7 Skidding 89.5 91.0 72.7 SMZs 90.8 95.0 73.9 Wetlands N/A 96.7 100.0 All 89.2 93.7 79.4
preparation averages. Greater than one third of all audit tracts (108 of 240) had at least one stream or wetland crossing. It is apparent that three very important categories that often leadPage 3 to water quality concerns, roads, crossings and skid trails, sometimes lag behind other categories with regard to implementation percentage (Tables 2 and 3). The histogram (Figure 1) indicates that the vast majority of tracts scored an overall implementation percentage of 81 percent or greater. While the overall mean BMP implementation for all tracts is 87.7 percent (Table 2) and the overall harvest average score is 87.8 percent, the harvest median score is 93 percent. Given the skewed distribution of the overall scores in Figure 1, the median is perhaps a better judge of central tendency of the tract score data. These results indicate a steady level of BMP implementation statewide over recent years, and it should be understood that random sample averages fluctuate over time and small year to year changes may not indicate a real change in BMP implementation. Any real changes will become apparent over the long term as more data are accumulated. This audit report includes the expectation that all BMPs should be done per the manual regardless of likely impacts on water quality on each harvested tract. In most cases, BMPs that are not done do not directly impact water quality. These BMPs can be considered “luxury” BMPs as they are recommended by the manual but are not necessarily impacting water quality. Any BMP failures on the part of the operator that directly impact water quality are apparent in the significant risk and active sedimentation tallies as reported in Table 4 and the explanation below. These singular failures are also handled through the VDOF silvicultural water quality law enforcement process according to § 10.1-1181.2 (http://leg1. state.va.us/cgi-bin/legp504.exe?000+cod+10.1-1181.2). The definition of significant risk describes a water quality concern that is observed on an audit tract that, due to a lack of BMPs, is causing or is likely to cause pollution. When a significant risk was noted during an audit field visit, the auditor also determined if active sedimentation was occurring. Audits that indicated a significant risk were isolated and evaluated independently of all other audits. Out of the 240 tracts in this audit cycle, nine (3.75 percent) had at least one significant risk and four of those tracts (1.7 percent)had an active sedimentation concern. Table 4 summarizes the specific problems that were noted on the nine tracts. It is apparent in Table 4 that tracts that had at least one risk often had multiple risks in 2014. A second analysis including only tracts with at least one significant risk issue determined that the average “% Yes” score for those nine harvests was 69.8 percent, the median harvest score was 73.5 percent and the average harvest score was 69.8 percent, which indicates that long-term water quality problems tend to persist on tracts where overall BMP implementation is well below the average and median values for all tracts. The 107 audit tracts that were located in the Chesapeake Bay watershed were isolated and averages were calculated. The Bay harvest average score was 90.4 percent, and the tract median score was 93.6 percent while the BMP average of all the audit questions combined for all the Bay tracts was 90.4 percent. This is slightly better than the state as a whole. The Bay data also indicate that there were three significant risk issues on only two tracts, and active sedimentation was observed on one of those tracts. All observed significant risks dealt with either haul roads near a stream that lacked necessary drainage and stabilization work, or skidding. Figure 1: A histogram describing the score distribution of all 240 audits for the 2014 audit cycle in Virginia.Page 4 Table 4 indicates that operations that disturb or expose soil near to streams are more likely to cause a significant sedimentation risk if not properly stabilized. A combination of improper road drainage and unstable stream crossing approaches combine to include a large number of risks. Nearly all risks are related directly to un-stabilized, exposed soil near a waterway. Simply avoiding most operations in or near to riparian areas would likely reduce risks to water quality. Minimizing roads, decks and stream crossings would Table 4: Tally and description of significant risks to water quality and associated active sedimentation for the 2014 BMP audit cycle. BMP Issue by Region and Type RiskSediment Central Region 2 0 Roads 2 0 Are turnouts directing water and/or sediment away from riparian areas? 1 0 Is there rock or vegetation on slopes where needed to prevent erosion? 1 0 Eastern Region 3 2 Crossings 1 1 Are culvert pipes installed properly in the channel to avoid undercutting and channel erosion? 1 1

Roads 1 0 Is water diverted from the road surface at specified intervals using dips, bars or traps? 1 0 Skidding 1 1 Is vegetation established where needed on trails to prevent erosion and sedimentation? 1 1 Western Region 22 14 Crossings 12 7 Are approaches stable and unlikely to contribute sediment to the stream? 4 2 Are culverts covered with gravel to reduce erosion near the stream? 1 1 Are headwalls stabilized with vegetation, rock, or fabric to minimize cutting? 1 1 Are permanent bridge abutments adequate and stable? 1 0 Are stream banks and approaches re-claimed with sufficient vegetation, rock, or slash? 1 1 Are temporary culverts, pole bridges, and bridges removed? 1 0 Are water diversion structures present when needed on approaches? 3 2 Roads 4 2 Is there rock or vegetation on slopes where needed to prevent erosion? 1 1 Is water being “turned out” into surrounding landscape with appropriate structures? 1 0 Is water diverted from the road surface at specified intervals using dips, bars or traps? 2 1 clearly be beneficial to water quality risk reduction and would also reduce the number of BMP issues that need attention during and after the operation. Specific BMP deficiencies that almost always contribute to sedimentation issues deal specifically with a lack of drainage and stabilization of roads particularly on or near to stream crossings approaches. It is critical that operators use dips, bars and turnouts to guide water off of roads and clean gravel on slopes and approaches near waterways.Page 5 Audit Questions by Category Response Counts % Yes N/A No YesTotal Chemicals 944

– 16 960100.0 Did applicators avoid mixing chemicals or filling equipment where runoff would likely enter a stream? 236

– 4 240100.0 Did applicators remove all refuse from the tract? 236

– 4 240100.0 Did chemical applicators avoid accidental drift into sensitive areas or SMZs? 236

– 4 240100.0 Did chemical applicators avoid applying chemical directly into streams or SMZs? 236

– 4 240100.0 Crossings 3,769 81 7104,56089.8 Are approaches stable and unlikely to contribute sediment to the stream? 140 9 91 240 91.0 Are culvert pipes installed properly in the channel to avoid undercutting and channel erosion? 213 4 23 240 85.2 Are culverts and bridges of adequate length? 174 5 61 240 92.4 Are culverts covered with adequate and appropriate fill material? 211

– 29 240100.0 Are culverts covered with gravel to reduce erosion near the stream?214 4 22 240 84.6 Are culverts properly sized according to the BMP manual Tables 6 and 7 or Talbot’s formula? 213 7 20 240 74.1 Are fords used only where a natural rock base (or geoweb) and gentle approaches allow? 231

– 9 240100.0 

# Appendix A: Individual Audit Questions and Scores

Table 4: Tally and description of significant risks to water quality and associated active sedimentation for the 2014 BMP audit cycle. BMP Issue by Region and Type RiskSediment Skidding 6 5 Are all skid trails free from channelized flow that is likely to cause sedimentation? 1 1 Are water bars established on trails where erosion is likely at recommended intervals? 1 1 Are water turnouts built to ensure drainage of skid trails where needed? 1 1 Do trails avoid long, continuous grades? 1 1 Do trails avoid rutting that will likely cause channelized erosion near a stream? 1 0 Is vegetation established where needed on trails to prevent erosion and sedimentation? 1 1 Statewide Total 27 16Page 6 Audit Questions by Category Response Counts % Yes N/A No YesTotal Are headwalls stabilized with vegetation, rock or fabric to minimize cutting? 220 8 12 240 60.0 Are permanent bridge abutments adequate and stable? 232 2 6 240 75.0 Are stream banks and approaches re–claimed with sufficient vegetation, rock or slash? 146 9 85 240 90.4 Are stream crossings installed at or near to right angles where possible? 132 2 106 240 98.1 Are stream crossings minimized? 133 4 103 240 96.3 Are temporary culverts, pole bridges and bridges removed? 168 7 65 240 90.3 Are water diversion structures present when needed on approaches? 183 14 43 240 75.4 Do all ford crossings avoid restricting the natural flow of water? 231

– 9 240100.0 Do all ford crossings have a 50–foot approach of clean gravel? 232 3 5 240 62.5 Do all ford crossings have underlying geo–textile where needed (on approaches)? 236 1 3 240 75.0

Is the addition of unnatural materials in the stream to facilitate the use of a ford minimized? 232

– 8 240100.0 Were pole bridges used only in appropriate circumstances? 228 2 10 240 83.3 Decks 589 94 1,4772,16094.0 Are all decks limited in size? 3 1 236 240 99.6 Are all log decks located at least 50 feet from the nearest SMZ. 55 8 177 240 95.7 Are appropriate soil protection measures in place to prevent erosion on the deck? 17 36 187 240 83.9 Are decks reshaped where needed to ensure drainage? 130 3 107 240 97.3 Are fluid spills from equipment minimal? 9 4 227 240 98.3 Are log decks located on relatively well–drained ground with low to moderate slopes? 4

– 236 240100.0 Are sediment trapping structures present if needed to prevent pollution? 189

– 51 240100.0 Are water diversion structures installed to prevent water from crossing the deck? 179 31 30 240 49.2 Is the deck free of trash, garbage and other non–slash debris related to the harvest operation? 3 11 226 240 95.4

Fires 3,575 6 193,60076.0 Are command and staging areas located away from streams? 239

– 1 240100.0 Are large areas of bare soil re–vegetated where slope exceeded 5%? 239 1

– 240 0.0Page 7 Audit Questions by Category Response Counts % Yes N/A No YesTotal Are water bars installed properly on firelines, roads and cleared areas? 238 1 1 240 50.0 Did fire crew avoid plowing up and down slopes where possible? 238

– 2 240100.0 Did fireline construction avoid disturbing existing gullies? 238

– 2 240100.0 Did the burning crew avoid exposing large areas of mineral soil? 238

– 2 240100.0 Did the burning crew avoid pushing firelines directly into streams? 238

– 2 240100.0 Does fireline construction follow appropriate skid trail BMPs? 238 2

– 240 0.0 Does fireline construction divert water away from streams where necessary? 239

– 1 240100.0
Is all fire–related debris removed from stream channels? 239

– 1 240100.0 Is all refuse and sewage disposed of properly? 238

– 2 240100.0 Is vegetation or slash on firelines and cleared areas to prevent erosion as needed? 238 2

– 240 0.0 Were high intensity site–prep burns kept out of the SMZs? 238

– 2 240100.0 Were prescribed burns on fragile soils and steep slopes absolutely necessary to achieve goals? 239

– 1 240100.0 Were steep grades and/or fragile soils protected from excessive burn and ground disturbance? 238

– 2 240100.0
Mechanical_SP 3,354 1 5 3,36083.3 Are SMZs maintained with no significant disturbance? 239

– 1 240100.0 Did all mechanical operations avoid slopes in excess of 45%? 240

– – 240 N/A Did all mechanical operations avoid wet or fragile ground? 239

– 1 240100.0 Did all mechanical operations take place on the contour to the extent possible? 239

– 1 240100.0 Did bedding contractor avoid tying beds into streams, ditches or drainage structures? 240

– – 240 N/A
Did machine planters avoid excessive slopes? 240

– – 240 N/A Did operators prevent debris or soil in the stream sufficient to degrade banks or impede flow? 239

– 1 240100.0 Did raking, piling and windrowing avoid excessive movement or exposure of mineral soil? 239 1

– 240 0.0 Did scalping, furrowing and sub–soiling avoid connections to drainages? 240

– – 240 N/A Is scalping and furrowing less than 6 inches deep and on the contour? 240

– – 240 N/A

Is soil disturbance minimized across the site relative to establishment goals? 239

– 1 240100.0Page 8 Audit Questions by Category Response Counts % Yes N/A No YesTotal Was bedding conducted on the contour where possible? 240

– – 240 N/A Was machine planting done on the contour? 240

– – 240 N/A Was sub–soiling or ripping done on the contour? 240

– – 240 N/A Planning 224 70 426 72085.9 In the case of severe site conditions (very wet or steep) was the harvesting system modified to reduce damage to soil, site and water? 220 6 14 240 70.0

Is there evidence or knowledge of a harvest plan (painted lines, flagging, delineated hazards, SMZs or decks, engineered roads, etc...)? 3 63 174 240 73.4

Is there evidence that the logger utilized a harvesting system that is generally appropriate for the site and timber conditions? 1 1 238 240 99.6

Roads 2,7422971,5214,56083.7 Are grades between 2% and 10% except for necessary deviations? 71 5 164 240 97.0 Are new roads located and constructed to allow for proper drainage? 187 8 45 240 84.9 Are new roads located to avoid erodible, wet and sensitive ground?187 3 50 240 94.3 Are riprap and/or brush dams used where needed to slow water and trap sediment? 226 2 12 240 85.7 Are roads built outside of SMZs where possible? 119 2 119 240 98.3 Are roads daylighted where needed and feasible? 70 2 168 240 98.8 Are roads in SMZs as far from the channel as possible and built to prevent stream sedimentation? 193 2 45 240 95.7 Are roads on the contour where practical? 95 3 142 240 97.9 Are roads outsloped where needed and conditions allow? 139 21 80 240 79.2 Are temporary roads retired with properly constructed water bars or tank traps? 213 16 11 240 40.7 Are turnouts directing water and/or sediment away from riparian areas? 192 7 41 240 85.4 Are under road culverts installed, spaced and maintained properly?209 3 28 240 90.3 Is access being controlled with a functional gate or barrier? 59 70 111 240 61.3 Is construction of dips, bars, turnouts and traps adequate to maintain function? 180 14 46 240 76.7 Is gravel or vegetation present to protect water bars from erosion? 154 18 68 240 79.1 Is there rock or vegetation on slopes where needed to prevent erosion? 92 39 109 240 73.6Page 9 Audit Questions by Category Response Counts % Yes N/A No YesTotal Is water being “turned out” into surrounding landscape with appropriate structures? 145 39 56 240 58.9 Is water diverted from the road surface at specified intervals using dips, bars or traps? 147 43 50 240 53.8
Was road construction and use minimized? 64

– 176 240100.0 Skidding 1,4412601,4193,12084.5 Are all skid trails free from channelized flow that is likely to cause sedimentation? 16 15 209 240 93.3

Are all skid trails located outside the SMZ? 71 13 156 240 92.3 Are appropriate cross drainages installed where springs or seeps crossed the trails? 227 1 12 240 92.3 Are bladed skid trails limited to less than 26% grade unless absolutely necessary? 175 4 61 240 93.8 Are bladed skid trails limited to sideslopes less than 60%? 180 7 53 240 88.3 Are un–bladed trails limited to sideslopes less than 36% in general?106 2 132 240 98.5 Are water bars established on trails where erosion is likely at recommended intervals? 123 54 63 240 53.8 Are water turnouts built to ensure drainage of skid trails where needed? 151 35 54 240 60.7 Did the logger avoid skidding logs through intermittent or perennial streams? 70 4 166 240 97.6 Do trails avoid long, continuous grades? 69 20 151 240 88.3 Do trails avoid rutting that will likely cause channelized erosion near a stream? 62 10 168 240 94.4 Is vegetation established where needed on trails to prevent erosion and sedimentation? 130 54 56 240 50.9 Were brush mats used to stabilize trails and prevent erosion where needed? 61 41 138 240 77.1

SMZs 1,6971541,2693,12089.2 Are all SMZs a minimum of 50 feet wide on each side of the stream bank? 84 40 116 240 74.4
Are SMZ widths modified to accommodate cold water fisheries and municipal water supplies? 238

– 2 240100.0 Did the logger avoid exposing large sections of soil in the SMZ? 86 6 148 240 96.1 Did the logger avoid partial or patch clear cutting in the SMZ? 84 32 124 240 79.5 Did the logger avoid silvicultural debris in the stream that would warrant a law enforcement action under the "debris in the stream law?" 88

– 152 240100.0Page 10 Audit Questions by Category Response Counts % Yes N/A No YesTotal Did the logger avoid silvicultural sediment in the stream that might endanger public health, beneficial uses or aquatic life as stated in the "silvicultural water quality law?" 84 1 155 240 99.4

Do all intermittent and perennial streams have an SMZ? 88 12 140 240 92.1 Do all sinkholes or karst features have an SMZ? 240

– – 240 N/A Does at least 50% of the original basal area exist in the SMZ? 84 34 122 240 78.2 In tidal areas, has a 50–foot SMZ been maintained from the grass or marsh edge? 237

– 3 240100.0 Is SMZ width relatively consistent along the entire length? 86 20 134 240 87.0 Is the SMZ free of roads and landings where possible? 85 9 146 240 94.2 Was exposed soil in the SMZ revegetated or covered with organic materials? 213

– 27 240100.0

Wetlands 1,883 1 361,92097.3 Are landings located on appropriate ground? 234

– 6 240100.0 Did operations in wetlands avoid altering hydrology of the site to such a degree as to convert a wetland to a non wetland? 234

– 6 240100.0 Did the operation avoid activities during particularly wet weather? 234

– 6 240100.0 Is water movement maintained on the site? 234

– 6 240100.0 Was low ground pressure equipment (LGP) utilized where needed? 236 1 3 240 75.0 Was the harvesting system appropriate for the site conditions? 234

– 6 240100.0 Were the 15 mandatory road BMPs followed for wetland roads? 238

– 2 240100.0 Were the six mandatory site–prep BMPs followed as needed? 239

– 1 240100.0 Grand Total 20,2189646,89828,08087.7



## Acknowledgements Virginia Department of Forestry www.dof.virginia.gov Written by

Matt Poirot, Assistant Director of Forest Management for Water Quality William Lakel, Ph.D, Water Quality Program Supervisor Data Analysis by Lauren Whitlow, Database Analyst Design by Janet Muncy, Public Information Specialist Virginia Department of Forestry 900 Natural Resources Drive, Suite 800 Charlottesville, Virginia 22903 Phone: (434) 977-6555 www.dof.virginia.gov VDOF P00143; 03/2015 This institution is an equal opportunity provider.