NCASI comments on effectiveness of forest road practices

NCASI recently submitted comments in response to the US Environmental Protection Agency’s “Notice of Intent to Revise Stormwater Regulations to Specify that an NPDES Permit is not Required for Stormwater Discharges from Logging Roads and to Seek Comments on Approaches for Addressing Water Quality Impacts from Forest Road Discharges” (Federal Register May 23, 2012, pp. 30473-30481). In that NOI, the EPA announced its intention to propose revisions to the Phase I stormwater regulations to specify that stormwater discharges from logging roads are not associated with “industrial activity.” The agency also solicited comments on approaches for addressing water quality impacts associated with discharges of stormwater from forest roads.

The NCASI comments focus on the following key points.

  • State BMP programs for forestry can be considered one of the success stories of the Clean Water Act, as all states with significant commercial forest operations have adopted a set of BMPs.
  • States have used diverse and effective approaches to address their unique physiological, ecological, and sociological conditions and to avoid a costly and disruptive permit program. BMPs throughout North America are based on a common set of science-based principles, and variation among jurisdictions in BMPs and approaches to their implementation are attributable to efforts by states and provinces to apply general principles to their own circumstances.
  • Determining appropriate BMPs often requires the flexibility to address site-specific conditions.
  • A large and growing body of research demonstrates the effectiveness of forestry BMPs in protecting water quality and aquatic habitats.
  • Forest road practices have evolved over time and current research findings are the most relevant when evaluating BMP effectiveness, although legacy road conditions must still be addressed.
  • Legacy road conditions are most effectively addressed as part of ongoing commercial forestry operations, and there is strong evidence that these upgrades are occurring as part of active forest management.
  • In a recent NCASI analysis, forest road erosion model estimates were not accurate when compared to field measurements, reflecting the site- and region-specific factors that influence erosion and the need for field assessments to identify problem road segments.
  • Information in the EPA’s Assessment, TMDL Tracking and ImplementatioN System (ATTAINS) database on impaired waterbodies reflects a reduction in the relative contribution of silvicultural activities over time, although states identify and report impairment sources differently creating difficulties in evaluating trends among potential sources.
  • Two major challenges for EPA and the forestry community in the future will be (1) adopting water quality standards that recognize the disturbance patterns that are essential to maintaining forest watershed functions; and (2) distinguishing between changes that are statistically significant versus environmentally significant.

For a copy of the NCASI comments, please contact Dr. Erik Schilling or Dr. Bob Danehy.

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