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E-M:/ Forestry BMP's Audit for 1997

Enviro-Mich message from anne.woiwode@sfsierra.sierraclub.org

SUMMARY: A report on a 1997 audit of Forestry Best Management Practices
effecting water quality on a cross section of all forest ownerships has been
released.  While not statistically valid, the report points out some areas of
concern in current practices, and offers some food for thought about the
efforts to increase timber harvesting on State Forest lands in particular.


The state of Michigan, like all other states, is required to develop a
program for control of non-point source water pollution under the Clean
Water Act.  Part of that plan is development of a program for forestry
operations.  Michigan has adopted voluntary best management practices (BMPs)
for forestry operations as part of efforts to reduce non-point pollution of
waterways in the state.  Michigan's BMPs are written up in a handbook
published in 1994 called "Water Quality Management Practices on Forest Land."
Because logging, road building, stream crossing, etc. can have a potentially
devastating effect on water quality, these BMPs are to provide a baseline for
expected practices on forest lands. 

Since there are no mandatory standards in Michigan for forest practices of any
sort these provide the ONLY basis on which to judge forest practices in state,
and even these do not begin to cover the universe of forestry practice issues
that should be addressed to protect the environment.

The DNR does an annual audit of a selection of sites (not statistically valid)
where timber management has occurred on State Forests lands, National Forests
lands, industrial lands, Private lands owned by individuals, and corporate
owned lands (I don't know the difference between industrial and corporate).
Sites are selected from the database of state timber sales, and solicited from
the Forest Service, forestry consultants, soil conservation districts and
private industry. The Michigan Forestry Best Management Practices Site Audit
Program for Water Quality, 1997 Forestry BMP Site Audits Final Report was
issued earlier this month, and information about it can be obtained from Rich
Hausler, Forest Management Division, DNR, at 517-335-3351, or email at
<hauslerr@state.mi.us >.

With a number of caveats, the report makes the following broad findings.
I'll follow this with some information from the State Forest summary as well.

"The sites were evaluated for meeting BMP standards and specifications as
stated in the manual "Water Quality Management Practices on Forest Land." The
following application categories were used in rating BMP applications:

1) Practice exceeds BMP recommendations.

2) Practice meets BMP recommendations.

3) Minor Departure - Practice not clearly needed but woudl have been helpful
in preventing erosion, or practice attempted but poorly applied.

4) Major Departure - Practices clearly needed but no attempt at application,
or BMP clearly and consistently ignored.

5) Gross Neglect - BMPs and concern for water quality were blatantly
disregarded and the potential risk to water resources was significant.

"82% was the average achieved for meeting BMP specifications based on team
members rating approximately 1200 practices and 54 sites.  The Operations and
Maintenance BMP category had the highest percentage in meeting BMP standards.
Overall, O&M BMPs met standards 95% of the time.  Skidding and Skid Trails had
the lowest percentage of all forest management categories in meeting BMP
standards at 67%."  [From Executive Summary]

The biggest problem area is evidently the installation of water diversion
devices on skid trails and haul roads and culverts for stream crossings.  

Appendix C of the report is "1997 Audit Results for State Owned Lands by BMP
Application Category."  Again, the report stressed that this is not a
comprehensive review and shoudl not be considered statistically valid.  But
the report does point to some serious concerns.  Overall, compliance with BMPs
on the state lands is at 83%, slightly above the statewide average.  However,
on the weakest area, skidding practices, the percentage dropped well below the
average, to 50%.  Other areas reviewed for compliance and their percentages as
presented in the report:  Operations and Maintenance - 90%; Roads - 81%; Water
Crossings - 75%; Landings - 83%; Buffer Strips - 78%.  

Additional Analysis:

This is only the second year such an audit has been done, and in the 1996
report the compliance with BMPs was broken down into different categories of
ownership.  This created some consternation because the State Forests ranked
very low compared with other ownership categories.  One explanation for this
was that the state foresters offered up samples of bad sites, while other
categories offered up primarily good sites.  

Unfortunately, because the sampling is not random, and because as this year's
report points out the site audits are a point in time review that may not
account for problems occuring during logging or road building operations and
don't account for weather conditions just before the audit is done, the
sampling is not a good tool for judging compliance overall.  Instead, the 1997
audit report stresses its primary value as a way to assess needs for further

There is offered in an appendix to the report a summary of the site audit
information collected on State Forest lands, which I would hope is used to
adjust the state's timber management practices.  Especially with the current
debate over whether to keep or even increase the mandated timber marking
levels on State Forest lands, citizens concerned about water quality and
forest practices should take note of the information included here, which
occurred prior to the first mandated timber marking in the DNR budget. 

Since that time, DNR Forest Management Division staff numbers have been
reduced as a Wisconsin consulting firm has picked up some of the work, and the
mandated level of timber marking has gone up 6% for FY99 over the actual
amount cut in FY97 and the mandated in FY98. The FY00 is still under debate,
and it is expected that the timber industry will continue to push for a
further increase.  If not changed at all, however, the FY00 STILL will contain
the mandated level 6% above that actually cut in FY97, as reviewed in this

Sierra Club has been critical of the state in its compliance with BMPs
primarily because this is the agency with both the responsibility for largest
ownership of forest land in the state, and the responsibility to assure that
the BMPs are met by all sectors (DEQ shares the second responsibility).
Two primary areas of concern have been raised consistently: 1) assuring that
BMPs are clearly required in ALL timber sales as they are written; and 2)
doing adequate inspection and monitoring of those doing timber management to
assure that compliance is occuring.  

In the first case, a more consistent form for bids that clearly has a
requirement for all sales to "meet or exceed" the state's BMPs would be a
start, and ideally a penalty for failure to comply should be built in.  

In the second case, the state has failed to commit adequate numbers of staff
to the field to assure that compliance occurs and that followup and monitoring
of the sales is provided. As the state Legislature and the Governor are
MANDATING more timber marking, thus more cutting, and reducing the number of
actual DNR staff, preferring to use contractors instead, the situation will
only deteriorate, and in this case it is well beyond the capacity of the DNR
Forest Management Division to react. 

While not a statistically valid review, I hope that these figures help to
demonstrate that the numbers game of reducing staff in the DNR while the
timber industry pushes legislators to arbitrarily increase cutting means that
our precious state resources are being adversely effected.  This is a major
concern, not just for tree huggers but for anyone concerned about the quality
of Michigan's waters and habitat, etc.

Anne Woiwode

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