Are Best Management Practices (BMP's)For Forestry Being Used Properly?

By James Holland, Altamaha Riverkeeper

1. Permanent roads, temporary roads, and skid trails (all for forestry) in waters of the U.S. shall be held to the minimum feasible number, width, and total length consistent with the purpose of specific silvicultural operations, and local topographic and climatic conditions;

3. The road fill shall be bridged, culverted or otherwise designed to prevent the restriction of expected flood flows;
4. The fill shall be properly stabilized and maintained during and following construction to prevent erosion;

7. The design, construction and maintenance of the road crossing shall not disrupt the migration or other movement of those species of aquatic life inhabiting the water body;

15. 15: All temporary fills shall be removed in their entirety and the area restored to its original elevation.
NOTE: ARK is of the opinion that none of the 15 CWA mandated provisions for forestry are either voluntary or subjective. Each of the 15 CWA mandated provisions for forestry clearly state "shall be or shall not be."

Georgia took these guidelines even further than the U.S. Congress by creating the Best Management Practices (BMP's) Manual for harvesting timber in Georgia. There is neither time nor space in this article to cover the entire BMP Manual for Harvesting Timber in Georgia so I will only high light the ones in which I have received the most numerous BMT complaints and what I believe they mean.

First, let's look at the CWA mandated provisions for harvesting timber in Georgia listed in this article.

1. This CWA mandated provision clearly notes skidder trails as a type of road that should be regulated. Skidder trails should only cross water bodies at temporary road crossings. Skidder trails should never run down the middle of a body of water. Skidder trails should never leave deep ruts on the landscape. Deep ruts can alter the characteristic and or the hydrological flow regimes of a body of water and may be a conduit for sediment to enter a water body.

3. This CWA mandated provision simply means; do not do anything that will interfere with the water passing through the road crossing.
4. This CWA mandated provision simply means that just like any other entity or developer, timber harvesters must employ erosion and sedimentation (E&S) control measures to insure that sediment doesn't enter the water body from a road or road crossing the water body.

7. This CWA mandated provision means you can't do anything with the road crossing that interferes with the flow of water or the movement of fish or any other aquatic species that may use the water body.

15. This CWA mandated provision means: If during the logging operation the banks of a water body are damaged when the harvest is complete the harvester must restore the banks to their original elevation before leaving the site.

State BMP's

Not only are timber harvesters exempt from the Federally Mandated BMP provisions, they are also exempt from the Georgia Erosion and Sedimentation Act (E&S) Permitting process. However, this does not mean that timber harvesters are exempt from the Act itself. No entity in the State of Georgia is exempt from the E&S Act or the State Water Quality Control Act (SWQCA). Timber harvesters are only exempt from the permitting process. For instance, if a timber harvester committed a water quality violation and did not use the necessary E&S controls, from that point on they are just like any other developer. If a developer installs the necessary and proper erosion controls and something goes wrong causing a water quality violation, the developer has a defense. If the developer does not install proper E&S controls legally he can't use the E&S controls as a defense. In other words, in most cases, he would not have a defense and would be found guilty of a water quality violation.

Timber harvesting companies must either use E&S controls or be subject to the law, but unlike developers, they don't have to go through the permitting process.

BMP's were designed to be a common sense method to use for water quality protection. Listed below are some of the most often found and common complaints about State BMP's for harvesting timber in Georgia.

1. Stream Management Zones (SMZ's) or better known to most as stream buffers. Streams listed as requiring SMZ's are; Intermittent, perennial, or ephemeral streams. Also included are springs, seeps, sloughs and some lakes. Timber harvesters are allowed to harvest trees inside the SMZ's as long as they follow BMP's (don't create deep ruts, remove stream bank trees or leave tree tops in streams). Harvesters are not supposed to remove the under story inside the SMZ's.
1. Intermittent streams or some times referred to as wet weather streams (branches). A minimum SMZ of 20 feet as measured outwards from the stream bank are required. Inside this minimum SMZ the timber harvester must leave a minimum of 25% canopy or 25 square feet of basal area per acre to provide shade. This remaining 25% canopy or 25% basal feet per acre must be evenly distributed throughout the zone.
2. Perennial streams normally hold water most of the year, however, may dry up during droughts or due to upstream usage. Perennial streams are required to have a minimum 40-foot SMZ as measured from the stream bank outward. Perennial streams after harvesting must have a minimum of 50% canopy cover for shade or 50 basal feet per square acre evenly distributed throughout the zone.
3. Ephemeral streams are commonly referred to as drains, draws, or dry washes. Ephemeral streams are to be treated as intermittent streams during the timber harvest. Leave a minimum 20-foot SMZ as measured from the stream bank outwards. There must also be 25 feet of canopy or 25 feet of basal area per square acre to provide shade evenly distributed throughout the zone.
4. Springs and seeps, treat as perennial streams if they flow all year long or intermittent otherwise.
Does it make common sense to violate any of the above BMP's. When installing forestry roads the companies are required to design and maintain these roads to prevent sediment from entering water bodies during rain events. Generally, when installing a forest road that has a downward gradient the companies install road turn outs to slow the storm water run off and direct sediment into upland areas.

Practices to avoid

The BMP Manual for Harvesting Timber in Georgia states under practices to avoid: Tying road turnouts into streams. This means do not create a road turn out and direct the storm water run off into a water body. Even though the BMP Manual is very clear about avoiding this practice, I still continue to see road turn outs directed into water bodies on some forestry sites. Road turnouts can cause pollutants to enter water bodies for an indefinite period of time and be a constant source of sediment and erosion. Does it make sense to violate the road turn out BMP? NOTE: Road turn outs into streams and other water bodies are a constant on going practice with some county public works crews when scraping dirt roads and must be stopped, as well

Another chapter in the BMP Manual for harvesting timber in Georgia also lists another practice to avoid. This practice to avoid states that timber harvesters should avoid cutting stream bank trees. This practice is one of the most commonly violated BMP's in the manual for harvesting timber in Georgia. Does it make sense to remove the shading from a body of water? One of the main concerns and reasons for BMP's is to protect the water quality against the danger of thermal pollution. It is not possible to have a proper Streamside Management Zone (SMZ) if you take trees from within the banks of a water body. The SMZ provides vegetation, a habitat for wildlife, and flood protection by dissipating the velocity of moving water.

The BMP Manual for harvesting timber in Georgia only requires a minimal buffer (SMZ) along streams where the trees have been harvested. It is an even worse practice to remove trees from inside a water body.

BMP's for harvesting forested wetlands.

There are a number of BMP's for harvesting trees in forested wetlands. I have listed below a couple of the more critical BMP's that are the most often violated.

1. Use site-specific equipment and methods to minimize water quality impacts, including high-flotation, low pressure harvesting equipment, shovel logging, or cable yarding.



2. Concentrate skid trails and use logging slash, mats, or other techniques to minimize soil compaction and rutting.
The most common occurrences I observe in forested wetlands is rutting from the use of improper harvesting equipment. I do not believe that vehicles with tracks (instead of tires) are designed to be low impact equipment. Yet, tracked vehicles are some of the most commonly used equipment in these forested wetlands.

Deep ruts in and near water bodies can alter the characteristics and hydrology of the system. Ruts can cause additional sedimentation that can interfere with waterfowl and fish spawning habitat. Continued in: Are Best Management Practices (BMPs) For Forestry Being Enforced in Georgia.