The Ohio Forestry Association by AAjwoYgM


									                                Ohio Forestry Association, Inc.
                                           1100-H Brandywine Blvd., Zanesville, OH 43701
                                   PH: 614-497-9580 Fax: 614-497-9581 Toll Free: (888) 38-TREES
Executive Committee                               E-mail:
Mark Cantwell                              
Ryan Redoutey
1st Vice President
Rob McCarthy
2nd Vice President
Apple Creek
Ed Robbins            Water Docket                                            September 4, 2012
3rd Vice President    Environmental Protection Agency
Piketon               Mail Code 2822T
Jim Bishop
Past President        1200 Pennsylvania Avenue, NW
New Philadelphia      Washington, DC 20460
David Bergman
Treasurer             Attention Docket ID No. EPA-HQ-2012-0195
John E. Dorka         To whom it may concern:
Executive Director
Columbus              The Ohio Forestry Association, Inc. (OFA) is an Ohio trade association representing the
Board of Trustees
                      forest products industry in the state. OFA administers the Master Logging Company
Randy Bates           program, a voluntary certification for logging companies. One of the key goals of this
Cambridge             program is to promote sounds forestry BMPs and logging road practices that reduce soil
Rudy Brandt           erosion and maintain water quality. OFA has been a key partner in carrying out Ohio’s
Haydenville           Silvicultural Non-point Source Pollution Program since it was first developed more than 20
Tom Brown             years ago.
Adam Conway           OFA believes that current programs which promote voluntary mechanisms to control soil
Jim Elze
                      erosion on logging roads and harvest operations have been extremely effective. Although
Salem                 tens of thousand of acres of Ohio forests are harvested each year, silvicultural activities do
Peter Gayer           not rate as a source of stream impairment. The current program is working.
Mark Hochstetler       We support EPA’s proposal to modify 40 CFR 122.26 in order to clarify that, where logging
Millersburg           roads provide access to silvicultural activities, they do not constitute “immediate access” to
Jeff Hoselton         an industrial activity. This is consistent with past EPA decisions exempting silvicultural
                      activities from the requirements of a National Pollutant Discharge Elimination System
Clint Manns
                      (NPDES) permit.
Gailen Maxwell
Lancaster             We believe that the Ninth Circuit Court’s decision in NEDC vs. Brown which requires a
Dr. Eric McConnell    NPDES permit for logging roads is wrong and would have created an unnecessary cost
Columbus              burden for private and public forest landowners. Given that forestry best management
Ervin Raber           practices are widely used and that water quality from forested landscapes is already
Brinkhaven            consistently higher than other land uses these additional costs are not defensible from any
Cassie Ridenour       standpoint.
Shawn Sexton
Jackson               We understand that EPA is attempting to determine how to treat the broader category of
Norman Shetler        “forest roads” and “logging roads” under the Clean Water Act Section 402(p)(6). It will be
Mount Eaton           difficult to define a forest road under multiple jurisdictions and physical conditions. We are
Richard Sorg          interested in the results of this review and will offer input as necessary.
Mt. Perry
James Stafford                                                                Sincerely,
Larry Strickland
Oak Hill
Stanley Swierz
Columbus                                                                      John Dorka
Bob Thompson                                                                  Executive Director
Nelson Troyer
Apple Creek

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