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					    2004 Field Audit Report
Wyoming Forestry Best Management Practices
  Forest Stewardship Guidelines for Water Quality




                                              Photo courtesy of USDA Forest Service




                Wyoming Timber Industry Association
                PO Box 6088 • Sheridan, WY 82801
                         (605) 341-0875

           Wyoming Department of Environmental Quality
      122 West 25th St, Herschler Building • Cheyenne, WY 82002
                            (307) 777-7937

                  Wyoming State Forestry Division
            1100 W. 22nd Street • Cheyenne, WY 82002
                                        (307) 777-7586


                                      Executive Summary
Best Management Practices (BMPs) for the protection of water quality during forestry and
silvicultural activities have been established by the State of Wyoming and US Environmental
Protection Agency for some time. The forest products industry, in partnership with state
agencies, has offered training opportunities for foresters and logging professionals in the
application of BMPs.

The Wyoming Timber Industry Association (WTIA) sought a grant from the Wyoming
Department of Environmental Quality (DEQ) under Section 319 of the Clean Water Act to
conduct field audits of timber sale compliance with BMPs in 2000 and 2001. Training was
also conducted at that time. The system of training and audits is an effort to self-monitor the
implementation of water quality protection measures on timber sales across private, state, and
federal land ownerships. Common mistakes in BMP application, as identified in the audit
results, are to be fed back into subsequent training sessions in a system designed for continuous
improvement.

Field audits were again conducted in 2004, under a similar grant arrangement between WTIA,
DEQ, and the Wyoming State Forestry Division. A diverse team of private- and public-sector
professionals with expertise in scientific and land management disciplines conducted the
audits. Six timber sales were examined for BMP compliance; two each from private, state, and
federal land. Forty-two separate practices were examined at each site, and each practice was
rated on the basis of both application and effectiveness.

The audit results show that the BMP standard for application was met or exceeded on 97
percent of the total rated items. Ratings for BMP effectiveness confirmed adequate protection
of soil and water resources or improved protection from pre-project conditions on 95 percent of
the total rated items. No instances of gross neglect or major departures from the BMPs were
found, and neither were any instances found where major or prolonged impacts to soil and
water resources were incurred. Timber sales on federal land scored highest among the various
ownerships for BMP application, while those on private land scored highest for effectiveness.
These results compare favorably to 91 and 93 percent average ratings for application and
effectiveness, respectively, from the 2000/2001 audits.

The most common mistakes in BMP application pertained to proper culvert sizing and
installation, construction and maintenance of road surface drainage structures, and installing
erosion control measures prior to seasonal runoff.

A vast majority of the BMPs were applied without fail across all timber sales examined. Some
of these included incorporating BMPs into timber management plans, ensuring minimum site
disturbance from logging equipment, the protection of stream banks and channels, the
identification and avoidance of wetland areas, and the use of special operating restrictions
where necessary to avoid soil damage.

The audit team recommends continuing this system of audits and training, updating the BMP
Handbook, revising the audit rating guide, and working to broaden awareness about BMPs
beyond foresters, loggers, and land managers.
                                   Acknowledgements
This report presents the findings of an ongoing program of training and field audits for
water quality protection guidelines during forestry and silvicultural operations. The
program is the product of a grant partnership between the Wyoming Timber Industry
Association (WTIA), the Wyoming Department of Environmental Quality (DEQ), and
the Wyoming State Forestry Division. Special thanks are owed to Chuck Harnish of
DEQ and Jim Arnold of State Forestry for their help and support.

A greater collaborative effort among professionals and volunteers is necessary to make
this program a continuing success. Specifically, individuals were willing to lend their
time to an interdisciplinary team encompassing the fisheries biology, hydrology, soils,
geology, forestry, engineering, and logging professions in order to complete the field
audit portion of the program. In addition, these and other individuals were gracious
enough to serve on a steering committee charged with helping to guide various aspects of
the audits and training sessions. Many thanks are owed to the following people for their
generous contribution of time and expertise:

Steering Committee and Audit Team Members
       Cindy Allen                Bureau of Land Management
       Jim Arnold                 Wyoming State Forestry Division
       Greg Becker                USDA Natural Resources Conservation Service
       Mark Conrad                Wyoming Department of Environmental Quality
       Aaron Everett              Wyoming Timber Industry Association
       Cheryl Grapes              USDA Natural Resources Conservation Service
       Keith Harding              Wyoming Sawmills
       Chuck Harnish              Wyoming Department of Environmental Quality
       Bob McDowell               Wyoming Game and Fish
       Jim Myers                  USDA Forest Service
       Buck Peterson              Wyoming Sawmills
       Howard Pickerd             Wyoming State Forestry Division
       Dr. Thomas Thurow          University of Wyoming
       Don Whyde                  Bureau of Land Management
       Dr. Stephen Williams       University of Wyoming




                                           -1-
                                       Introduction
Wyoming’s forests are integral to the quality of life for the residents of the state. They
afford a variety of environmental benefits, including wildlife habitat, clean air, and clean
water. Clean water is of particular significance because surface water from forested
watersheds is relied upon as a domestic supply source by 35 percent of Wyoming’s
residents. As such, it is appropriate for managers and owners of forested lands to take
steps insuring the protection of hydrologic resources for the benefit of all.

Forestry and silvicultural activities are classified as potential sources of nonpoint
pollution by the US Environmental Protection Agency (EPA). The EPA defines nonpoint
source pollution as follows:

 “Nonpoint source (NPS) pollution, unlike pollution from industrial and sewage
 treatment plants, comes from many diffuse sources. NPS pollution is caused by
 rainfall or snowmelt moving over and through the ground. As the runoff moves, it
 picks up and carries away natural and human-made pollutants, finally depositing
 them into lakes, rivers, wetlands, coastal waters, and even our underground sources
 of drinking water.” (www.epa.gov, 2003)

An example of nonpoint source pollution from forestry activities might be an improperly
maintained road whose drainage system has failed, permitting sediment to be washed into
a stream or waterway during runoff. However, these forms of potential pollution are
preventable if sound forestry and logging practices are implemented.

The Wyoming Best Management Practices (BMPs) for forestry and silviculture were
developed to establish a set of water quality protection measures and guidelines to guard
against nonpoint source pollution. The BMPs include guidance on a wide array of
forestry activities, such as road construction and maintenance, stream crossings, harvest
and logging design, and streamside management zones. BMP standards were developed
in a cooperative effort between the Wyoming Department of Environmental Quality
(DEQ), the Wyoming State Forestry Division, and the EPA, and were adapted from
Montana and Idaho BMPs. The adapted BMPs may be found in the publication
Wyoming Forestry BMP’s; Forest Stewardship Guidelines for Water Quality, which is
available to the public from DEQ and State Forestry offices.

Compliance with the BMPs is voluntary. That is, landowners and forest managers are not
compelled by law or regulation to implement BMPs. However, the industries and
agencies involved with forest management in Wyoming have committed themselves to
sustainable forest management, including full BMP implementation.

Training to familiarize foresters and logging contractors with the BMPs was conducted in
2000, and audits of BMP compliance on timber sales were conducted in 2000 and 2001.
These activities were funded through a grant from the Wyoming DEQ under the Clean
Water Act, Section 319. The grant was administered by the Wyoming Timber Industry
Association, a trade association of forest products companies throughout the state.




                                           -2-
The 2000-2001 audits examined twelve timber sales on state, federal, and private land.
The results demonstrated favorable levels of BMP compliance, as well as documenting
the effectiveness of Wyoming BMPs at accomplishing their intended protection of water
quality. BMP compliance was evaluated on the basis of two criteria for each practice:
Application, and effectiveness. The application rating indicated the degree of compliance
with suggested BMP methodology, and the effectiveness rating established whether the
practice, as applied, was sufficient to achieve the intended protection of water resources.

An interdisciplinary team conducted the audits, including professionals in the fields of
forestry, hydrology, fisheries, soils, geology, and engineering from state, federal, and
private sectors. Each audit rated 42 separate practices, for both their application and
effectiveness, on key portions of each timber sale. Auditing each specific practice
facilitates the identification of common mistakes or areas of confusion. These items were
subsequently fed back into subsequent training for foresters and logging contractors in a
system designed for continuous improvement.

In keeping with the goal of continuous improvement, and on the recommendation of the
2000 audit and steering committees, audits and training were again planned through a
DEQ/EPA grant administered by WTIA. Audits of timber sale BMP compliance were
conducted in the summer of 2004, and further training is scheduled for the spring of
2005. This report details the findings of the 2004 timber sale BMP audits.


2004 Audit Objectives
Foremost, the objective of these audits was to continue a system of self-evaluation and
continuous improvement in the forestry and logging professions’ practice of water quality
protection measures. Establishing a statistically significant representative sample of
timber sales in the state, or conducting exhaustive reviews on each acre of each timber
sale, it should be noted, are not objectives to which the audits aspire. Rather, a focused
assessment of BMP application and effectiveness on key timber sales and sale areas was
desired for the purposes of continued coarse-scale monitoring and evaluation.
Specifically, objectives for the 2004 BMP audits included:

   1. Monitor the effects of silvicultural activities on soil and water quality, and
      compare the results against baseline conditions established in the 2000-2001
      audits.

   2. Continue monitoring the avoidance and protection of wetland soil and water
      resources during harvest and road construction.

   3. Continue monitoring road building effects (temporary/permanent roads/trails) on
      riparian areas under the BMP strategy of minimizing the overall number of
      roads/trails and emphasizing the construction of erosion control measures.

   4. Continue monitoring the level of education within the forestry and logging fields
      for handling and storage of hazardous substances and spill contingency planning.



                                           -3-
   5. Continue evaluating the level of timber harvest planning and design needed to
      maintain or improve the hydrographic character of timberlands, protect soils from
      erosion and streams from sedimentation during runoff periods.

   6. Continue evaluating the protection of streamside management zones (SMZs)
      under the BMPs.

   7. Expand the breadth of audited sales to include not only completed timber sales,
      but also those still ongoing.

   8. Monitor the effectiveness of voluntary audits in promoting BMP compliance.


                                        Audit Process
Site Selection
Sites were selected by the steering committee and audit team from a pool of timber sales
on state, federal, and private forestland. Baseline criteria were used to select among the
timber sales in the pool to ensure the audits were focused upon timber sales with the
greatest potential to affect water quality, as well as offering an equal representation of
state, federal, and private forestland. Baseline criteria included:

   1. Select a variety of timber sales completed within the last two years.
   2. Timber sale must have harvested a minimum of 1000 Board-Feet/acre.
   3. Timber sale area must include live water crossings, riparian areas, perennially or
      ephemerally saturated soils, federally designated wetlands, or other important
      hydrologic features or resources.

These criteria were designed to eliminate from consideration timber sales having little
potential to affect water quality. Also, the 2000-2001 audits determined that certain
BMPs were not observable during the post-harvest stage in which the audits took place.
That is, some BMPs apply only to the pre-harvest or ongoing harvest stages and therefore
could not be assessed. In this iteration of audits, sales at varying stages of completion
were selected to represent the range of applicable BMPs. The minimum 1000 board-feet
per acre harvested requirement ensured against the selection of sales with only marginal
potential to affect water quality. Finally, a great number of the timber sales in the state
take place in areas where little or no live water or other sensitive hydrologic resources are
present. While many BMPs are applicable to such timber sales, the audits focused on
sales with real potential to affect water quality. This selection against sales without
major water quality concerns does create bias in the results, because it means audits took
place upon sales with a greater likelihood of including departures from the BMPs.

In all, six timber sales were selected from several distinct geographic areas of the state.
Two audited timber sales were administered by the USDA Forest Service, two by the
Wyoming State Forestry Division, and two on private land. Figure 1 displays the general
location of the audited timber sales.



                                            -4-
  Figure 1. 2004 Wyoming Forestry BMP Field Audit Sites.

Overview of Selected Sites
• The West Goosberry timber sale was administered by the USDA Forest Service on
   the Shoshone National Forest. The sale was located as the intersections of sections 1,
   2, 11 and 12 (T46N, R102W) in Hot Springs County.
• The Joe’s Park timber sale was administered by the USDA Forest Service on the
   Medicine Bow National Forest. ...
• The Damfino timber sale was administered by the Wyoming State Forestry Division.
   The sale was located on a state section just North of the Colorado Border west of
   Blackhall Mountain in the Encampment River Watershed. The sale was located in
   section 16 (T12N, R83W) in Carbon Country.
• The Camino timber sale was administered on private land by Wyoming Sawmills.
   The sale was located south and west of Dullknife Reservoir in Section 21 (T47N,
   R85W) in Johnson Country.
• The Delapp timber sale was administered on private land by Wyoming Sawmills.
   The sale bordered to the north by the North Fork of the Powder River in Section 25
   (T47N, R85W) in Johnson County.
• The Story Fish Hatchery timber sale was administered on state land by the Wyoming
   State Forestry Division. The sale is located in the town of Story on the Fish Hatchery
   site in Section 13 (T53N, R84W) in Sheridan County, and is bordered by the Bighorn
   National Forest.

Audit Procedure
The field audits were conducted over the course of one week, with the audit team
spending approximately one-half day on each timber sale. Upon arriving at a given sale
area, the team received a briefing from personnel directly associated with its preparation


                                             -5-
and administration. Areas of interest, such as a timber sale unit or road directly
proximate to a riparian corridor, were identified for each sale and each member of the
audit team performed their own inspection of these areas. No effort was made to inspect
each acre of harvest area or each mile of road; rather, the audit focused upon the critical
portions of the timber sale, where proper BMP application was most important.

After independently inspecting these areas, the audit team reconvened to rate the timber
sale’s compliance with the BMPs according to their observations. Consensus was
reached among the group on an appropriate application and effectiveness rating for each
of the 42 BMP items in the rating guide (Appendix A).

The rating process conducted for each BMP begins with establishing whether or not the
BMP in question is applicable to the harvest activities under consideration (Figure 2).
For example, there are several BMPs pertaining to the construction of temporary roads,
but some timber sales are able to use the existing roads system to harvest the area and
therefore do not require the construction of temporary roads. In such an instance, the
BMPs pertaining to temporary roads would have been rated as not applicable by the audit
team. A related example is that, within a large timber sale area, the audit team may not
have been able to see first-hand the application of each BMP. For instance, a timber sale
may have contained temporary roads, but the audit team was not able to inspect them. In
this instance, as well, the BMPs related to temporary roads would have been rated not
applicable.




Figure 2. BMP Field Audit Rating Process


                                            -6-
Once the audit team establishes that a given BMP is applicable, an application rating for
the BMP is established. Table 1 displays the rating criteria for BMP application.

           Table 1. BMP Application Ratings and Criteria
              Rating    Criteria
                5       Operation exceeds requirements of the BMP.
                4       Operation meets the standard requirement of the BMP.
                3       Minor departure from the BMP.
                2       Major departure from the BMP.
                1       Gross neglect of the BMP.

Upon completing the application ratings (Figure 2), the audit team proceeds to evaluate
the effectiveness of the BMP as-applied. This way, the BMPs themselves can be
assessed as to whether or not they afford the desired protection of water quality, and one
can differentiate ineffectiveness due to improper application. Table 2 displays the rating
criteria for BMP effectiveness.

    Table 2. BMP Effectiveness Ratings and Criteria
      Rating        Criteria
        5           Improves protection of soil and water resources over pre-project
                    conditions.
          4         Adequate protection of soil and water resources.
          3         Minor and temporary impacts to soil and water resources.
          2         Major and temporary or minor and prolonged impacts to soil &
                    water resources.
          1         Major and prolonged impacts to soil and water resources.

                         Definition of Effectiveness Terms
    Adequate:  Small amounts of material eroded, but does not reach draws,
               channels, or floodplain.
    Minor:     Some material erodes and is delivered to draws, but not to a stream.
    Major:     Material erodes and is delivered to stream or annual floodplain.
    Temporary: Impacts lasting less than one season.
    Prolonged: Impacts lasting more than one year.

Limitations of the Audit Process
As previously explained, practicality, time, and resources prohibit evaluation of each
timber sale from initiation to completion for compliance with BMPs. The audit process
is designed instead to represent something of a ‘spot check.’ This ‘spot check’ is limited
to areas of the timber sale identified as having the greatest potential to affect water
quality. There is also a limitation to the timing of the audit in the life of the timber sale,
in that the audits cannot simultaneously monitor the pre-sale, ongoing, and post-sale
activities to which BMPs apply. The 2000-2001 audit team noted that BMPs relating to
time could not be fairly judged. For example, sites where grass seed mixtures had been
applied, but had not yet germinated.




                                                -7-
                                   Field Audit Results
 Tables 3 and 4 describe the application and effectiveness scores recorded in the 2004
 field audits for each land ownership category. The data in these tables represent the
 occurrence of each rating, and its percentage relative to the total number of items for
 which a rating was recorded (rated items). Not rated or not applicable items are excluded
 from the total. Figures 3 and 4 express the occurrence of individual application and
 effectiveness ratings as a percent of the total rated points compiled across all land
 ownership categories.

 In application scoring, the 2004 audits show timber sale operators to have met or
 exceeded the BMPs on 187 of 194 (97 percent) of the total rated items across all land
 ownership categories. No instances of gross neglect or major departures from the BMPs
 were recorded on any timber sale. Minor departures from the BMPs occurred on 7 of 194
 rated items (4 percent) across all ownership boundaries.

 Table 3. 2004 Wyoming Forestry BMP Field Audit Application Results.
 Ownership        Gross         Major          Minor         Met BMP Exceeded           Total
 Category         Neglect      Departure      Departure      Standard  BMP              Rated
 Private             0             0              4              72      1
                                                                                            77
 (percent)         (0%)          (0%)           (5%)           (94%)   (1%)
 State               0             0              2              60      5
                                                                                            67
 (percent)         (0%)          (0%)           (3%)           (90%)   (7%)
 Federal             0             0              1              48      1
                                                                                            50
 (percent)         (0%)          (0%)           (2%)           (96%)   (2%)
 Total               0             0              7             180      7                  194


Table 4. 2004 Wyoming Forestry BMP Field Audit Effectiveness Results.
                            Minor/Prolonged                                    Improves
              Major &                               Minor &
Ownership                          or                             Adequate       Pre-        Total
              Prolonged                            Temporary
Category                    Major/Temporary                       Protection    project      Rated
               Impacts                              Impacts
                                Impacts                                        Conditions
Private            0                  0                 4             72           1
                                                                                                  77
(percent)        (0%)               (0%)              (5%)          (94%)        (1%)
State              0                  0                 4             60           3
                                                                                                  67
(percent)        (0%)               (0%)              (6%)          (90%)        (4%)
Federal            0                  0                 3             46           1
                                                                                                  50
(percent)        (0%)               (0%)              (6%)          (92%)        (2%)
Total              0                  0                11            178           5             194

 In effectiveness scoring, the 2004 audits recorded adequate or improved protection on
 182 of the 194 rated items (95 percent) of the total rated items across all land ownership
 categories. No instances of major and prolonged, minor and prolonged, or major and
 temporary impacts were recorded on any timber sale. Minor and temporary impacts
 accounted for 11 of 194 (6 percent) of the total rated items across all land ownership
 categories.



                                                -8-
Federal timber sales scored highest among the various ownership categories in
application, having met or exceeded the BMPs in 98 percent of the total rated items.
Private timber sales scored highest among ownership categories in effectiveness,
affording adequate or improved protection across 95 percent of the total rated items.
State timber sales showed the highest percentage of practices exceeding the BMPs in
application and effectiveness, while all ownership categories were observed to have
exceeded the BMPs in a number of instances. With the exception of private sales,
application scores were slightly higher than effectiveness scores (see Discussion section).

                              Gross Neglect                  Major Departure
                                   0%                              0%
          Exceeds BMP                                                    Minor Departure
              4%                                                               4%




                                                                                     Meets BMP
                                                                                        93%


    Figure 3. 2004 Wyoming Forestry BMP Application Audit Results.


                                  Major/Temporary or
                                   Minor/Prolonged
                                                              Major & Prolonged
                                        Impacts
                                                                   Impacts
               Improves Pre-              0%
                                                                     0%
             project conditions                                                   Minor & Temporary
                     3%                                                                Impacts
                                                                                          6%




                                                                                  Adequate Protection
                                                                                        92%



    Figure 4. 2004 Wyoming Forestry BMP Effectiveness Audit Results.



                                                       -9-
                                       Discussion
When compared with the 2000/2001 audit results, the 2004 audits show marked progress
in both application and effectiveness scoring. The 2000/2001 results showed 91 and 93
percent accomplishment for application and effectiveness, respectively. The incidence of
minor departures in BMP application is down as well, from eight percent in 2000/2001 to
four percent in 2004. Incidence of minor and temporary impacts with respect to BMP
effectiveness decreased marginally, from seven percent in 2000/2001 to six percent in
2004. Incidence of major departures or gross neglect of the BMPs changed little between
2000/2001 and 2004; only one major departure was recorded in 2000/2001, and no
instance of gross neglect or major impacts.

The 2004 audits observed application scores that were slightly higher than effectiveness
scores. The reverse was true in the 2000/2001 results. This is largely due to a higher
incidence of minor and temporary impacts in effectiveness scoring relative to the number
of minor departures in application scoring. In two instances, this discrepancy was the
result of log landings having been located in relatively close proximity to an SMZ. While
no practice was really violated, and care was taken in both instances, some soil
movement was evident and was delivered to an annual floodplain. Therefore, while the
application score was not deducted, the existence of discernible effects merited an
effectiveness score deduction. In other instances, the lower effectiveness score was due
having applied vegetative ground cover seed, but not having germinated within the time
period recommended by the BMPs for ground cover establishment.

Several audit items are notable as having been common areas of confusion or mistakes in
BMP application and should be emphasized in future training (Appendix A). In some
instances, culverts were installed improperly or were under-sized and inadequate to
accommodate flood water volumes. Erosion control measures on road surfaces were not
always in place prior to seasonal precipitation or runoff. Road surface drainage structures
were in some cases constructed improperly, were spaced too far apart, or were not
maintained sufficiently. As previously mentioned, the location of log landings in relative
proximity to live streams or SMZs was the source of some departures as well.
Designation of an adequate SMZ was only problematic in one instance, but did not cause
adverse impacts. These items were common problems in the 2000/2001 audits as well,
and will be the focal in the 2005 training sessions.

Many audit items were properly applied and effective, some regularly exceeding the
BMPs, with consistency across all timber sales examined (Appendix A). The
incorporation of BMPs in the planning of timber harvest exceeded the standards in many
instances. BMPs were also successfully applied and effective with respect to using a
suitable system of logging equipment given topographic, soil type, and season of
operation concerns. Wetlands analysis and evaluation, where applicable, was performed
without exception. Operators were successful in minimizing the ground disturbance, soil
compaction, rutting, and sediment production from logging equipment operation.
Limiting the number of roads used, including using existing roads to minimize new
construction, was successfully accomplished in all instances as well. Temporary roads
were drained and blocked, the natural drainage was restored, and physical practices or



                                          - 10 -
vegetative cover was used to stabilize any exposed soil.         Recognition of special
operating limitations, such as the need for winter logging, was well performed. Stream
channels and banks were protected in all instances. While culvert installation was
problematic in some instances, culverts maintenance was observed to be adequate in all
audited sales.


                                    Recommendations

Response to Prior Recommendations
The foremost recommendation from the 2000/2001 audit team was that the BMP training
and audits continue on a regular cycle. The 2004 audits, and 2005 training, will continue
this program in the spirit of continuous improvement through monitoring and evaluation.
    • A centralized, organized system for keeping track of timber sales in the state was
        recommended as a means to aid audit site selection. This recommendation has
        not been implemented.
    • The size and composition of the audit team was recommended to be revisited, so
        as to guard against redundancy in representation from various disciplines, as well
        as to ensure adequate representation for all disciplines and interests. Attendance
        from the landowner, timber sale purchaser, logging operator, and road builder
        were cited as areas of deficiency. The 2004 primary audit team was comprised of
        seven individuals, representing the disciplines of hydrology, forestry, soils,
        geology, fisheries biology, and logging engineering. In all instances, personnel
        associated with the administration of the timber sale were present on the audit as
        well. However, participation from landowners and logging contractors continues
        to be undersupplied, primarily due to time constraints.
    • The 2000/2001 audit team recommended revisiting previously audited sites in
        order to assess long-term effectiveness. Five years was recommended as an
        appropriate minimum amount of time for a revisit. Without enough time having
        elapsed to meet this recommendation, the 2004 audits did not revisit any of the
        2000/2001 audit sites.

The 2000/2001 audit team recommended a revision to the BMP audit rating guide. The
current rating guide follows precisely the text of the BMPs themselves, which were
generally not designed to translate clearly into audit items. As a result, the current rating
guide is lengthy, ambiguous, and often redundant. For the 2004 audits, several
approaches in revising the rating guide criteria were explored. The task quickly proved
itself to be beyond the scope of this grant. Consequently, no revisions to the audit rating
guide were instituted for the 2004 audits (Appendix A).

The 2000/2001 audit team also recommended that the USDA Forest Service coordinate
its timber sale contractual requirements with the BMPs. Upon further discussion, the
2004 audit team refined this recommendation. The Forest Service develops Regional
supplements to the timber sale contract, which are the proper vehicle with which to
ensure BMP compliance. Additionally, the Land and Resource Management Plans on




                                           - 11 -
individual National Forests, and Regional Watershed Conservation Practices Handbook
are other vehicles to ensure proper BMP implementation on Forest Service timber sales.

The BMP Handbook, which is distributed to foresters and logging contractors as a
training reference, was also recommended for revision by the 2000/2001 audit team. The
provision of clarified guidance on common areas of confusion, such as the construction
and maintenance of drainage structures, culvert installation, and streamside management
zone (SMZ) designation, was suggested as a primary focus of the revision. The
development of a simple, effective rating system for soil erosion potential, and the
provision of recommended vegetative ground cover species mixtures were also suggested
revisions. Prior to the 2004 audits, two main clarifications in the BMPs were made with
respect to ground cover species mixtures and appropriate width of SMZ designations
based on slope distance. Otherwise, no revisions to the BMPs or the BMP Handbook had
been completed prior to the 2004 audits.

The final recommendation from the 2000/2001 audit team was to facilitate improved
BMP awareness through continued training. Using specific examples from audit data to
focus the training sessions, as well as broadening the training attendance to foresters,
loggers, and specialists from all walks of private, state, and federal land managers, were
suggested as means for improving BMP training. These recommendations will be
implemented in the BMP training to take place around the state in July, 2005.

Recommendations of the 2004 Audit Team
• Continue the BMP audits and training program.
        o Perform audits in 2006 and training in 2007.
        o Audit eight timber sales in total in 2006.
        o Evaluate revisiting two of the 2000/2001 audit sites in the 2006 audits
        o Audit team composition should include representation from the following
            disciplines and interests: wildlife biology, fisheries biology, engineering,
            forestry, private landowner, logging contractor, timber sale administrator
            and/or purchaser, range conservationist, hydrology, soils, geology, and
            conservation organization.
        o Focus training upon common areas of confusion from the 2004 audit
            results.

•   Transfer the primary grant sponsorship from WTIA to Wyoming State Forestry
    Division.
           o Continue to maintain a high degree of participation from forest products
              industry representatives, potentially through a formal subcontract for grant
              administration tasks to WTIA.

•   Update the BMP Handbook, potentially as an alternative to the 2007 training.
          o Focus upon common areas of confusion from the 2000/2001 audit results,
              such as:
                     Proper SMZ designation, including recognition of SMZ
                     extensions.


                                          - 12 -
                      Proper culvert and water crossing installation and maintenance.
                      Road drainage structure installation and maintenance:
                           • Structure specifications (size, surfaces, slope, etc.);
                           • Proper distance between structures;
                           • Installation of energy dissipating materials at structure
                             outlets.
           o   Provide a simple, effective system to rate soil types for erosion potential.
           o   Use up-to-date photographs and forestry practices relevant to Wyoming.
           o   Clarify BMPs on the preparation of a management plan to guide harvest
               operations.
           o   Include updated recommendations for vegetative cover species mixtures.
           o   Include updated recommendations for SMZ width based on slope distance.

•   Revise the BMP Audit Rating Guide
           o Evaluate rating guides from surrounding states to improve audit efficiency
               and ensure regional consistency in results reporting.
           o Delete items that are not applicable to forestry in Wyoming.

•   Continue improving BMP awareness
          o Broaden the audience for BMP training workshops beyond foresters,
              logging contractors, and land managers.
          o Utilize educational methods other than training workshops to make people
              aware of the BMPs.




                                          - 13 -
            APPENDIX A

2004 Forestry BMP Field Audit Raw Data
                 and
         Rating Guide Criteria
                                                                                  APPENDIX A
                                                                 2004 Field Audit Data and Rating Guide Criteria


                                                                 Story Fish Hatchery                                                                                                        Joe's Park Timber
            Timber Sale Name       Damfino Timber Sale                    TS                   Delapp Timber Sale            Camino Timber Sale             West Gooseberry TS                     Sale
             Land Ownership/
                                          State of WY                   State of WY                    Private                       Private                            USFS                        USFS
                Management


PLANNING                          Application   Effectiveness   Application   Effectiveness   Application   Effectiveness   Application   Effectiveness   Application     Effectiveness   Application   Effectiveness

1. Soil and Water Resource
Monitoring and Evaluation
The federal agency, state, or
private landowner has a
monitoring plan that includes
monitoring objectives, review
of existing data and
information, characteristics to
be monitored, types,
techniques and frequency of
monitoring, data analysis and
evaluation, reporting and cost.       4              4              5              5              4              4              4              4               5               5              5              5
2. Wetlands Analysis and
Evaluation
Wetland functions are
maintained and adverse soil
and water resource impacts
associated with the destruction
or modification of wetlands are
avoided. See attached
document for Section 404
compliance.                           4              4              4              4             NA              NA            NA              NA             NA               NA             4              4
3. Riparian Area
designation
Riparian zone designation is
required and adequate.                3              4              4              4              4              4             NA              NA              4               4              4              4
Ground disturbance from
silvicultural activities is
minimized.                            4              4              4              4              4              4             NA              NA             NA               NA             4              4
Special limitations of timing,
slope, space or actions are
appropriately applied.                4              4              4              4              4              4             NA              NA              4               4              4              4
4. Oil and Hazardous
Substance Spill Contingency
Contamination of waters from
accidental spills is minimized
through prior planning and
development of Spill
Prevention Plans.                    NA             NA             NA             NA              4              4             NA              NA              4               4             NA             NA
5. Sanitary Guidelines for
the Construction of Camps
Sewer and solid waste
considerations are
appropriately applied if camps
are present.                      4    4    4    4    4    3    NA   NA   NA   NA   4    4
6. Timber Sale Design
A suitable logging system is
used for topography, soil type
and season of operation, while
minimizing soil disturbance
and economically
accomplishing silvicultural
objectives.                       4    4    4    4    4    4    4    4    5    5    4    4
The timber harvest unit design
maintains or improves
hydrology by maintaining water
quality and soil productivity
and reducing soil erosion and
sedimentation.                    4    4    4    4    4    4    4    4    4    4    4    4
7. Skidding Design
Design in the location of skid
trails provides for adequate
drainage and minimizes soil
compaction and displacement.      4    4    4    4    4    4    4    4    4    4    5    4
8. Suspended Log Yarding
Suspended log yarding was
used where appropriate to
protect riparian areas or other
sensitive watershed areas.        NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
9. Consistency of Water
Source Development
Consistent with Water
Quality Protection
Quality of water is protected
when supplied for road
construction and maintenance
and fire protection.              NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA


HARVESTING THINNING,
SLASH TREATMENT AND
REVEGETATION
10. Equipment Limitations in
Wetlands, Bogs and Wet
Meadows
Soil damage, turbidity and
sediment production resulting
from compaction, rutting,
runoff concentration and
subsequent erosion is avoided.    4    4    4    4    NA   NA   NA   NA   4    4    4    4
11. Log Landing Location
and Design
Landings are located to
minimize soil disturbance while
meeting safety and efficiency
requirements.                     4    4    4    4    4    4    5    5    4    4    4    4
Landings are located to
provide appropriate drainage
that minimizes erosion and
avoids sediment delivery to
streams.                          4    4    4    4    4   3   4    4    4    3    4    4
Landings are located to
minimize the number of tractor
roads.                            4    4    4    4    4   4   4    4    NA   NA   4    4
12. Log Landing Erosion
Protection and Control
Landings are maintained to
allow for proper drainage to
permit the dispersion of water
and minimize erosion.             4    4    4    4    4   4   4    4    4    4    4    4
13. Revegetation of Areas
Disturbed by Harvest
Activities
Practices have been
completed to ensure adequate
revegetation cover needed to
prevent accelerated erosion in
areas disturbed by harvest.       NA   NA   NR   NR   4   4   4    4    4    4    NR   NR
14. Erosion Control on Skid
Trails
Skid trails are constructed and
maintained to minimize erosion
and avoid sediment delivery to
streams.                          4    4    4    4    4   4   NA   NA   NA   NA   NA   NA
15. Stream Channel
Protection
The natural flow of streams is
protected (unobstructed
passage of storm flows
provided; fish passages
unobstructed; shading and
ambient stream temperatures
maintained; sediment and
other pollutants kept from
entering streams; natural
course of any stream modified
as a result of timber
management activities is
restored.                         NA   NA   4    4    4   4   NA   NA   4    4    4    4
Streambanks associated with
silvicultural or road
construction/maintenance
activities are protected.         4    4    4    4    4   4   NA   NA   4    4    NA   NA
16. Erosion Control and
Structure Maintenance
All drainage structures,
culverts, stream crossings,
water bars, ditches, water
spreaders and dissipaters are
in good repair and stable
condition.                        4    4    4    4    4   4   NR   NR   3    4    4    4
17. Slash and Cull Wood
Treatment in Sensitive Areas
Wet meadows, wetlands,
riparian areas or landslide
areas have slash removed or
hand piled.                       4    4    4    4    NA   NA   NA   NA   NA   NA   4    4
ROADS
18. General Guidelines for
the Location and Design
(and Maintenance) of Roads
and Trails
The number of roads
necessary is minimized.           4    4    4    4    4    4    4    4    4    4    4    4

Existing roads are used unless
the use of existing roads would
aggravate erosion potential.      NA   NA   4    4    4    4    4    4    4    4    5    4
Road design minimizes soil
movement and sedimentation
as well as undue disruption of
water flow.                       4    4    4    4    4    4    4    4    4    4    4    4
Stream crossing
accommodates design for
flood volumes.                    3    3    NA   NA   NA   NA   NA   NA   4    4    NA   NA
Road locations avoid long,
sustained, steep road grades.     4    4    4    4    4    4    4    4    4    4    4    4
Road and trail drainage are
designed to keep sediment
from being deposited within
bank full flow.                   4    4    4    4    4    4    NA   NA   4    4    NA   NA
19. Road and Trail Erosion
Control Plan
Erosion control measures are
in place prior to seasonal
precipitation and runoff.         4    4    4    4    NR   NR   3    3    4    4    3    3
Exposed soil is protected from
detachment, and erosion is
minimized through vegetative
or physical practices.            4    3    4    4    NR   NR   4    4    4    4    4    4
Adequate road surface
drainage and drainage
dispersal associated with
roads is provided.                3    3    4    4    4    4    NR   NR   4    4    4    4
Culverts and drainage devices
are adequately maintained.        4    4    NA   NA   NA   NA   NA   NA   4    4    4    4
Adequate sized culverts are
designed and installed.           3    3    NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Ditch/relief culverts are
protected, stabilized and
placed appropriately.             NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Energy dissipaters are placed
at drainage structure outlets
where needed.                     4    4    NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
20. Timing of Construction
Activities
In-stream construction
activities are completed with
consideration to critical fish
spawning and incubation
periods.                          4    4    NA   NA   NA   NA   NA   NA   NA   NA   NA   NA

Erosion is minimized by
restricting operations during
excessive moisture periods.       4    4    NA   NA   NA   NA   4    4    4    4    NA   NA
21. Slope Stabilization and
Prevention of Mass Failures
There is no evidence of mass
failures, landslides and
embankment slumps due to
road construction or
maintenance.                      4    4    4    4    4    4    4    4    4    4    NA   NA
22. Stabilization of Slopes
Road cut &/or fill slopes and
travelways are stabilized.        4    4    4    4    4    4    4    4    4    4    NA   NA
23. Permanent Road
Drainage

Road drainage systems and
drainage control structures are
adequate and working.             4    4    4    4    4    4    4    4    4    4    NA   NA
24. Pioneer Road
Construction
Pioneer roads are designed to
protect water quality.            NR   NR   NA   NA   NR   NR   NA   NA   NR   NR   NA   NA
25. Timely Erosion Control
Measures on Incomplete
Roads
Erosion of and sedimentation
from disturbed ground on
incomplete projects is
minimized.                        NR   NR   NA   NA   NA   NA   NA   NA   NR   NR   NR   NR
26. Control of Road
Construction Excavation
and Sidecast Material
Excess material is stabilized.    NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NR   NR
27. Control In-Channel
Excavation
Stream channel disturbance is
minimized.                        4    4    NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Culverts conform to natural
streambed and slope.              4    4    NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Material excavated from the
stream channel is to be
removed to a suitable upland
disposal and disturbed
streambanks are stabilized.       4    4    NA   NA   NA   NA   NA   NA   4    3    NA   NA
28. Diversion of Flows
Around Construction Sites
Diversions that are necessary
to avoid excessive sediment
for in-stream operations are
properly constructed.             NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
29. Stream Crossings on
Temporary Roads
Stream crossing by temporary
roads are minimized.              NA   NA   NA   NA   NA   NA   NA   NA   4    4    4    4
Temporary roads do not
unduly damage streams,
disturb channels or obstruct
fish passage.                     NA   NA   NA   NA   NA   NA   NA   NA   4    4    4    4
30. Bridge and Culvert
Installation (Disposition of
Surplus Material and
Protection of Fisheries)
Calculation and rational is
provided for selection of
culvert size.                     NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Sediment is minimized.            4    4    NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Culvert and bridge size is
appropriate for stream channel
size based on site specific
objectives.                       NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Minimum cover is provided for
culverts.                         4    4    NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Inlet and outlet are armored to
prevent erosion.                  NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Water pumped from foundation
excavation is not discarded
directly into live streams.       NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Activity adjacent to stream
course is minimized to prevent
erosion.                          4    4    NA   NA   4    4    NA   NA   NA   NA   NA   NA
31. Regulation of Borrow
Pits, Gravel Source and
Quarries
Sediment production is
minimized from borrow pits,
gravel sources, and quarries,
and channel disturbance in
those gravel sources suitable
for development in floodplains
is limited.                       NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Reclamation processes are
completed in borrow pits and
gravel sources.                   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
32. Disposal of Right-of Way
and Roadside Debris
Debris generated during road
construction is kept out of
streams and slash and debris
is prevented from obstructing
channel.                          4    4    NA   NA   4    4    NA   NA   4    4    NA   NA
33. Streambank Protection
Sedimentation from structural
abutments in natural
waterways is minimized.             NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
34. Treatment of Temporary
Roads (Obliteration)
Roads are drained and
blocked.                            4    4    NA   NA   NA   NA   NA   NA   4    4    4    4
Natural drainage is restored.       4    4    NA   NA   NA   NA   NA   NA   4    4    4    4
Exposed soil is protected from
detachment and erosion is
minimized through vegetative
or physical practices.              4    4    NA   NA   NA   NA   NA   NA   4    4    NR   NR
Sideslopes are reshaped.            4    4    NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
PESTICIDES, HERBICIDES,
FERTILIZERS AND
CHEMICALS
35. Proper Application and
Use of Pesticides
Pesticides are properly
applied.                            NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
36. Proper Application and
Use of Fertilizers
Fertilizers are properly applied.   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
37. Cleaning and disposal of
Pesticide Containers and
Equipment
The cleaning and disposal of
pesticide containers and
applicator equipment is done
in accordance with federal,
state, and local laws,
regulations and directives.         NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
Records were kept that
document how and where
containers were disposed.           NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
38. Pesticide Application,
Monitoring and Evaluation
A monitoring and evaluation
plan is in place so as to
minimize or eliminate hazards
to non-target areas or
resources.                          NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
39. Servicing and Refueling
of Equipment
Refueling and servicing
activities are done at least 150
feet from any watercourse.          4    4    4    4    4    4    4    4    4    4    NA   NA
Spills are reported as required
in Wyoming Water Quality
Rules and Regulations,
Chapter IV.                         NA   NA   NA   NA   NA   NA   NA   NA   NR   NR   NA   NA
Mitigating measures are
immediately applied following
a spill.                            NA   NA   NA   NA   NA   NA   NA   NA   NR   NR   NA   NA
FIRE MANAGEMENT
40. Protection of Soil and
Water from Prescribed
Burning Effects
Appropriate techniques are
used to maintain soil
productivity, minimize erosion
and prevent ash, sediment,
nutrients and debris from
entering surface water.          NA   NA   NA   NA   NA   NA   NA   NA   NR   NR   4    3
41. Stabilization of Fire
Suppression Related
Watershed Damage
Appropriate mitigation
treatments are applied to
activities completed for fire
suppression.                     NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA
42. Emergency
Rehabilitation of Watersheds
Following Wildfires.
Appropriate treatments are
utilized to rehabilitate
watershed following wildfires.   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA   NA

				
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