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DEPARTMENT OF NATURAL RESOURCES & CONSERVATION • FORESTRY DIVISION • MISSOULA, MT 59801-3199

MONTANA STATE LIBRARY

3 0864 0015 3782 1

MONTANA

FORESTRY BEST MANAGEMENT PRACTICES
IMPLEMENTATION MONITORING

THE 1996 FORESTRY BMP AUDITS
FINAL REPORT

This report was partially funded through a
Clean Water Act Section 319 Grant, DEQ Contract #207001

MONTANA DEPARTMENT OF NATURAL RESOURCES AND CONSERVATION

FORESTRY DIVISION
MISSOULA, MONTANA 59804

Report Prepared by George Mathieus

Digitized by the Internet Archive

in 2016

https://archive.org/details/montanaforestryb1996mont

TABLE OF CONTENTS

PAGE

ACKNOWLEDGMENTS iv

EXECUTIVE SUMMARY 1

INTRODUCTION 5

METHODS 7

The Audit Teams 8

The Study Area 9

Site Selection 9

Sample Size 12

The Rating Form 12

Audit Site Inspections 14

Limitations of the Audit Methods 15

RESULTS 16

High Risk BMPs 17

Some Practices Not Rated 17

Application of BMPs 17

Effectiveness of BMPs 21

Cumulative Watershed Effects 24

DISCUSSION 25

Streamside Management Zones 28

Results by Ownership Group 31

Comparison with Previous Audits 31

RECOMMENDATIONS FROM AUDIT TEAM MEMBERS 35

REFERENCES 36

APPENDICES

A. Audit Team Members A-l

B. Hazard Matrix B-l

C. Rating Form C-l

D. Rating Flow Chart D-l

E. Audit Sites E-l

F. Audit Results by Individual BMP F-l

- i -

INDEX OF TABLES AND FIGURES

PAGE

Table 1 Percent of Sites Meeting High Hazard Criteria 11

Table 2 Size of Harvest Units Evaluated by Ownership 12

Table 3 Application of BMPs to All Rated Practices by Ownership Group

and Rating Category 18

Table 4 Application of High Risk BMPs by Ownership Group

and Rating Category 19

Table 5 Audit Sites with Departures from BMP Application and Average

Number of Departures per Site 20

Table 6 Effectiveness of BMPs for All Rated Practices by Ownership Group

and Rating Category 21

Table 7 Effectiveness of High Risk BMPs by Ownership Group

and Rating Category 23

Table 8 Audit Sites with Impacts and Average Number

of Impacts Per Site 23

Table 9 SMZ Departures by Ownership Group 29

Table 10 SMZ Departures by Practice 30

Table 11 Comparison of BMP Audit Results--1994 vs. 1992 and 1990 31

Figure 1 BMP Application— All versus High Risk 19

Figure 2 1996 BMPs Resulting in Impacts 22

Figure 3 Percent of Sites w/at Least One SMZ Departure 29

Figure 4 Comparison of BMP Application 32

Figure 5 Comparison of BMP Effectiveness 33

Figure 6 Sites with Major Departures or Impacts 33

Figure 7 Average # of Departures per Site 34

Figure 8 Average # of Impacts per Site 34

- ii -

Photo 1 Northwest Audit Team and Observers Filling out Rating Form 8

Photo 2 Southwest Audit Team Fill out Rating Form 14

Photo 3 Audit Team Inspecting a Skid Trail Water Bar 15

Photo 4 Slash Filter Windrow 16

Photo 5 Audit Team Evaluating Harvest Unit 18

Photo 6 Audit Team Member Inspecting Culvert Alignment 20

Photo 7 Audit Team Inspecting the Effectiveness of a Road Drainage Structure 22

Photo 8 Audit Team Evaluating SMZ 28

Photo 9 Audit Team Member Measuring Slope for SMZ Boundary 30

- iii -

ACKNOWLEDGMENTS

In 1996, the task of completing the Forestry BMP audits was given to the Service Forestry
Bureau, Forestry Division of the Montana Department of Natural Resources and Conservation.
The division graciously acknowledges the many people who gave their time and energy toward
the audit effort. Special thanks to the Work Group members who contributed to the task of
reviewing the many issues that arose from the 1994 audits as well as overseeing the entire
process. Special thanks also goes out to the audit team members who traveled extensively,
worked long days in the field, and made many difficult decisions in a professional manner.
Thanks to the Environmental Quality Council and the Governor’s office for acknowledging the
significance of the forestry water quality issue and for recognizing that the audit process
continued in 1996. Our gratitude to the Water Quality Division, Department of Health and
Environmental Sciences, for their help in securing the grant which helped fund audit team
members and covered the cost of printing this publication. Thanks to all who supplied
information to select the sites and those who gave access to private lands. Thanks also goes to
Gary Frank and Norm Fortunate for their assistance in the site selection process. Special
thanks goes to Patty Fish for creating and editing portions of this report. Thanks also to Mira
Bruner and Kate Kronen for their assistance with all the mailing. Finally, the department
would like to thank Pam Hackley and Mark Lennon for supplying the photos that were
incorporated into this report.

- IV -

EXECUTIVE SUMMARY

The Best Management Practice (BMP) audit process is used to evaluate whether BMPs are
being applied and if they are effectively limiting non-point source pollution. In 1995 the
Governor requested the Montana Department of Natural Resources and Conservation (DNRC),
Forestry Division to evaluate forest practices for BMP implementation and report to the EQC
before the 1997 legislative session. This report summarizes the findings of Montana's 1996
forestry BMP audits. A similar study and report were completed in 1990, 1992 and 1994.

Three interdisciplinary teams conducted the audits. Each audit team was composed of six
members: a fisheries biologist, a forester, a hydrologist, a representative of a conservation
group, a road engineer, and a soil scientist. DNRC used site selection criteria to choose 46
timber harvest sites harvested since 1994. The selection criteria limited the sample to those
sites most sensitive to the practices that affect water quality. The audit teams evaluated a
maximum of 47 practices at each site, rating application and effectiveness for each BMP on a
5-point scale.

The audit teams evaluated 44 sites for BMP application. Audit results showed that 92 % of
the time BMPs were properly applied. Most harvest sites had at least one instance where
BMP application was inadequate. However, a majority of these departures were minor and did
not cause erosion or deliver material to a stream. Twenty-seven percent of the sites had one
or more BMP departures which resulted in some erosion or deposition of material to a stream.
Because practices vary greatly in their potential impact, the application of eight high risk
BMPs was evaluated separately. High risk BMPs are among those most important for
protecting soil and water resources. Eighty-one percent of these high risk BMPs were
properly applied.

The audit teams also evaluated BMP effectiveness. Audit results showed that 94% of the time
BMPs were effective in protecting soil and water resources. Most of the sites had some minor
departures in BMP effectiveness. Minor departures in effectiveness produce minor impacts to
soil and water resources. Only 34% of the sites had major departures in BMP effectiveness.
Eighty-six percent of the eight high risk BMPs evaluated were rated as providing adequate
protection to soil and water resources.

The greatest departure from BMPs, and the most impacts, were associated with road drainage.
The text includes a list on pages 25-26 of problematic BMPs and BMPs that are usually
applied properly.

The audit teams also evaluated application and implementation of the Montana Streams ide
Management (SMZ) Law. There were 29 SMZ law infractions noted during all the audits.
Most of these were minor and produced no discernible impacts to soil and water resources.

- 1 -

Results for BMP application, effectiveness and SMZ application are summarized by ownership
groups below:

PRACTICE

Federal

DNRC

Industrial

Non-Indust.

Private

BMP APPLICATION

93%

96%

94%

86%

BMP EFFECTIVENESS

94%

98%

97%

89%

SMZ APPLICATION *

33%

40%

15%

83%

* These numbers represent the percent of sites with at least one instance where the SMZ law
was not met.

Similar audits were conducted in 1990, 1992 and 1994 which can be compared to the 1996
results. The 1996 audits show improvement in the application and effectiveness of BMPs
when compared with the 1990, 1992 and 1994 results. These comparisons are summarized
below:

Comparison of BMP Audit Results - 1996 vs. 1994, 1992 and 1990

1996

1994

1992

1990

Application of practices that meet or
exceed BMP requirements.

92%

91%

87%

78%

Application of high risk practices that
meet or exceed BMP requirements.

81%

79%

72%

53%

Number of sites with at least one
major departure in BMP application.

12 of 44
(27%)

17 of 46
(37%)

20 of 46
(43%)

27 of 44
(61%)

Average number of departures in BMP
application, per site.

3.0

3.9

5.6

9

Number of practices providing
adequate protection.

94%

93%

90%

80%

Number of high risk practices
providing adequate protection.

86%

83%

77%

58%

Number of sites having at least one
major/temporary or minor/prolonged
impact.

15 of 44
(34%)

13 of 46
(28%)

17 of 46
(37%)

28 of 44
(64%)

Average number of impacts per site.

2.3

3

4.6

8

-2-

Recommendations from 1996 Audit Team Members

• Continue the interdisciplinary forestry BMP audits. The audit process has been
fundamental in educating and making people aware of BMP requirements. Conduct
the audits every two years.

• Continue to evaluate implementation of the SMZ law and rules.

• Update the BMP audit process to include site selection, clarification and refinement of
the BMP’s and the audit form.

• Encourage the development of a mechanism to monitor the effectiveness of BMP’s.

• Recognize the need to formally involve NIP landowners into the entire BMP audit
process.

• Encourage all ownership groups to continue their commitment, involvement and
support in the audit process.

• Continue educating loggers, landowners, and foresters, concentrating on problem
areas documented through BMP audits. Lack of adequate drainage on new and
existing roads continues to be the primary impact to water quality. BMP education
should emphasize the need for meeting road drainage BMPs.

• Actively encourage the sites’ owners and logging contractors to attend the audit. The
Montana Logging Association and the Montana Wood Products Association will assist
DNRC in notifying contractors. At a minimum, give contractors a copy of the audit
results for their sites.

• The team leader should encourage the landowner and contractor and, if needed in the
case of NIP lands, the DNRC Service Forester, to develop a remedy for problems
noted. An audit team member will assist if necessary, especially to identify
problems. Industry groups, such as MLA and MWPA may participate as needed.

• Continue funding volunteer audit team members.

• Institute a similar BMP audit process for other land uses, including mining, livestock
grazing, agriculture and subdivision development.

- 3 -

INTRODUCTION

The forest lands of Montana form the headwaters for several major river basins and produce
large quantities of high quality water. This water nurtures some of the West's best fisheries,
and is used for irrigation and livestock, as well as for domestic, recreational and industrial
purposes. These same lands supply the logs that sustain the forest products industry, an
important component of Montana's economy. All products from Montana's 22.5 million acres
of forest land contribute in an essential manner to Montana's economy and way of life.

Montana's water quality protection program for forestry involves a combination of regulatory
and non-regulatory approaches. Since the 1970 's, non-regulatory Forestry Best Management
Practices have provided guidance as minimum water quality protection standards for forestry
operations.

The BMPs, if properly designed and effectively applied, can limit non-point source
pollution— the kind of diffuse pollution that forestry operations often produce, such as sediment
from a road or timber harvest. The BMP audit process is used to evaluate whether BMPs are
being applied and if they are effectively limiting non-point source pollution.

Concern over the impacts of forest management on Montana's watersheds prompted the 1987
Montana Legislature to pass House Joint Resolution 49. This resolution directed the Montana
Environmental Quality Council (EQC) to study "how current forest management practices are
affecting watersheds in Montana." The EQC established a BMP technical committee that
revised Montana's forestry BMPs in 1989.

Prior to 1990, forestry water quality was addressed through a voluntary approach. In 1989,
the Legislature enacted the BMP Notification Law (76-13-101 MCA) which requires private
landowners who plan to harvest timber to notify the state of their plans. Under this law,
forestry BMP information is sent to landowners. Implementation of practices is voluntary.
DNRC Service Foresters review a limited number of high risk sites prior to timber harvest.
Nearly all sites on private land reviewed during the 1996 audits were subject to the BMP
Notification Law.

Since October 1991, the Streamside Management Zone (SMZ) Law (77-5-301 MCA) regulates
forestry practices along streams. This law prohibits certain forest practices along stream
channels. The SMZ rules, which were mandated by the law, became effective March 15,

1993 and were intended to help define and clarify the SMZ law. The 1992 BMP audits did not
evaluate compliance with the SMZ law because most operations audited were completed prior
to the effective date of the law. The 1994 audits, however, were designed to provide
preliminary information on the application and implementation of the SMZ law and rules,
using a supplemental SMZ questionnaire.

In 1996, a different approach was used to evaluate the SMZ law and rules. The 1994
questionnaire was dropped and nine practices applicable to SMZ’s were taken from the BMP’s
and the SMZ rules, then combined into a rating format. The format was the same as the one
used to evaluate the BMP’s for application and effectiveness on a 5-point scale. DNRC’s
intent here was to supply data that would be more easily summarized.

-5 -

Forestry BMP audits have been conducted previously in Montana. As part of HJR-49, audit
teams conducted the first statewide assessment of forest practices for BMPs during the summer
of 1988 (Zackheim, 1988). In 1989, the University of Montana, under the Flathead Basin
Water Quality and Fisheries Cooperative, audited more sites for BMPs in the Flathead River
drainage (Ehinger and Potts, 1990). The Montana Legislature directed DNRC to conduct
further series of statewide BMP audits in 1990, 1992 and 1994 (Schultz, 1990 and 1992),
(Frank, 1994).

In 1995, the Governor requested the Montana Department of Natural Resources and
Conservation (DNRC) Forestry Division to once again evaluate forest practices for BMP
implementation and report to the EQC before the 1997 legislative session. This report
summarizes the findings of Montana's 1996 forestry BMP audits.

The BMP audit process, which the EPA calls BMP implementation monitoring, is a
widely-used means of evaluating forest practices. Implementation monitoring is a surrogate
for water quality monitoring, a more quantitative approach. Water quality monitoring is a
long-term and expensive endeavor. Water quality varies naturally due to variable geology,
land forms, soils, and climatic events. Due to this variability, investigators have to collect
large numbers of samples at the right time and over a long period of time to accurately
characterize water quality.

Investigators use qualitative implementation audits to find out if BMPs are being applied and
whether they are controlling erosion; they can use quantitative water quality monitoring to
determine if BMPs are protecting beneficial water uses. Since BMPs are recognized by state
and federal legislation as a method to control non-point source pollution, it makes sense to
check the application and effectiveness of BMPs as part of such a program. States are
increasingly relying on qualitative surveys, using interdisciplinary teams to assess forest
practices on-site, to monitor their silvicultural non-point source control programs (NCASI,
1988). California, Idaho, Oregon, Utah, Minnesota, Washington, South Carolina, Texas and
Florida all use a similar qualitative approach to assess the control of non-point source pollution
from forest practices.

-6-

METHODS

The 1996 audits were conducted with similar objectives and criteria as the 1994, 1992 and
1990 audits in order to produce comparable results.

The objectives for the 1990 and 1992 BMP field audits were to:

1. Determine if BMPs are being applied on timber harvest operations.

2. Evaluate the general effectiveness of BMPs in protecting soil and water resources.

3. Provide information on the need to revise, clarify, or strengthen BMPs.

4. Provide information to focus future study efforts by identifying subjects and
geographic areas in need of further investigation.

In addition to those listed above, the 1994 and 1996 field audits included one objective
concerning the Montana Streamside Management Zone Law and rules:

5. Provide preliminary information on the implementation of the SMZ law and rules and
evaluate general effectiveness of SMZs in protecting water quality.

DNRC sought a broad range of participation in planning the 1996 audits, but since the audit
was conducted with similar objectives and criteria, less planning was necessary than for
previous audits.

-7-

The Audit Teams

DNRC designated three audit teams-one for the northwestern, one for the west central, and
one for the southwestern and eastern parts of the State. Each team was composed of six
members— a fisheries biologist, a forester, a hydrologist, a representative of a conservation
group, a road engineer, and a soil scientist. A member of each audit team was assigned to
lead the team. The team leader was responsible for filling out the consensus rating form and
for overseeing the logistics of the team. Team members were employees of federal and state
agencies, private industry, independent consultants, and volunteers representing several
conservation organizations. The Department of Natural Resources and Conservation received
a 319 grant from the EPA in part to pay volunteer members who could not participate as a part
of their regular job. Continuity in team membership was excellent. Fifteen of the 18 team
members from the 1994 audits participated in the 1996 audits. DNRC named an alternate for
each member in order to ensure a full range of interdisciplinary participation at each site.

Most of the alternates had also participated in the 1994 audits. See Appendix A for a complete
list of team members.

Photo #1. Northwest Audit Team and Observers Filling out Rating Form.

The Study Area

The Department expanded the study area to include the eastern half of the State in the 1994
and 1996 audits. During the 1990 and 1992 audits the study area was limited to the western
half of the state, where a majority of the timber harvest had occurred. Since that time, there
has been a substantial increase in the volume of timber harvested in Eastern Montana.
Approximately 44% of the statewide Non-Industrial Private harvest volume in 1994 came from
east of the Continental Divide.

Site Selection

The criteria for selecting sites were similar to the 1990, 1992 and 1994 audits, with an updated
time frame. The purpose in defining the criteria was to concentrate on sites that were more
likely to have potential for water quality impacts. The selection criteria limited the sample to
only those timber harvest sites most sensitive to the practices that affect water quality.

Selecting the sites was the responsibility of DNRC.

The initial criteria for selection were:

• Sites were selected from areas with timber harvested in 1994, 1995, or 1996.

Priority was given to most recently harvested sites.

• A portion of the sale needed to be located within 200 feet of a stream (see BMP
definition).

- 9 -

• Minimum size for harvest units to be included in the audit process was five acres.
Minimum timber removal was 5,000 board feet per acre. For east-side sales, some
flexibility was allowed if smaller or low volume harvest met other criteria.

• The distribution of audit sites reflected the distribution of timber harvest in Montana,
geographically, and by ownership group.

• Sites were classified into four land ownership classes— Nonindustrial Private,

Industrial Private, Federal, and State. The number of sites per ownership group was
to be proportional to the volume of timber each group harvested in 1994, the latest
complete reporting period. A minimum of five sites per ownership class was audited.

For sites that met the initial criteria, DNRC made further stratification:

• Sites which included harvesting within 200 feet of a stream and had road construction
or reconstruction with a stream crossing and slash disposal completed were given first
priority.

• Sites with streams adjacent to harvesting, road construction or reconstruction but
slash disposal not complete were given second priority.

• Sites with a stream adjacent to harvesting with slash disposal complete, but no road
construction or reconstruction was given third priority.

• Sites were further stratified by erosion hazard. Two-thirds of the audits were located
on high erosion hazard sites. One-third were to be located on low to medium erosion
hazard sites. This stratification was subject to availability of sites in the various
hazard groups.

Erosion hazard was determined as a function of slope steepness and erosivity based on
geologic parent material and soil texture. Erosion hazard was stratified by ownership
class so that a disproportionate number of high hazard sites did not fall in any one
ownership class. Erosion hazard was determined using an erosion hazard matrix
developed through the Montana Riparian Association. See Appendix B. Timber
harvest in riparian zones was categorized as high hazard.

The number of days team members would be able to conduct audits limited DNRC to choosing
46 sites for the teams to visit. Two Non-Industrial Private sites fell out of the selection pool
due to uncontrollable circumstances. As a result, 44 total sites were reviewed by the Audit
teams. The maximum time commitment for audit team members was set at 10 days, since a
longer commitment would likely jeopardize the ability of individuals to participate. On most
days, teams could audit a maximum of two sites. See Appendix E for the list of sites. The
four ownership groups and number of sites audited were:

- 10-

Ownership Group

Number of Sites Audited

1996

1994

1992

1990

Federal (USFS)

12

14

16

16

Industrial Private

14

14

16

16

Non-Industrial Private

13

13

9

7

DNRC

_5

_5

_5

_5

TOTAL

44

46

46

44

The goal for the audits was to have two-thirds of the sites in the "high hazard" category, as
explained in the criteria for selecting sites. In order to meet the high hazard criteria, a site had
either to rank high in a risk matrix that considers slope steepness, soil erodibility, and type of
operation, or to be in a riparian zone. See Appendix B. Table 1 shows the percent of audited
sites that, based on field evaluation, met the high hazard criteria, whether included by matrix,
riparian, or both. Three-quarters of the total sites audited were high hazard. This is similar to
the number of high hazard sites in 1990, 1992 and 1994.

Table 1

Percentage of Sites Meeting High Hazard Criteria

Ownership

Group

Number of
Sites

Matrix

Riparian

Matrix, Riparian
or Both

Federal

12

67%

42%

58%

Industrial

14

86%

71%

100%

NIP

13

46%

46%

62%

State

5

80%

60%

80%

All Sites

44

68%

55%

75%

Members of all the ownership groups provided excellent cooperation in assisting DNRC with
site selection. Industry and government supplied all information requested, and in most cases,
in a very timely manner. DNRC acquired the information about recent timber sales as
follows: The affected National Forests and BLM searched their recent timber sales for sites
that met some or all of the criteria. No BLM sites were supplied to DNRC that met the initial
site selection criteria; therefore, only USFS sites were used to represent (FED) ownership.
DNRC finished refining the search where needed. For non-industrial and industrial private
lands, DNRC searched Hazard Reduction Agreements and Master Hazard Reduction
Agreements for sites that met the criteria. DNRC searched its own timber sale accounting
program for state sites that met the criteria.

- 11 -

DNRC listed sites that met the criteria, by region within ownership groups. Sites to be
audited were selected randomly from the pool of suitable sites within each ownership group.
Only those sites with potential to impair water quality were judged to be suitable.

In the case of non-industrial private lands, DNRC contacted landowners for permission to visit
their lands. Participation by NIP landowners was very high. After a DNRC representative
contacted non- industrial landowners, a follow-up letter was sent to each landowner explaining
the purpose of the audit process as well as DNRC’s policy toward enforcement actions. Access
to the other ownership groups was not an issue.

The size of audited sites varied greatly. See Table 2 for information on size of harvest units
evaluated by ownership group. On very large sites, time did not allow the teams to review
every acre of the site or every segment of new or existing roads. Teams concentrated on areas
with the greatest potential for problems.

Table 2

Size of Harvest Units Evaluated by Ownership

Ownership

Group

Number of
Sites

Average
Unit Size
(Ac.)

Maximum
Unit Size
(Ac.)

Minimum
Unit Size
(Ac.)

Federal

12

40

110

12

Industrial

14

63

238

10

NIP

13

54

150

10

State

5

42

118

10

All Sites

44

47

238

10

Sample Size

Because the total number of cutting units in the State is not known, it is not possible to say
what percentage of them the 44 sites represent. It is a representative sample of logging
operations conducted in Montana since 1994 that meet the selection criteria. The selection
criteria limited the sample to only those timber harvest sites most sensitive to the practices that
affect water quality. The results are indicative of conditions for sites with potential to impair
water quality. The results do not represent a sample of all timber harvest operations in
Montana. The 44 sites represented approximately 1 % of the total volume harvested in the
state for the study period.

The Rating Form

The audit teams used a rating form similar to that of previous audits. See Appendix C for a
copy of the form. The form was slightly revised for the 1996 BMP field audits to clarify
unclear, incomplete or misleading statements. A new SMZ rating section was added while the

- 12 -

1994 SMZ questionnaire was dropped. The new SMZ section eliminated some of the old
SMZ/BMP ratings. All of the revisions were made with the goal of keeping the format
consistent with that used in past audits. The guide for rating application and effectiveness was
the same as used in the previous audits. The audit teams evaluated a maximum of 47 practices
at each site, rating application and effectiveness for each on a 5-point scale.

The audit team rated the application of BMPs by first noting if the BMP was applicable to the
site; if so, whether it was applied correctly and in the proper locations. Lack of adequate
application or misapplication are departures from BMPs. The rating guide for application of
BMPs was:

5 - Operation exceeds requirements of BMP.
4 - Operation meets requirements of BMP.

3 - Minor departure from intent of BMP.

2 - Major departure from intent of BMP.

1 - Gross neglect of BMP.

The following description of the rating guide is adapted from Ehinger & Potts, 1990. Ratings
of 5 and 4 are self-explanatory. The 3 rating, minor departure, applies to departures of small
magnitude distributed over a localized area, or over a larger area where potential for impact is
low. The 2 rating, major departure, applies to departures of large magnitude or BMPs being
repeatedly neglected. The 1 rating, gross neglect, applies where risks to soil and water
resources were obvious and yet there was no evidence indicating that operators had applied
BMPs to protect these resources.

The effectiveness rating answered questions concerning impacts. For example "has the
application or misapplication of a particular forest practice increased the likelihood of, or
actual occurrence of, sediment delivery to streams?" Lack of effectiveness results in impacts.
The rating guide for effectiveness was:

5 - Improved protection of soil and water resources over pre-project condition.

4 - Adequate protection of soil and water resources.

3 - Minor and temporary impacts on soil and water resources.

2 - Major and temporary, or minor and prolonged, impacts on soil and water resources.
1 - Major and prolonged impacts on soil and water resources.

The work group defined these terms prior to the 1990 audits to help the audit teams use them
consistently:

Adequate -

Minor -
Major -
Temporary
Prolonged

Small amounts of material eroded; material does not reach draws, channels,
or floodplain.

Some material erodes and is delivered to draws but not to stream.

Material erodes and is delivered to stream or annual floodplain.

- Impacts lasting one year or less; no more than one runoff season.

- Impacts lasting more than one year.

- 13 -

The audit teams used a flow chart to help rate application and effectiveness and, again, to keep
the rating consistent. See Appendix D.

Audit Site Inspections

The first audit site inspection served as a calibration audit for the teams. Since most team
members participated in previous audits, this session served as a refresher. The goal was to
have the audit teams establish a consistent method of rating that could carry through the rest of
the audits. Team members and alternates met for several hours of classroom instruction on the
BMP audit process, and then evaluated the first audit site in the field. The team members
shared their results with the other members, and identified and discussed their differences and
ways to be consistent.

Photo #2. Southwest Audit Team Filling out Rating Form.

The teams conducted the audits June through August of 1996. The field routine consisted of
meeting at a central location in the morning of each audit day. Teams traveled to the audit
site. On site, the team leader provided maps and audit forms. Usually a representative of the
landowner briefed the team by giving background information on the silvicultural prescription,
time of operation, and associated practices. Team members walked the site, reviewing
potential impact areas such as roads, streams, streams ide management zones (SMZs), skid
trails and firelines. Teams typically spent about two hours inspecting each site.

After finishing the inspection, the team gathered to discuss the rating while still on site. The
team leader was charged with leading the discussion and recording the consensus rating for
each item on the rating form. For ratings where the team could not reach a consensus, the
team took a vote and recorded the rating with the most votes. The team leader noted

- 14-

dissenting values in the Comments section. Teams almost always reached a consensus. Only
two individual ratings came to a vote. This number is down from 32 in the 1994 BMP audits.

Limitations of the Audit Methods (in part, adapted from Idaho DHW, 1989.)

In analyzing the audit results, readers need to consider the limitations of the techniques used in
the audit. The audit technique consisted of a one-time field inspection and assessment. This
approach documents erosion and sedimentation problems which occur in the first or second
year after harvest. This is generally the critical period for erosion associated with timber
harvests. Some practices conducted during harvest cannot easily be evaluated in post-harvest
audits. The assessment was based on visual appraisals of practices and impacts to surface soils
and streams. The results are a snapshot-in-time of the practices and subsequent impacts. They
do not necessarily reflect future impacts.

Sites were split among three teams. There are likely some differences in how the teams may
have rated individual items. Lack of consistency is probably not a big problem, based on
discussion with other teams and through overlap of team members on some audits, but it
should not be overlooked.

Also, auditors may rate several practices connected with one action. In some cases, one action
may result in more than one rating. For example, if a skidder operates extensively in the
Streamside Management Zone, the practice may rate poorly under both "Adequate SMZ
Maintained" and "Equipment Operation Minimized in SMZ." Even given these limitations,
the BMP audit process is an effective way to evaluate the implementation of BMPs. In
addition, the audit process has helped promote BMPs and encouraged landowners and
operators to protect water quality on managed forests.

Photo #3. Audit Team Inspecting a Skid Trail Water Bar.

- 15 -

RESULTS

The results of the 1996 BMP field audits are presented in several categories, including
application of BMPs and SMZs effectiveness of BMPs and SMZs, a supplemental question on
cumulative watershed effects, the SMZ law and rules evaluation, and the comparison of the
1996 results with previous audit results.

There are several ways to analyze and summarize the qualitative data generated by this study.
One method is simply to look at what percent of the practices audited for BMPs fell into each
rating category, by ownership group. This information is presented, for application and
effectiveness of BMPs respectively, in Tables 3 and 6. While this is useful information for
some purposes-including documenting problem BMP areas and comparing these results with
other audits— readers should not base their conclusions on these simple percentage ratings.
Appendix F tabulates how the ownership groups complied with each BMP.

All the practices evaluated in the audits can have an effect on water quality, but vary greatly in
their potential impact. For example, BMPs in the "Road Planning and Location" section do
not have as direct a potential impact on water quality as the practices in "Providing Adequate
Road Surface Drainage" or "Adequate SMZ Maintained."

- 16-

High Risk BMPs

Focusing on the simple percentages will not give a clear picture of how well or poorly
Montana's watersheds are being protected. Even a low percentage of misapplied BMPs can
still result in serious impacts. To provide several perspectives, the data has been analyzed in
different ways. In particular, a subset of eight high risk BMPs has been analyzed separately.
These eight high risk BMPs are among the most important for protecting Montana's
watersheds. The eight high risk BMPs are:

BMP

Number

Practice Description

I.C.l Provide adequate road surface drainage for all roads.

I.C.6 Route road drainage through adequate filtration zones before entering a
stream.

I.D.2 Stabilize erodible soils (i.e., seeding, benching, mulching).

I. E.2 Maintain erosion control features (dips, ditches and culverts functional).

II. A. 5 Design and locate skid trails to avoid concentrating runoff.

II.C.2a Adequate drainage for temporary roads, skid trails, fire lines.

II. D. 9 Limit water quality impacts of prescribed fire.

III. C.3 Prevent erosion of culvert and bridge fills (i.e., armor inlet and outlet).

The results for application and effectiveness of the eight high risk BMPs is presented in Tables
4 and 7, and Figure 1. Tables 5 and 8 summarize the data on a site basis, displaying the
percent of sites with departures or impacts and the average number of departures or impacts
per site.

Some Practices Not Rated

The number of practices rated represents 79% of the total possible number of practices. Some
BMPs did not apply to a site: some sites did not have stream crossings or new road
construction; most sites did not have borrow pits; in several instances, slash disposal and site
preparation had not been completed. In other cases, the audit team could not rate the BMP at
the time of the audit— BMPs having to do with timing of operations during the harvest cannot
be judged post-harvest.

Application of BMPs

The application rating measures whether the BMP was applied, whether it was applied
correctly, and whether it was applied in the proper locations. See "The Rating Form" section
on pages 12-14 for further explanation of the application rating. The audit teams evaluated a
total of 1,641 practices to assess how landowners and operators applied BMPs. Table 3 lists
the percent of practices that fell in each application rating category, by ownership group.
Rather than focusing on simple analysis, the reader should refer to other tables (Tables 4, 5, 7
and 8) that better indicate how well Montana's watersheds are being protected.

- 17 -

Table 3

Application of BMPs to All Rated Practices
by Ownership Group and Rating Category

Percent (%) Practices Rated As

Ownership

Group

# Practices
Rated

Meet or
Exceed

Minor

Departures

Major

Departures

Gross

Neglect

Federal

433

93%

6%

1%

0%

Industrial

549

94%

6%

<1%

0%

NIP

454

86%

10%

4%

0%

State

205

96%

4%

0%

0%

All Sites

1,641

92%

7%

1%

0%

Photo #5. Audit Team Evaluating Harvest Unit.

- 18 -

Table 4 shows the BMP application for the eight high risk BMPs that were evaluated
separately (see page 17). The percent of practices with departures is higher for the high risk
group (Table 4) than for all audited practices (Table 3), as shown in Figure 1.

Table 4

Application of High Risk BMPs
by Ownership Group and Rating Category

Percent (%) Practices Rated As

Ownership

Group

# Practices
Rated

Meet or
Exceed

Minor

Departures

Major

Departures

Gross

Neglect

Federal

87

85%

13%

2%

0%

Industrial

103

83%

17%

0%

0%

NIP

91

73%

21%

6%

0%

State

39

87%

13%

0%

0%

All Sites

320

81%

16%

3%

0%

BMP Application - All vs. High Risk

Meet or Exceed Minor Departure Major Departure Gross Neglect

□ All

High Risk

Figure 1.

Photo #6. Audit Team Member Inspecting Culvert Alignment.

Table 5 shows what percentage of sites departed from BMPs, and the average number of
departures per site. The average number of departures per site includes all the sites, not just
the sites with departures. Table 5 shows that most sites 89% -39 of 44— had at least one minor
departure. It also shows that 27%— 12 of 44— sites have at least one major departure in BMP
application.

Table 5

Audit Sites with Departures from BMP Application
and Average Number of Departures per Site

Percentage (%) of Sites with
Departures

# of Departures/Total #
of Sites = Ave. #/Site

Ownership

Group

Total # of
Sites

Minor

Major

Gross

Minor

Major

Gross

Federal

12

83%

33%

0%

2.3

.42

0

Industrial

14

93%

7%

0%

2.1

.07

0

NIP

13

85%

54%

0%

3.4

1.4

0

State

5

100%

0%

0%

1.6

0

0

All Sites

44

89%

27%

0%

2.5

.55

0

-20-

Effectiveness of BMPs

The effectiveness rating evaluates how well BMPs protected soil and water resources. See
page 13 for further explanation of the effectiveness rating. The audit teams evaluated a total
of 1,641 practices to see how effective the BMPs were. Table 6 provides a summary of the
effectiveness of all practices audited, by ownership group.

As with the corresponding table for BMP application (Table 3), the effectiveness information
(Table 6) should be used with discretion. While simple percentage ratings may be relatively
high for the category Adequate Protection, poor effectiveness of a single BMP may still result
in impacts.

Table 6

Effectiveness of BMPs for All Rated Practices
by Ownership Group and Rating Category

Percentage (%) Practices Rated As

Ownership

Group

Number of
Practices
Rated

Adequate

Protection

Minor/Temp.

Impacts

Major/Temp.,

Minor/

Prolonged

Major/

Prolonged

Federal

433

94%

4%

2%

0%

Industrial

549

97%

3%

<1%

0%

NIP

454

89%

7%

4%

0%

State

205

98%

2%

0%

0%

All Sites

1,641

94%

4%

2%

0%

-21 -

Photo #1 . Audit Team Inspecting the Effectiveness of a Road Drainage Structure.

Figure 2 presents the percent of practices audited that are contributing to impacts by ownership
group. This figure shows differences among ownership groups in effectiveness of their BMP
implementation.

1996 BMP's Resulting in Impacts

By Ownership

DNRC FED IND NIP ALL

i 1 Minor Major

Figure 2

Table 7 shows the effectiveness of the eight high risk BMPs listed on page 17. The percent of
practices providing adequate protection is lower for the high risk BMPs than for the total BMP
results presented in Table 6. The percent of practices resulting in impacts are higher for the
high risk BMPs than for practices in general.

-22-

Table 7

Effectiveness of High Risk BMPs
by Ownership Group and Rating Category

Percentage (%) Practices Rated As

Ownership

Group

Number of
Practices
Rated

Adequate

Protection

Minor/Temp.

Impacts

Major/Temp.,

Minor/

Prolonged

Major/

Prolonged

Federal

87

84%

9%

7%

0%

Industrial

103

91%

9%

0%

0%

NIP

91

79%

14%

7%

0%

State

39

90%

10%

0%

0%

All Sites

320

86%

11%

3%

0%

Table 8 lists the percentage of sites with impacts and average number of impacts per site. This
table shows that 66% of the sites audited were producing at least minor/temporary impacts— at
an average of 1.6 per site. Thirty four percent of all sites were producing major/temporary
impacts— an average of 0.66 per site. This analysis illustrates that, while the percentage of
practices rated as providing adequate protection may be quite high (86%), impacts were still
occurring on a majority of the sites audited.

Table 8

Audit Sites with Impacts and Average Number of Impacts per Site

Percentage (%) of Sites
with Impacts

# of Impacts/Total ti
of Sites = Ave. #/Site

Ownership

Group

Total #
of Sites

Minor/

Temp.

Major/Temp.,

Minor/

Prolonged

Major/

Prolonged

Minor/

Temp.

Major/Temp.,

Minor/

Prolonged

Major/

Prolonged

Federal

12

67%

50%

0%

1.5

.83

0

Industrial

14

71%

7%

0%

1.2

.07

0

NIP

13

69%

62%

0%

2.5

1.40

0

State

5

40%

0%

0%

1.0

0

0

All Sites

44

66%

34%

0%

1.6

.66

0

-23 -

Cumulative Watershed Effects

The audit teams asked audit site representatives the following supplemental question
addressing cumulative watershed effects:

Were any CWE assessments or watershed analyses included in the timber harvest
planning?

If yes, what type and level of analysis was carried out (i.e., monitoring, screening, CWE
indices, interdisciplinary teams, assessments of changing geomorphic processes or a
combination of two or more).

The table below reflects the sites that included some type of CWE assessment into the harvest
plan.

Sites Where Landowners

Ownership Group Assessed Cumulative Effects

Federal

12 of 12 =

100%

Industrial

6 of 14 =

43%

NIP

2 of 13 =

15%

State

5 of 5 =

100%

All Sites

25 of 44 =

57%

There were 25 of 44 sites that included some type of assessment. The table below reflects the
four types of assessments and their percentage of occurrence.

Assessment Type

% of Occurrence

CWE Indices
EC A Analysis
Model

Preliminary Screening

4 of 25= 16%

4 of 25= 16%

10 of 25 = 40%
7 of 25 = 28%

-24-

DISCUSSION

Table 3 indicates that 92% of the practices applied on all sites met or exceeded BMP
standards. This type of analysis does not accurately represent the impact that practices have
had on the audited sites. Not all practices are equally important for protecting water quality.
81% of high risk BMPs, as listed in Table 4, met BMP requirements.

Eleven percent of the high risk BMPs resulted in impacts, as shown in Table 7. Table 8
indicates that 66% of the audited sites (29 out of 44) produced minor/temporary impacts and
34% (15 out of 44) produced either major /temporary or minor/prolonged impacts. No sites
produced major/prolonged impacts. Most of these impacts could have been prevented if
landowners and operators had properly applied BMPs.

As was true for the 1990, 1992 and 1994 audits, the results of the 1996 audits show that the
greatest departure from BMPs, and the most impacts, were associated with road drainage.
Improper installation of or lack of slash filter windrows, insufficient maintenance of erosion
control features and drainage and poor skid trail design, location, and drainage also resulted in
a large number of deficiencies in application and impacts.

The list that follows is of individual BMPs that most often are not properly applied or result in
impacts, ranked in order, by the sum of departures and impacts. Rankings from the 1990,
1992 and 1994 audits are listed in parentheses. An ( - ) indicates not frequent enough to be in
the top list for that year.

-25 -

1996

1994

1992

1990

Practice Description

Practice #

1.

( 1.)

(3.)

(1-)

Provide adequate road surface drainage for
all roads.

I.C.l

2.

(4.)

(-)

(5.)

Slash filter windrows installed.

I.D.3

3.

(3.)

(13.)

(19.)

Direct road drainage away from stream
crossing site.

III. B. lb

4.

(9.)

(10.)

(2.)

Prevent erosion of culvert and bridge fills.

III.C.3

5.

(5.)

(-)

(10.)

Maintain erosion control features (dips, ditches,
and culverts functional).

I.E. 2

6.

(-)

(12.)

(-)

Cut and fill slopes at a stable angle.

I.D.5

7.

(2.)

(2.)

(3.)

Route road surface drainage

I.C.6

8.

(8.)

(15.)

(4.)

Stabilize erodible soils (i.e. seeding, benching,
mulching).

I.D.2

9.

(6.)

( 1.)

(6.)

Adequate drainage for temporary roads, skid
trails, and fire lines.

II.C.2a

10.

(-)

(-)

(-)

Skew ditch relief culverts.

I.C.2

11.

(7.)

(5.)

(9.)

Design and locate skid trails to avoid
concentrating runoff.

II. A. 5

12.

(14.)

(-)

(-)

Avoid incorporating woody debris in road fills.

ID. 6

13.

(-)

(-)

(-)

Excess materials placed in locations that avoid
entering a stream.

I.D.8

14.

(11.)

(-)

(-)

Provide energy dissipators at drainage structure
outlets where needed.

I.C.4

15.

(-)

(6.)

(16.)

Limit water quality impacts of prescribed fire.

II. D. 9

16.

(-)

(7.)

(15.)

Grade roads to maintain drainage.

I.E.l

These 16 practices accounted for 84% of all departures and 79% of all impacts. The
remaining BMPs had a lower frequency of departures in application or resultant impacts.

The following practices were on the 1994 list of BMPs most often not applied or resulting in
impacts but did not make the list in 1996. The number in pparentheseson the left is the
ranking from the 1994 report.

GO.)

Culverts conform to natural streambed and slope

(IIIC2)

(12.)

Reconstruct only to the extent necessary to provide

adequate drainage and safety.

(ID 10)

(13.)

Skidding operation minimizes soil compaction and

displacement.

(IIC la)

(15.)

Locations avoid high hazards sites (i.e., wet areas

and unstable slopes).

(IA4)

(16.)

Streams free of logging debris.

(IIB4)

(17.)

Vary road grades to reduce concentrated drainage.

(IB4)

On the positive side, the 1996 audits showed that the following BMPs were nearly always
properly applied, resulting in few impacts (two or fewer minor/temporary impacts).

-26-

• Most BMPs related to road planning and location (I.A).

• Designing roads to minimum standard necessary to accommodate uses (I.B.2).

• Proper sizing for crossing structures (I.B.5).

• Suitable logging system for topography, soil types and season of operation (II. A. 2).

• Suitable location, size, and number of landings (II. A. 6).

• Skidding operation minimizes compaction (II. C. 1 .b).

• Adequate drainage for landings (II.C.2.b).

• Scarify only to the extent necessary (II. D. 4).

• Equipment operation on suitable slopes only (II. D. 6).

• Cross streams at right angles if practical (III.B.l.a).

• Avoid unimproved stream crossings (III.B.2).

• Minimize stream channel disturbance (III.C.l).

• Minimum cover for culverts provided (III.C.5)

• Adequate storage and disposal for fuel, waste oil (V.A).

Logging contractors attended 31 out of the 44 audits. Team members felt it was beneficial for
all if contractors attended.

Audit team members noticed a range of potential or actual water quality impacts that are not
reflected in the results. Both grazing and mining impacts were observed at several audit sites.
In some cases, road erosion problems were the result of other land uses.

-27-

Streamside Management Zones

The questionnaire used in the 1994 BMP audits to evaluate the application and implementation
of requirements of the SMZ law and rules were dropped from the 1996 audits. The
questionnaire was replaced with nine questions that were put into a rating form. These
questions were taken from the SMZ/BMP’s and the SMZ rules. The question format was the
same as the 47 BMP questions with a 5-point rating scale. These questions did not constitute a
DNRC enforcement action. Audit team members evaluated departures based on their best
professional judgement.

Photo #8. Audit Team Evaluating SMZ.

Both the law and the rules were applicable to 42 of the 44 sites. The remaining two sites did
not have stream channels that meet the definition of a stream contained in the law. Both the
law and the rules were applicable to some phase of the harvest operation (road construction,
harvest or slash disposal) on all of these 42 sites.

Harvest of trees within the SMZ occurred on 24 of the 44 sites. Four pre-approved alternative
practices, as allowed under the rules and four DNRC approved site specific alternative
practices were utilized on six of the sites evaluated.

A total of 29 departures from either the law or rules were noted on 18 of the 42 applicable
sites. SMZ departures occurred on 83% of the applicable (NIP) sites, 40% of the applicable
state sites, 33% of the applicable (FED) sites and 15% of the applicable (IND) sites (see Table
9) and Fig 3.

-28-

Table 9

SMZ Departures by Ownership Group

Ownership Group

Number of Sites
Evaluated

Number of Sites
With Departures

Total Number
of Departures

Federal

12

4

6

Industrial

13

2

2

NIP

12

10

19

State

5

2

2

All Sites

42

18

29

% of SITES W/ AT LEAST ONE SMZ DEPARTURE

By Ownership

100

(A

£ 80
c/)

I 60
<0
o

% 40

Cl

<

o 20

55

0

DNRC FED IND NIP ALL

Figure 3

SMZ maintained/properly marked was the most common departure and occurred on 10 of the
sites. Other practices with the most departures included clearcutting within the SMZ or failure
to meet the retention tree requirements, sidecasting, broadcast burning, and logging slash
deposited in streams (see Table 10). There were seven instances of equipment operation in the
SMZ.

-29-

Table 10

SMZ Departures by Practice

Practice

ft Departures

Broadcast Burning in SMZ

1

Equipment Operation in SMZ

7

Clearcutting/Retention Tree Requirements

3

Sidecasting into Stream

3

Slash Deposited into Stream

5

SMZ Maintained/Properly Marked

10

Total

29

Failure to mark or properly locate SMZ boundaries was observed on 10 sites. Improper SMZ
delineations alone cannot be considered to be the sole cause of other departures at these sites.
SMZ departures were noted on eight sites with properly located and marked SMZ boundaries.
Three sites had no departures despite incorrect SMZ delineation. However, incorrect SMZ
boundary delineation was judged to be a factor in contributing to 7 other departures at 6 sites.

Photo #9. Audit Team Member Measuring Slope for SMZ Boundary.

Although 29 departures were noted on 18 of the sites, most of the departures were minor in
extent and produced no discernible impacts. For example, 6 of the 7 departures due to
equipment operation in the SMZ consisted of one or two skid trails that were not located in
immediate proximity to the stream. Audit teams determined that all but 8 of the SMZ
departures were still effective in protecting water quality.

-30-

Results by Ownership Group

There are notable differences among the ownership groups in their application and
effectiveness of all BMPs. Ratings for application of BMPs were as follows: State lands
ranked highest among all ownership groups. Industrial lands ranked second; Federal (USFS )
lands ranked 3rd, while non-industrial private ranked 4th in BMP application. In BMP
effectiveness, the results for Industry (IND) and State lands were similar, and both ranked
higher than the other ownership groups. Federal sites ranked third and NIP sites were ranked
fourth in effectiveness. See Figure 2. Non-Industrial lands exhibited the highest average
number of departures per site, however, this number is slightly lower than the 1994 average.

Comparison with Previous Audits

The 1996 audits were conducted in a manner directly comparable to the 1990, 1992 and 1994
audits. The same selection criteria and rating format were used. Most audit team members
had participated in the 1990, 1992 and 1994 audits. Earlier audits, conducted in 1988 and
1989, were similar, but had differences in design and format. The most accurate comparison
is among the 1990, 1992, 1994 and 1996 audits.

The 1996 audits show overall improvement in the application and effectiveness of BMPs when
compared with the 1990, 1992 and 1994 results. See Table 11 for a comparison of the 1990,
1992, 1994 and 1996 results.

Table 11

Comparison of BMP Audit Results: 1994 vs. 1992 and 1990

1996

1994

1992

1990

Application of Practices that Meet or Exceed BMP
Requirements

92%

91%

87%

78%

Application of High Risk Practices that Meet or
Exceed BMP Requirements

81%

79%

72%

53%

Number of Sites with At Least One Major
Departure in BMP Application.

12 of 44
(27%)

17 of 46
(37%)

20 of 46
(43%)

27 of 44
(61%)

Average Number of Departures in BMP
Application, Per Site.

3.0

3.9

5.6

9

Number of Practices Providing Adequate
Protection

94%

93%

90%

80%

Number of High Risk Practices Providing
Adequate Protection.

86%

83%

77%

58%

Number of Sites Having at Least One Major
Temporary or Minor Prolonged Impact

15 of 44
(34%)

13 of 46
(28%)

17 of 46
(37%)

28 of 44
(64%)

Average Number of Impacts Per Site

2.3

3

4.6

8

- 31 -

Non-industrial private lands showed the most improvement over the last four cycles of audits.
In 1990, NIP sites averaged 15 impacts per site. In 1992, NIP sites averaged 10 impacts per
site. In 1994, NIP sites averaged 4 impacts per site. In 1996, NIP sites averaged less than 4
impacts per site. Minor/temporary impacts were reduced, and there were no gross neglect
departures or major/prolonged impacts on NIP sites in 1996.

Federal sites showed increases in both application and effectiveness of practices rated in 1996.
Federal lands also showed decreases in the percentage of sites with minor and major
departures, as well as decreases in the percentages of major /temporary, minor/prolonged
impacts. There were no gross neglect departures or major/prolonged impacts on Federal sites
in 1996.

Industrial lands continued to show improvement. Seven of the Industrial sites had
major/ temporary or minor/prolonged impacts in 1996. In 1994, 21% of the sites had such
impacts, while in 1992 the percentage was 31% and 69% in 1990. There were no gross
neglect departures or major/prolonged impacts on Industrial sites in 1996.

State lands showed decreases in the percentage of practices rated with minor departures and
minor/ temporary impacts in 1996. State lands also showed increases in both application and
effectiveness earning the highest ratings of 96% and 98% respectively. State lands were the
only ownership group that had no major departures or major/temporary, minor/prolonged
impacts in 1996.

Figure 4 displays BMP application results of 4 forestry BMP audits conducted in Montana.

Comparison of BMP Application

Major Departures Minor Departures Adequate or Exceeds

□ 1990

1992

1994 j I 1996

Figure 4 Major Departures Are Practices with an Application Rating <3.

Minor Departures Are Practices with an Application Rating of 3 .
Adequate or Exceeds Are Practices with an Application Rating >3.

- 32 -

Figure 5 displays BMP effectiveness results of 4 forestry BMP audits conducted in Montana.

Comparison of BMP Effectiveness

Major Impacts Minor Impacts Adequate Protection

|J 1990 H] 1992 gg 1994 1996

Figure 5 Major Impacts Are Practices with an Effectiveness Rating <3.

Minor Impacts Are Practices with an Effectiveness Rating of 3.

Adequate Protection Is a Practice with an Effectiveness Rating >3.

The 1996 audit ratings showed improvement over the 1990, 1992 and 1994 ratings when one
looks at the percent of sites with major departures or impacts, as in Figure 6.

Sites with Major Departures or Impacts

1990

1992

1994 : | 1996

Figure 6. Major Departures Are Practices with an Application Rating of 1 or 2.

Major Impacts Are Practices with an Effectiveness Rating of 1 or 2.

-33-

The 1996 audits had fewer major departures and impacts per site than the 1990, 1992 and
1994 audits did. See Figures 7. & 8. Impacts/departures per site are expressed as a
percentage of rated practices per site, in order to account for differences in the average
number of rated practices per site between study years.

Average # of Departures per Site

1990 1992 | 1994 1996

Figure 7. Major Departures are Practices with an Application Rating <3.

Minor Departures are Practices with an Application Rating of 3 .

Average # of Impacts per Site

1990

H 1992

1994 j_J 1996

Figure 8. Major Impacts Are Practices with an Effectiveness Rating of <3.

Minor Impacts Are Practices with an Effectiveness Rating of 3.

-34-

RECOMMENDATIONS FROM AUDIT TEAM MEMBERS

• Continue the interdisciplinary forestry BMP audits. The audit process has been
fundamental in educating and making people aware of BMP requirements. Conduct
the audits every two years.

• Continue to evaluate implementation of the SMZ law and rules.

• Update the BMP audit process to include site selection processes, clarification and
refinement of the BMP’s and the audit form.

• Encourage the development of a mechanism to monitor the effectiveness of BMP’s.

• Recognize the need to formally involve NIP landowners into the entire BMP audit
process.

• Encourage all ownership groups to continue commitment, involvement and support in
the audit process.

• Continue educating loggers, landowners, and foresters, concentrating on problem
areas documented through BMP audits. Lack of adequate drainage on new and
existing roads continues to be the primary impact to water quality. BMP education
should emphasize the need for meeting road drainage BMPs.

• Actively encourage the site’s owners and logging contractors to attend the audit. The
Montana Logging Association and the Montana Wood Products Association will assist
DNRC in notifying contractors. At a minimum, give contractors a copy of the audit
results for their sites.

• The team leader should encourage the landowner and contractor and, if needed in the
case of NIP lands, the DNRC Service Forester, to develop a remedy for problems
noted. An audit team member will assist if necessary, especially to identify
problems. Industry groups, such as MLA and MWPA may participate as needed.

• Continue funding volunteer audit team members.

• Institute a similar BMP audit process for other land uses, including mining, livestock
grazing, agriculture and subdivision development.

- 35 -

References

Ehinger W. and D. Potts. 1990. On-site Assessment of "Best Management Practices as an
Indicator of Cumulative Watershed Effects in the Flathead Basin." Flathead Basin
Water Quality and Fisheries Cooperative. University of Montana School of Forestry.
Missoula, Montana 137 pp.

Frank, Gary. 1994. Montana Forestry Best Management Practices Implementation Monitoring
— The 1994 Forestry BMP Audits Final Report. Montana Department of State
Lands, Forestry Division, Missoula, MT. 30pp.

Idaho Dept, of Health and Welfare. 1989, Final Report: Forest Practices Water Quality

Audit 1988. Idaho DHW, Division of Environmental Quality. Boise, Idaho, 26 pp.

Montana Dept, of Health and Environmental Sciences. 1990. Montana Water Quality, 1990.
Montana DHES, Water Quality Bureau. Helena, MT. 21 pp.

National Council of the Paper Industry for Air and Stream Improvement (NCASI). 1988.
Procedures for Assessing the Effectiveness of Best Management Practices in
Protecting Water and Stream Quality Associated with Managed Forests. NCASI
Technical Bulletin 538. January, 1988. 23 pp.

Schultz, Bill. 1990. Montana Forestry Best Management Practices Implementation

Monitoring - The 1990 Forestry BMP Audits Final Report. Montana Department of
State Lands, Forestry Division, Missoula, MT. 32p.

Schultz, Bill. 1992. Montana Forestry Best Management Practices Implementation

Monitoring — The 1992 Forestry BMP Audits Final Report. Montana Department of
State Lands, Forestry Division, Missoula, MT. 32p.

Zackheim, Hugh. 1988. House Joint Resolution 49-Forest Practices and Watershed Effects:
Final Report. Montana Environmental Quality Council. Helena, MT. 95 pp.

-36-

APPENDIX A

5/96

1996 BMP FIELD AUDITS
BMP AUDIT TEAM MEMBERS

EXPERTISE AUDIT TEAM

NORTHWEST WEST CENTRAL SOUTHWEST /EAST

| Fisheries

+ S. Rumsey, DFWP

+ D. Workman, DFWP*

+ J.

Brammer, DFWP

+(T. Weaver, DFWP)

+(C. Clancey, DFWP)

(D.

Skarr DFWP)

+(P. Van Eimeren, FS)

Hydrology

+ S. Johnson, USFS

+ G. Frank, DNRC

+ S .

Tralles, DEQ\WQD*

+ (B . Sugden, PCT)

(P. Callahan, DNRC)

(B.

Stuart, USFS)

(J. Whittingham, BLM)

Soils

+ J. Collins, DNRC

S. Barndt, USFS

+ H.

Hunter, PVT

(B. Basko, USFS)

+ (T. Wiersum, NRCS)

+ (B.

Logar, NRCS)

Forestry

+ R. Hudson, PVT*

+ D. Wick, PCT

+ G.

Sanders , PML

+ ( L . Coryell, USFS)

+(P. Davis, PCT)

+ (S.

Flynn, LP)

Eng. /Roads

+ V. Anderson, PCT

+ ( Jim Saubier, USFS)

+ J.

Marshik, USFS

+ ( F . McCubbins, STZ)

+(E. Applekamp, USFS)

+ (S.

Anderson, PVT)

Conservation

+ Dan Paschke, TU

+ B. Benson, CFC

+ P.

Hackley, EIC

+ (R . Ash, Audub.)

(M Roy, NWF)

+ (C.

Jones, EIC)

Legend:

REDLINE Denotes Team Leader.

( ) Denotes Alternate.

+ Denotes Prior BMP Audit Team Experience.
* Denotes Alternate Team Leader

A-l

APPENDIX B

1996 BMP FIELD AUDITS
RISK RATING GUIDE

MONTANA “RISK” MATRIX (3/91)

TYPE

CLEAR-CUT

PARTIAL CUT

SITE PREP

ROADS

SLOPE

SOIL

T E

RS

P s

F S

T E

R S

P S

FS

M P

B B

0

p

T

EROD.

RQ

U K

A U

u u

R Q

U K

A U

UU

A I

R U

T

E

E

AU

B I

R S

L S

A U

B I

R S

LS

C L

D R

H

R

M

C 1

B D

T P

L P

C 1

B D

T P

L P

H E

C N

E

M

P

K P

E

I

K P

E

I

I IS

A

R

E

R

A

E

R

A

N C

S

D

L

D

L

E A

T

R

0-5%

H

2

2

2

1

2**

2**

1

1

2

1

1

2**

3

M

2

1

1

1**

2

1**

1

1

2**

1

1

i

1

L

1

1

1

1

1

t

1

1

2

1

1

t

1

5-20%

H

4

3

2

1

4*

3

2

1

4

2

1

3

4

M

3

2

1

1

3*

2

1

1

3

2

1

2

3

L

2

2

1

1

2*

2*

1

1

2

1

1

2

2

20-40%

H

5

5

4*

2

5*

5*

3**

1

5

3**

1

4

5

M

4*

4

3

1

3

3

2

1

4

3

1

3

4*

L

3*

2

2

1

2

2

2

1

3

2

1

3*

3

1 >40%

H

5

5

4

2

5

5

4

2

5

4

1

5

5

M

5

5

4

2*

5

5

3

1

5

4

1

5

5

L

4

4

3

1

4

4

2

1

4

3*

1

4

4

(* Indicates Mean Value Used, ** Final Group Consensus Adjustment for Internal Consistency)

MONTANA EROSION-IMPACT MATRIX

From: “Management Guidelines for Riparian Forests” by Robert Pfister and Kim Sherwood. Flathead Basin Forest Practices
Water Quality and Fisheries Cooperative Program.

LEGEND
1 = LOW RISK

2-3 = MODERATE RISK

4-5 = HIGH RISK

SOIL ERODIBILITY

HIGH ERODIBILITY
GRANITICS
ALLUVIUM
LACUSTRINE

MODERATE ERODIBILITY
SCHIST

SOFT/HARD SEDIMENTS
BASIC IGNEOUS

LOW ERODIBILITY

ARGILLITE/QUARTZITE
METAMORPHIC (BELT)

HIGH RISK DUE TO RIPARIAN HARVEST

“HIGH” risk will be assigned to sales with logging in riparian zones along streams. Riparian zones are located between
aquatic and terrestrial environments are identified by distinct vegetation that requires or tolerates free or unbound water.
This includes but is not limited to the following habitat types: ABLA/CACA, (all phases), ABLA/APHO,
PICEA/EQAR, THPL/OPHO.

B-l

APPENDIX C

DS-49

BMP FIELD AUDITS
SITE INFORMATION

Site Number:

Meets Selection Criteria:
High Hazard:

Site Name:
Owner :

Legal Description:

Primary Drainage :

Stream Within 200 Ft.? Y / N

Unit Size:

Road Construction:

Road Reconstruction:

Slash Disposal Complete:

Logging Method:

Slope: 0-5% ; 5-20%

Parent Material :

County:

Month/Year Harvested:

Name: Bankfull Width:

Volume Removed:

Length:

Length:

Method:

20-40% ; 40% +

Soil Erodibility: High Medium Low

Harvest in Riparian: Y / N

Stream Class :

Comments :

FIELD AUDIT

Date :

Team Leader/Recorder:
Team Members :

Observers Present :

RATING GUIDE

APPLICATION

5--0PERATI0N EXCEEDS REQUIREMENTS OF BMP
4--0PERATI0N MEETS REQUIREMENTS OF BMP
3- -MINOR DEPARTURE FROM BMP
2- -MAJOR DEPARTURE FROM BMP
1 - -GROSS NEGLECT OF BMP

EFFECTIVENESS

5- - IMPROVED PROTECTION OF SOIL AND WATER
RESOURCES OVER PRE-PROJECT CONDITION
4- -ADEQUATE PROTECTION OF SOIL AND WATER
RESOURCES

3- -MI NOR AND TEMPORARY IMPACTS ON SOIL &

WATER RESOURCES

2- -MAJOR AND TEMPORARY OR MINOR AND PROLONGED
IMPACTS ON SOIL AND WATER RESOURCES.

1- -MAJOR AND PROLONGED IMPACTS ON SOIL AND WATER
RESOURCES.

DEFINITIONS (BY EXAMPLE ) :

ADEQUATE- -SMALL AMOUNT OF MATERIAL ERODED;
MATERIAL DOES NOT REACH DRAWS, CHANNELS, OR
FLOODPLAIN.

MIN0R--ER0SI0N AND DELIVERY OF MATERIAL TO DRAWS
BUT NOT STREAM.

MAJOR- -EROSION AND SUBSEQUENT DELIVERY OF
SEDIMENT TO STREAM OR ANNUAL FLOODPLAIN.
TEMPORARY-- IMPACTS LASTING ONE YEAR OR LESS; NO
MORE THAN ONE RUNOFF SEASON.

PROLONGED-- IMPACTS LASTING MORE THAN ONE YEAR.

NR- -NOT REVIEWED NA- -NOT APPLICABLE

R: 10/96

C-l

MONTANA FOREST PRACTICES REVIEW WORKSHEET

BMPs Applicable to:

+ New Road Construction
* Existing Roads
► Reconstruction

RECOMMENDED BEST
MANAGEMENT PRACTICES

APPLICABLE TO SITE (Y/N)
| APPLICATION

I EFFECTIVENESS

COMMENTS

SECTION I- -ROADS

► +

la .

lb.

3 .

4 .

5 .

6a.

6b .

ROAD PLANNING & LOCATION
SECTION I .A.

MINIMIZE NUMBER OF ROADS
NECESSARY.

USE EXISTING ROADS UNLESS
AGGRAVATE EROSION.

AVOID LONG, SUSTAINED, STEEP
ROAD GRADES.

LOCATIONS AVOID HIGH HAZARD
SITES (I.E., WET AREAS AND
UNSTABLE SLOPES) .

ADEQUATE SMZ BETWEEN ROAD AND
STREAM CHANNELS WHERE ROADS
ARE LOCATED ALONG STREAMS.

MINIMIZE NUMBER OF STREAM
CROSSINGS. NUMBER .

CHOOSE STABLE STREAM
CROSSING SITES.

ROAD DESIGN
SECTION I.B.

►+ 2. DESIGN ROADS TO MINIMUM

STANDARD NECESSARY TO
ACCOMMODATE ANTICIPATED USES

+ 4 . VARY ROAD GRADE TO REDUCE

CONCENTRATED DRAINAGE.

+► 5. PROPER SIZING FOR CROSSING

STRUCTURES .

+ ►* 1

DRAINAGE FROM ROAD SURFACE
SECTION I.C.

PROVIDE ADEQUATE ROAD SURFACE
DRAINAGE FOR ALL ROADS.

R: 10/96

C-2

+ New Road Construction; * Existing Roads; ► Reconstruction

I .D.

APPLICABLE TO SITE (Y/N)
| APPLICATION
| | EFFECTIVENESS

RECOMMENDED BEST I

+ ►

2 .

MANAGEMENT PRACTICES
SKEW DITCH RELIEF CULVERTS.

1

1

1

COMMENTS

+►*

4 .

PROVIDE ENERGY DISSIPATORS AT
DRAINAGE STRUCTURE OUTLETS
WHERE NEEDED.

+ ►*

6 .

ROUTE ROAD DRAINAGE THROUGH
ADEQUATE FILTRATION ZONES
BEFORE ENTERING A STREAM.

CONS TRUCT I ON / RE CONS TRUCT I ON
SECTION I.D.

+ ►

2 .

STABILIZE ERODIBLE SOILS
(I.E., SEEDING, BENCHING,
MULCHING) .

+ ►

3 .

SLASH FILTER WINDROWS
INSTALLED .

+ ►

5 .

CUT AND FILL SLOPES AT STABLE
ANGLES. SLOPE RATIO:

+ ►

6 .

AVOID INCORPORATING WOODY
DEBRIS IN ROAD FILL.

+ ►

8 .

EXCESS MATERIALS (WASTE)
PLACED IN LOCATIONS THAT
AVOID ENTERING STREAM.

+ ►

9 .

SEDIMENT FROM BORROW PITS AND
GRAVEL PITS MINIMIZED.

►

10

RECONSTRUCT ONLY TO THE
EXTENT NECESSARY TO PROVIDE
ADEQUATE DRAINAGE AND SAFETY.

ROAD MAINTENANCE
SECTION I.E.

+►*

1

GRADE ROADS IF NECESSARY
TO MAINTAIN DRAINAGE.

+►*

2

MAINTAIN EROSION CONTROL
FEATURES (DIPS, DITCHES AND
CULVERTS FUNCTIONAL) .

★

3

AVOID CUTTING THE TOE OF
CUT SLOPES.

+ ►*

6

AVOID USE OF ROADS DURING WET
PERIODS AND SPRING BREAKUP.

+ ►*

8

ABANDONED ROADS IN CONDITION
TO PROVIDE ADEQUATE DRAINAGE
WITHOUT FURTHER MAINTENANCE.

R: 10/96

C-3

+ New Road Construction; * Existing Roads; ► Reconstruction

I.D.

RECOMMENDED BEST
MANAGEMENT PRACTICES

APPLICABLE TO SITE (Y/N)

| APPLICATION

| EFFECTIVENESS

! ! | COMMENTS

SECTION II- -TIMBER HARVESTING

HARVEST DESIGN
SECTION I I. A.

2 .

SUITABLE LOGGING SYSTEM FOR
TOPOGRAPHY, SOIL TYPE AND
SEASON OF OPERATION.

5 .

DESIGN AND LOCATE SKID TRAILS TO
AVOID CONCENTRATING RUNOFF.

6 .

SUITABLE LOCATION, SIZE, AND
NUMBER OF LANDINGS.

OTHER HARVESTING ACTIVITIES
SECTION II. C.

la

SKIDDING OPERATION MINIMIZES SOIL
COMPACTION AND DISPLACEMENT.

lb.

AVOID TRACTOR SKIDDING ON UNSTABLE
SLOPES AND SLOPES THAT EXCEED
40% UNLESS NOT CAUSING
EXCESSIVE EROSION.

2a.

ADEQUATE DRAINAGE FOR TEMPORARY
ROADS, SKID TRAILS AND FIRE LINES.

2b.

ADEQUATE DRAINAGE FOR LANDINGS.

SLASH TREATMENT AND SITE PREPARATION

SECTION II. D.

2 .

BRUSH BLADES USED ON DOZERS.

4 .

SCARIFY ONLY TO THE EXTENT
NECESSARY TO MEET REFORESTATION
OBJECTIVE .

5 .

ACTIVITIES LIMITED TO FROZEN OR
DRY CONDITIONS TO MINIMIZE SOIL
COMPACTION AND DISPLACEMENT.

6 .

EQUIPMENT OPERATIONS ON SUITABLE
SLOPES ONLY.

9 .

LIMIT WATER QUALITY IMPACT OF
PRESCRIBED FIRE.

R: 10/96

C-4

+ New Road Construction; * Existing Roads; ► Reconstruction

I .D.

APPLICABLE TO SITE (Y/N)

| APPLICATION

| EFFECTIVENESS

RECOMMENDED BEST j j j

MANAGEMENT PRACTICES | j | COMMENTS

SECTION III- -STREAM CROSSINGS

LEGAL REQUIREMENTS
SECTION III .A.

► + 1 . PROPER PERMITS FOR

STREAM CROSSINGS.

DESIGN CONSIDERATIONS
SECTION III.B.

► +

la .

CROSS STREAMS AT RIGHT
ANGLES, IF PRACTICAL.

► +

lb.

DIRECT ROAD DRAINAGE AWAY FROM
STREAM CROSSING SITE.

► +

2 .

AVOID UNIMPROVED STREAM
CROSSINGS .

INSTALLATION OF STREAM CROSSINGS
SECTION III.C.

► + 1. MINIMIZE STREAM CHANNEL

DISTURBANCE.

► + 2 . CULVERTS CONFORM TO NATURAL

STREAMBED AND SLOPE.

►+ 3. PREVENT EROSION OF CULVERT

AND BRIDGE FILLS (I.E., ARMOR
INLET AND OUTLET.

► + 5 . MINIMUM COVER FOR CULVERTS

PROVIDED .

SECTION V--HAZ£

lRDC

US

SUE

STANCES

GENERAL
SECTION V . A .

2 . ADEQUATE STORAGE AND DISPOSAL
FOR FUEL, SHOP DEBRIS, AND
WASTE OIL.

WERE ANY CWE ASSESSMENTS OR WATERSHED
ANALYSIS INCLUDED IN THE TIMBER HARVEST
PLANNING?

RESPONSE :

IF YES, WHAT TYPE AND LEVEL OF ANALYSIS
WAS CARRIED OUT (I.E., MONITORING,
SCREENING, CWE INDICES, INTERDISCIPLINARY
TEAMS, ASSESSMENTS OF CHANGING GEOMORPHIC
PROCESSES, A COMBINATION OF TWO OR MORE.)

R: 10/96

C-5

+ New Road Construction; * Existing Roads; ► Reconstruction

I .D.

APPLICABLE TO SITE (Y/N)

| APPLICATION

| EFFECTIVENESS

RECOMMENDED BEST | j |

MANAGEMENT PRACTICES | | | COMMENTS

SECTION II- -TIMBER HARVESTING

HARVEST DESIGN
SECTION I I. A.

2 .

SUITABLE LOGGING SYSTEM FOR
TOPOGRAPHY, SOIL TYPE AND
SEASON OF OPERATION.

5 .

DESIGN AND LOCATE SKID TRAILS TO
AVOID CONCENTRATING RUNOFF.

6 .

SUITABLE LOCATION, SIZE, AND
NUMBER OF LANDINGS.

OTHER HARVESTING ACTIVITIES
SECTION II. C.

la

SKIDDING OPERATION MINIMIZES SOIL
COMPACTION AND DISPLACEMENT.

lb.

AVOID TRACTOR SKIDDING ON UNSTABLE
SLOPES AND SLOPES THAT EXCEED
40% UNLESS NOT CAUSING
EXCESSIVE EROSION.

2a.

ADEQUATE DRAINAGE FOR TEMPORARY
ROADS, SKID TRAILS AND FIRE LINES.

2b.

ADEQUATE DRAINAGE FOR LANDINGS .

SLASH TREATMENT AND SITE PREPARATION

SECTION II. D.

2 .

BRUSH BLADES USED ON DOZERS.

4 .

SCARIFY ONLY TO THE EXTENT
NECESSARY TO MEET REFORESTATION
OBJECTIVE .

5 .

ACTIVITIES LIMITED TO FROZEN OR
DRY CONDITIONS TO MINIMIZE SOIL
COMPACTION AND DISPLACEMENT.

6 .

EQUIPMENT OPERATIONS ON SUITABLE
SLOPES ONLY.

9 .

LIMIT WATER QUALITY IMPACT OF
PRESCRIBED FIRE.

R: 10/96

C-4

+ New Road Construction; * Existing Roads; ► Reconstruction

I .D.

APPLICABLE TO SITE (Y/N)
| APPLICATION

I EFFECTIVENESS

RECOMMENDED BEST
MANAGEMENT PRACTICES

COMMENTS

SECTION III- -STREAM CROSSINGS

► +

1 .

LEGAL REQUIREMENTS
SECTION III .A.

PROPER PERMITS FOR
STREAM CROSSINGS.

DESIGN CONSIDERATIONS
SECTION III.B.

► +

la .

CROSS STREAMS AT RIGHT
ANGLES, IF PRACTICAL.

► +

lb.

DIRECT ROAD DRAINAGE AWAY FROM
STREAM CROSSING SITE.

► +

2 .

AVOID UNIMPROVED STREAM
CROSSINGS .

INSTALLATION OF STREAM CROSSINGS
SECTION III.C.

► + 1. MINIMIZE STREAM CHANNEL

DISTURBANCE.

► + 2 . CULVERTS CONFORM TO NATURAL

STREAMBED AND SLOPE.

►+ 3. PREVENT EROSION OF CULVERT

AND BRIDGE FILLS (I.E., ARMOR
INLET AND OUTLET.

► + 5 . MINIMUM COVER FOR CULVERTS

PROVIDED .

SECTION V--HAZ£

iRDC

US

SUE

STANCES

GENERAL
SECTION V . A .

2 . ADEQUATE STORAGE AND DISPOSAL
FOR FUEL, SHOP DEBRIS, AND
WASTE OIL.

WERE ANY CWE ASSESSMENTS OR WATERSHED
ANALYSIS INCLUDED IN THE TIMBER HARVEST
PLANNING?

RESPONSE :

IF YES, WHAT TYPE AND LEVEL OF ANALYSIS
WAS CARRIED OUT (I.E., MONITORING,
SCREENING, CWE INDICES, INTERDISCIPLINARY
TEAMS, ASSESSMENTS OF CHANGING GEOMORPHIC
PROCESSES, A COMBINATION OF TWO OR MORE.)

R: 10/96

C-5

+ New Road Construction; * Existing Roads; ► Reconstruction

I .D.

STREAMS IDE MANAGEMENT ZONE SITE INFORMATION

ARE SMZ RULES APPLICABLE? (EFF. 3/15/93) Y/N

WERE ANY PRE -APPROVED ALTERNATIVE
PRACTICES UTILIZED?

(* DENOTES PRACTICES THAT APPLY.)

Y/N (LIST APPLIED PRACTICES)

WERE ANY DNRC -APPROVED SITE-SPECIFIC
ALTERNATIVE PRACTICES IMPLEMENTED IN THE
HARVEST ACTIVITIES?

(** DENOTES PRACTICES THAT APPLY.)

Y/N (LIST APPLIED PRACTICES)

APPLICABLE TO SITE (Y/N)
| APPLICATION
! I EFFECTIVENESS

RECOMMENDED BEST | |

MANAGEMENT PRACTICES | j | COMMENTS

1. ADEQUATE SMZ WIDTH MAINTAINED AND

PROPERLY MARKED? AVG . WIDTH

2. EXCLUSION OF BROADCAST BURNING IN

SMZ . **

3 . SMZ RETENTION TREE REQUIREMENTS MET .

(# OF TREES, REPRESENTATIVE OF
PRE -HARVEST STAND, FAVOR BANK -EDGE
AND LEANING TREES, SHRUBS AND
SUBMERCHANTABLE) **

4. EXCLUSION OF EQUIPMENT OPERATION IN

SMZ EXCEPT ON ESTABLISHED ROADS.*

5 . EXCLUDE CONSTRUCTION OF ROADS IN THE

SMZ EXCEPT WHEN NECESSARY TO CROSS A
STREAM OR WETLAND.**

6. EXCLUSION OF ROAD FILL MATERIAL

DEPOSITED IN SMZ EXCEPT AS NEEDED TO
CONSTRUCT CROSSINGS.

7. EXCLUSION OF SIDE-CASTING OF ROAD

MATERIAL INTO A STREAM, LAKE, WETLAND
OR OTHER BODY OF WATER DURING ROAD
MAINTENANCE .

8. EXCLUSION OF SLASH IN STREAMS, LAKES

OR OTHER BODIES OF WATER.**

9. EXCLUDE THE HANDLING, STORAGE,

APPLICATION OR DISPOSAL OF HAZARDOUS
OR TOXIC MATERIALS IN THE SMZ IN A
MANNER THAT POLLUTES OR CAUSES DAMAGE
OR INJURY.

ADDITIONAL COMMENTS :

C-6

APPENDIX D

(

RATIONALE FOR THE RATING SYSTEM
POST HARVEST EVALUATION

D-l

APPENDIX E

1996 BMP FIELD AUDITS
SITES PICKED FOR AUDITS
BY OWNERSHIP GROUP

Number

Sale Name

Location

Countv

Owner

Team

DNRC-1

Six Mile

S 1 2

T15N-R22W

Msla

State

WC

DNRC-2

Tom Miner

S16

T08S-R06E

Gallatin

State

SW

DNRC-3

Werner/Taylor

S30

T33N-R22W

Flthd

State

NW

DNRC-4

Deer Park

S36

T15N-R11W

Powel l

State

WC

DNRC-5

Clear Creek

S36

T25N-R25W

Flthd

State

SW

FED-1

Upper Cabin

S11

T07N-R04E

Brdwtr

USFS

SW

FED-2

Thompson View

S16

T26N-R26W

Flthd

USFS

NW

FED-3

Deep Gi Iman

S12

T13N-R22W

Msla

USFS

WC

FED-4

Truman Emmons

S 1 2

T26N-R22W

Flthd

USFS

NW

FED-5

Saw Mill

S24

T06N-R14W

Grani te

USFS

SW

FED-6

Deadhorse

S03

T10N-R10E

Meagher

USFS

SW

FED-7

Slate Point

SOI

T02S-R22W

Raval l i

USFS

WC

FED-8

Tangled Again

S22

T31N-R27W

Lincoln

USFS

NW

FED-9

Fourth Cyclone

S07

T34N-R33W

Lincoln

USFS

NW

FED-10

31 Special

S05

T34N-R33W

Lincoln

USFS

NW

FED-11

Lewis Gulch

S09

T04S-R13E

Swtgrass

USFS

SW

FED-12

Upper Mantrap

S29

T25N-R28W

Sanders

USFS

WC

IND-1

Porter Creek

S21

T27N-R23W

Flthd

PCT

NW

IND-2

Ashley Mtn.

S17

T29N-R24W

Flthd

PCT

NW

IND-3

Bear 21

S21

T04S-R05E

Gallatin

BSL

SW

IND-4

Action Jackson

S25

T01S-R07E

Gallatin

BSL

SW

IND-5

Mill Tevis

S09

T11N-R21W

Msla

PCT

WC

IND-6

Olney Face

S27

T33N-R23W

Flthd

PCT

NW

IND-7

Graves Thin

SOI

T12N-R23W

Msla

PCT

WC

IND-8

Pearson Green

S09

T14N-R13W

Powel l

PCT

WC

IND-9

Walters #1

SOI

T27N-R25W

Flthd

SLL

WC

IND-10

C&J Kids

S27

T14N-R13W

Powel l

PCT

WC

IND-11

33 Owls

S33

T26N-R29W

Lincoln

PCT

NW

IND-12

Carrigan Camp

S09

T32N-R31W

Lincoln

PCT

NW

IND-13

Kelsey Creek

S32

T31N-R26W

Lincoln

PCT

NW

IND-14

Deerhorn

S31

T23N-R27W

Sanders

PCT

WC

NIP-1

Bald Butte

S16

T11N-R06W

L&C

NIP

SW

NIP-2

Latham Gulch

S33

T10N-R06W

Powel l

NIP

SW

NIP-3

Rock Creek

S05

T04N-R15W

Grani te

NIP

SW

NIP-4

Wolf Mtn.

S14

T06S-R37E

Big Horn

NIP

SW

NIP-5

Alaska Bench

S27

T13N-R20E

Fergus

NIP

SW

NIP-6

Goodman Creek

S12

T03N-R43E

Rosebud

NIP

SW

NIP-7

Mud Gulch

S 1 4

T14N-R03E

Meagher

NIP

SW

NIP-8

Sleeping Child

SOI

T03N-R19W

Raval l i

NIP

WC

NIP-9

Blackfoot

S25

T14N-R10W

Powel l

NIP

WC

NIP-10

St i l Iwater

S29

T32N-R23W

Flthd

NIP

NW

NIP-11

Lion Mtn.

S22

T31N-R22W

Flthd

NIP

NW

NIP-12

Iron Creek

S06

T30N-R33W

Lincoln

NIP

NW

NIP-13

Swamp Creek

S 1 3

T25N-R32W

Sanders

NIP

WC Dropped

NIP-14

McKay Creek

S34

T26N-R32W

Sanders

NIP

WC

NIP-15

Ha If breed

S07

T07N-R26E

Musselshl

NIP

SW Dropped

E-l

APPENDIX F

1996 BMP RATINGS BY PRACTICE AND OWNERSHIP GROUP

APPLICATION

EFFECTIVENESS

Practice

Owner

1

2

3

4

5

NR

1

2

3

4 5

NR

ROAD PLANNING

Minimi ze #

DNRC

0

0

0

5

0

0

0

0

0

5 0

0

of Roads

FED

0

0

0

11

0

1

0

0

0

11 0

1

I. A. la

IND

0

0

0

14

0

0

0

0

0

14 0

0

NIP

0

0

0

11

0

2

0

0

0

11 0

2

Total :

0

0

0

41

0

3

0

0

0

41 0

3

Use Existing

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

Roads

FED

0

0

0

11

0

1

0

0

0

11

0

1

I. A. 1b

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

0

13

0

0

0

0

0

13

0

0

Total :

0

0

0

43

0

1

0

0

0

43

0

1

Avoid Long,

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

Steep Grades

FED

0

0

0

10

0

2

0

0

0

10

0

2

I. A. 3

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

0

10

0

3

0

0

0

10

0

3

Total :

0

0

0

37

0

7

0

0

0

37

0

7

Avoid High

DNRC

0

0

0

2

1

2

0

0

0

2

1

2

Hazard Areas

FED

0

0

0

10

0

2

0

0

0

10

0

2

I .A. 4

IND

0

0

0

13

0

1

0

0

0

13

0

1

NIP

0

0

0

11

0

2

0

0

0

11

0

2

Total :

0

0

0

36

1

7

0

0

0

36

1

7

Adequate SMZ

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

Planned

FED

0

0

0

8

0

4

0

0

0

8

0

4

I .A. 5

IND

0

0

0

12

0

2

0

0

0

12

0

2

NIP

0

0

0

10

0

3

0

0

0

10

0

3

Total :

0

0

0

33

0

11

0

0

0

33

0

11

Minimize # of

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

Stream X' ings

FED

0

0

0

8

0

4

0

0

0

8

0

4

I .A. 6a

IND

0

0

0

12

0

2

0

0

0

12

0

2

NIP

0

0

0

7

0

6

0

0

0

7

0

6

Total :

0

0

0

30

0

14

0

0

0

30

0

14

F-l

1996 BMP RATINGS BY PRACTICE AND OWNERSHIP GROUP

Practice

Choose

Stable Stream
Crossing Sites
I .A. 6b

ROAD DESIGN

Minimum Design
Standards
I . B . 2

Vary Grade
for Drainage
I . B .4

Crossings
Properly Sized
I . B . 5

ROAD DRAINAGE

Adequate Sur-
face Drainage
I . C . 1

Skew Relief
Culverts
I . C . 2

APPLICATION EFFECTIVENESS

Owner

1

2

3

4

5

NR

1

2

3

4

5

NR

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

FED

0

0

0

7

0

5

0

0

0

7

0

5

IND

0

0

0

10

0

4

0

0

0

10

0

4

NIP

0

0

0

7

0

6

0

0

0

7

0

6

Total :

0

0

0

27

0

17

0

0

0

27

0

17

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

0

11

0

1

0

0

0

11

0

1

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

2

9

0

2

0

0

1

10

0

2

Total :

0

0

2

39

0

3

0

0

1

40

0

3

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

FED

0

0

0

8

0

4

0

0

0

8

0

4

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

1

10

0

2

0

0

1

10

0

2

Total :

0

0

1

35

0

8

0

0

1

35

0

8

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

0

7

0

5

0

0

0

7

0

5

IND

0

0

0

10

0

4

0

0

0

10

0

4

NIP

0

1

1

5

0

6

0

1

1

15

0

6

Total :

0

1

1

27

0

15

0

1

1

27

0

15

DNRC

0

0

2

3

0

0

0

0

1

4

0

0

FED

0

1

2

9

0

0

0

2

1

9

0

0

IND

0

0

4

10

0

0

0

0

2

12

0

0

NIP

0

0

7

6

0

0

0

0

6

7

0

0

Total :

0

1

15

28

0

0

0

2

10

32

0

0

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

FED

0

0

2

7

0

3

0

0

1

8

0

3

IND

0

0

0

8

0

6

0

0

0

8

0

6

NIP

0

0

3

0

0

10

0

0

2

1

0

10

Total :

0

0

5

18

0

21

0

0

3

20

0

21

F-2

1996 BMP RATINGS BY PRACTICE AND OWNERSHIP GROUP

APPLICATION EFFECTIVENESS

Practice

Owner

1

2

3

4

5

NR

1

2

3

4

5

NR

Energy Dissip.

DNRC

0

0

0

4

0

1

0

0

0

4

0

1

at CMP Outlets

FED

0

0

2

9

0

1

0

0

1

10

0

1

I .C.4

I ND

0

0

0

10

0

4

0

0

0

10

0

4

NIP

0

0

2

7

0

4

0

1

0

8

0

4

Total :

0

0

4

30

0

10

0

1

1

32

0

10

Route Drainage

DNRC

0

0

1

4

0

0

0

0

1

4

0

0

Through SMZ

FED

0

1

2

9

0

0

0

2

1

9

0

0

I .C.6

IND

0

0

2

11

0

1

0

0

2

11

0

1

NIP

0

1

1

8

0

3

0

2

0

8

0

3

Total :

0

2

6

32

0

4

0

4

4

32

0

4

ROAD CONSTRUCTION

Stabi l i ze

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

Erodible Soi Is

FED

0

0

0

11

0

1

0

0

1

10

0

1

I .D.2

IND

0

0

1

13

0

0

0

0

1

13

0

0

NIP

0

1

2

8

0

2

0

0

3

8

0

2

Total :

0

1

3

37

0

3

0

0

5

36

0

3

Slash Filter

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

Windrows

FED

0

0

2

6

0

4

0

0

1

7

0

4

I.D.3

IND

0

1

2

8

0

3

0

1

3

7

0

3

NIP

0

2

5

0

0

6

0

4

3

0

0

6

Total :

0

3

9

17

0

15

0

5

7

17

0

15

Slopes at

DNRC

0

0

1

4

0

0

0

0

1

4

0

0

Stable Angle

FED

0

1

0

9

0

2

0

1

0

9

0

2

I .D.5

IND

0

0

3

11

0

0

0

0

0

14

0

0

NIP

0

2

3

6

0

2

0

2

2

7

0

2

Total :

0

3

7

30

0

4

0

3

3

34

0

4

Clear Veget.

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

Before Const.

FED

0

0

0

9

0

3

0

0

0

9

0

3

I.D.6

IND

0

0

2

12

0

0

0

0

1

13

0

0

NIP

0

0

2

9

0

2

0

0

2

9

0

2

Total :

0

0

4

35

0

5

0

0

3

36

0

5

F-3

1996 BMP RATINGS BY PRACTICE AND OWNERSHIP GROUP

Practice

Overburden
Placement
I .D .8

Sediment From
Borrow Pits
I .D .9

Minimi ze
Reconstructi on
I . D . 1 0

ROAD MAINTENANCE

Grade Roads
for Drainage
I .E . 1

Erosion Control

Functional

I.E.2

Avoid Cutting
Slope Toe
I.E.3

APPLICATION EFFECTIVENESS

Owner

1

2

3

4

5

NR

1

2

3

4

5

NR

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

FED

0

0

1

7

0

4

0

1

0

7

0

4

I ND

0

0

1

10

0

3

0

0

1

10

0

3

NIP

0

1

0

4

0

8

0

1

0

4

0

8

Total :

0

1

2

24

0

17

0

2

1

24

0

17

DNRC

0

0

0

1

0

4

0

0

0

1

0

4

FED

0

0

0

1

0

11

0

0

0

1

0

11

IND

0

0

0

1

0

13

0

0

0

1

0

13

NIP

0

1

0

3

0

9

0

0

1

3

0

9

Total :

0

1

0

6

0

37

0

0

1

6

0

37

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

0

6

1

5

0

0

0

6

1

5

IND

0

0

0

10

0

4

0

0

0

10

0

4

NIP

0

0

0

7

0

6

0

0

0

7

0

6

Total :

0

0

0

28

1

15

0

0

0

28

1

15

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

1

11

0

0

0

0

1

11

0

0

IND

0

0

1

13

0

0

0

0

1

13

0

0

NIP

0

0

1

12

0

0

0

0

0

13

0

0

Total :

0

0

3

41

0

0

0

0

2

42

0

0

DNRC

0

0

2

3

0

0

0

0

2

3

0

0

FED

0

0

2

10

0

0

0

0

2

10

0

0

IND

0

0

2

12

0

0

0

0

0

14

0

0

NIP

0

0

4

7

0

2

0

0

2

9

0

2

Total :

0

0

10

32

0

2

0

0

6

36

0

2

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

1

11

0

0

0

0

0

12

0

0

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

1

11

0

1

0

0

1

11

0

1

Total :

0

0

2

41

0

1

0

0

1

42

0

1

F-4

1996 BMP RATINGS BY PRACTICE AND OWNERSHIP GROUP

APPLICATION EFFECTIVENESS

Practice

Owner

1

2

3

4

5

NR

1

2

3

4

5

NR

Restrict Use

DNRC

0

0

1

4

0

0

0

0

0

5

0

0

When Wet

FED

0

0

0

12

0

0

0

0

0

12

0

0

I.E.6

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

0

13

0

0

0

0

0

13

0

0

Total :

0

0

1

43

0

0

0

0

0

44

0

0

Adequate Drain.

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

on Aband. Roads

FED

0

0

1

2

2

7

0

0

1

4

0

7

I.E.8

IND

0

0

1

2

0

11

0

0

0

3

0

11

NIP

0

0

0

1

0

12

0

0

0

1

0

12

Total :

0

0

2

8

2

32

0

0

1

11

0

32

HARVEST DESIGN

Logging Suits

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

Topography

FED

0

0

1

11

0

0

0

0

1

11

0

0

II .A. 2

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

0

13

0

0

0

0

0

13

0

0

Total :

0

0

1

43

0

0

0

0

1

43

0

0

Skid T rai l

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

Design

FED

0

0

1

11

0

0

0

0

1

11

0

0

II. A. 5

IND

0

0

2

12

0

0

0

0

1

13

0

0

NIP

0

1

0

12

0

0

0

1

0

12

0

0

Total :

0

1

3

40

0

0

0

1

2

41

0

0

Landing Size

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

Location

FED

0

0

0

12

0

0

0

0

0

12

0

0

II .A. 6

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

0

13

0

0

0

0

0

13

0

0

Total :

0

0

0

44

0

0

0

0

0

44

0

0

OTHER HARVEST ACTIVITY

Skid to Min.

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

Displacing Soil

FED

0

1

0

11

0

0

0

1

0

11

0

0

Il.C.la

IND

0

0

0

13

1

0

0

0

0

14

0

0

NIP

0

0

0

13

0

0

0

0

0

13

0

0

Total :

0

1

0

42

1

0

0

1

0

43

0

0

F-5

1996 BMP RATINGS BY PRACTICE AND OWNERSHIP GROUP

Practice

Skid to Min.
Compacting Soil
Il.C.lb

Adequate Drain,
for Skid T rai Is
1 1 .C.2a

Adequate Drain,
for Landings
1 1 . C . 2b

SITE PREPARATION

Brush Blades

Used

II. D. 2

Scari fy Only
to Extent
Necessary
II. D. 4

Compaction and
Di splacement
Minimi zed
1 1 . D . 5

APPLICATION

EFFECTIVENESS

Owner

1

2

3

4

5

NR

1

2

3

4

5

NR

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

0

11

0

1

0

0

0

11

0

1

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

1

11

0

1

0

0

1

11

0

1

Total :

0

0

1

41

0

2

0

0

1

41

0

2

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

1

11

0

0

0

1

0

11

0

0

IND

0

0

2

10

0

2

0

0

1

11

0

2

NIP

0

0

2

11

0

0

0

0

1

12

0

0

Total :

0

0

5

37

0

2

0

1

2

39

0

2

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

0

12

0

0

0

0

0

12

0

0

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

0

13

0

0

0

0

0

13

0

0

Total :

0

0

0

44

0

0

0

0

0

44

0

0

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

FED

0

0

0

6

0

6

0

0

0

6

0

6

IND

0

0

0

4

0

10

0

0

0

4

0

10

NIP

0

0

0

9

0

4

0

0

0

9

0

4

Total :

0

0

0

22

0

22

0

0

0

22

0

22

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

1

9

0

2

0

0

0

10

0

2

IND

0

0

0

14

0

0

0

0

0

14

0

0

NIP

0

0

0

13

0

0

0

0

0

13

0

0

Total :

0

0

1

41

0

2

0

0

0

42

0

2

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

FED

0

0

1

8

0

3

0

0

1

8

0

3

IND

0

0

1

13

0

0

0

0

1

13

0

0

NIP

0

0

0

13

0

0

0

0

0

13

0

0

Total :

0

0

2

39

0

3

0

0

2

39

0

3

F-6

1996 BMP RATINGS BY PRACTICE AND OWNERSHIP GROUP

APPLICATION

EFFECTIVENESS

Practice

Owner

1

2

3

4

5

NR

1

2

3

4 5

NR

Dozer Operation

DNRC

0

0

0

5

0

0

0

0

0

5 0

0

on Suitable

FED

0

0

0

9

0

3

0

0

0

9 0

3

Slopes Only

IND

0

0

0

13

0

1

0

0

0

13 0

1

II .D. 6

NIP

0

0

0

11

0

2

0

0

0

11 0

2

Total :

0

0

0

38

0

6

0

0

0

38 0

6

Limit WQ Impact

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

of F i re

FED

0

0

0

10

0

2

0

0

0

10

0

2

II. D. 9

IND

0

0

2

11

0

1

0

0

1

12

0

1

NIP

0

0

2

11

0

0

0

0

0

13

0

0

Total :

0

0

4

37

0

3

0

0

1

40

0

3

STREAM CROSSINGS

Proper Permit

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

Obtained

FED

0

0

0

7

0

5

0

0

0

7

0

5

III .A.1

IND

0

0

0

7

0

7

0

0

0

7

0

7

NIP

0

0

0

7

0

6

0

0

0

7

0

6

Total :

0

0

0

26

0

18

0

0

0

26

0

18

STREAM XING DESIGN

Cross Stream

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

at Right Angle

FED

0

0

0

7

0

5

0

0

0

7

0

5

III .B. la

IND

0

0

0

10

0

4

0

0

0

10

0

4

NIP

0

0

0

7

0

6

0

0

0

7

0

6

Total :

0

0

0

29

0

15

0

0

0

29

0

15

Reduce Concen.

DNRC

0

0

1

4

0

0

0

0

0

5

0

0

of Runoff

FED

0

0

3

4

0

5

0

1

2

4

0

5

III. B. 1b

IND

0

0

2

8

0

4

0

0

1

9

0

4

NIP

0

3

2

2

0

6

0

2

2

3

0

6

Total :

0

3

8

18

0

15

0

3

5

21

0

15

Avoid Unimproved DNRC

0

0

0

5

0

0

0

0

0

5

0

0

Crossings

FED

0

0

0

7

0

5

0

0

0

7

0

5

III .B.2

IND

0

0

0

10

0

4

0

0

0

10

0

4

NIP

0

0

0

8

0

5

0

0

0

8

0

5

Total :

0

0

0

30

0

14

0

0

0

30

0

14

F-7

1996 BMP RATINGS BY PRACTICE AND OWNERSHIP GROUP

APPLICATION

EFFECTIVENESS

Practice

Owner

1

2

3

4

5

NR

1

2

3

4

5

NR

STREAM XING INSTALLATION

Min. Channel

DNRC

0

0

0

4

1

0

0

0

0

5

0

0

Disturbance

FED

0

0

0

6

0

6

0

0

0

6

0

6

III.C.1

IND

0

0

0

10

0

4

0

0

0

10

0

4

NIP

0

1

0

15

1

6

0

1

0

5

1

6

Total :

0

1

0

25

2

16

0

1

0

26

1

16

Culverts Conform

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

to Streambed

FED

0

1

0

5

0

6

0

0

1

5

0

6

Slope

IND

0

0

0

10

0

4

0

0

0

10

0

4

III.C.2

NIP

0

0

1

4

0

8

0

0

1

4

0

8

Total :

0

1

1

24

0

18

0

0

2

24

0

18

Prevent Fill

DNRC

0

0

0

4

0

1

0

0

0

4

0

1

Erosion

FED

0

0

3

3

0

6

0

1

2

3

0

6

III.C.3

IND

0

0

2

7

0

5

0

0

1

8

0

5

NIP

0

3

1

3

0

6

0

3

1

3

0

6

Total :

0

3

6

17

0

18

0

4

4

18

0

18

Adequate Cover

DNRC

0

0

0

3

0

2

0

0

0

3

0

2

for Culverts

FED

0

0

0

6

0

6

0

0

0

6

0

6

III.C.5

IND

0

0

0

9

0

5

0

0

0

9

0

5

NIP

0

1

0

4

0

8

0

0

1

4

0

8

Total :

0

1

0

22

0

21

0

0

1

22

0

21

HAZARDOUS SUBSTANCES

Proper Storage

DNRC

0

0

0

5

0

0

0

0

0

5

0

0

and Disposal

FED

0

0

0

14

0

0

0

0

0

14

0

0

V.A.2

IND

0

0

0

13

0

1

0

0

0

13

0

1

NIP

0

0

0

13

0

0

0

0

0

13

0

0

Total :

0

0

0

45

0

1

0

0

0

45

0

1

GRAND

TOTALS:

0

24

109

1501

7

427

0

29

72

1537

3

427

F-8