Wyoming Forestry Best Management Practices

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Wyoming Forestry Best Management Practices Forest Stewardship Guidelines for Water Quality 2011 Field Audit Report Office of State Lands and Investments Wyoming State Forestry Division January 2012

Table of Contents Executive Summary... - 1 - Acknowledgements... - 2 - State Audit BMP Steering Committee... - 2-2011 State Audit Team... - 2 - Introduction... - 2-2011 Audit Objectives... - 4 - Audit Process... - 5 - Site Selection... - 5 - Overview of Selected Sites... - 6 - Re-Audit Sites... - 6 - Audit Procedure... - 7 - Definition of Effectiveness Terms... - 8 - Limitations of the Audit Process... - 9 - Field Audit Results... - 9 - Discussion... - 11 - Recommendations... - 13-2011 Audit Team Recommendations... - 13 - Appendix A.... - 15 - Appendix B.... - 22 - Photos taken by Carson Engelskirger and Rich Edwards.

Executive Summary Water is a valuable commodity in Wyoming that must be protected from non-point source pollution (NPS). In an effort to be proactive in protecting water quality, in 2000 Wyoming began implementing Best Management Practices (BMPs); voluntary measures and guidelines for forestry and silviculture activities to prevent NPS pollution. Prior to beginning the audit process for 2011, the BMP Steering Committee decided to broaden the scope of projects that could be included in the audit process. With suppressed timber markets and a limited number of active timber harvest sites, the Committee elected to include fuels mitigation, aspen restoration, and hazard tree reduction efforts as possible entries into the BMP Audit process. In 2011 five harvested sites were selected from federal, state, and private land with live or active water courses. Each site was evaluated on the application and effectiveness of seventy BMPs using the field audit rating guide criteria. For application, in 2011, the timber sale operators met or exceeded the BMPs 85 percent of the time for all ownership groups, with state timber sales scoring the highest. The applied BMPs were effective 86 percent of the time. In 2011, state timber sales also had the highest effectiveness rating. As a result of this audit, the BMP Audit Committee s recommendations included: 1. Conduct training sessions to landowners, contractors, and state and federal employees on the proper use of the BMP Guidelines 2. Clearly define criteria for stream classification on future audits 3. Review the BMP Field Audit Ranking Sheet and developing clearer language for several categories 4. Consider the possibility of conducting BMP Audits biannually to better evaluate our BMP effectiveness - 1 -

Acknowledgements In an effort to ensure that Best Management Practices (BMPs) are being effectively applied during forestry and silviculture operations the Wyoming State Forestry Division (WSFD) facilitated the organization of the 2011 Wyoming Forestry BMP Audits. This has been an ongoing program since first initiated by the Wyoming Timber Industry Association (WTIA) in 1999 with past audits being conducted in 2000/2001, 2004, and 2007. Credit is given to the individuals and organizations who so graciously gave their time and expertise to this interdisciplinary group including specialists in the fields of fisheries biology, hydrology, agronomy, geology, forestry, engineering, and timber harvest. A special thanks to the following individuals for their continued help and support: State Audit BMP Steering Committee Carson Engelskirger Melissa Dempsey Jay Hein Jennifer Zygmunt Stephen Williams Greg Bohls Dennis Oberle Mark Conrad Paul Mavrakas Bob Means Casey Sheley Mark Stiller 2011 State Audit Team Bob Means Carol Purchase Carson Engelskirger Dennis Oberle Jay Hein Mark Conrad Mark Stiller Melissa Dempsey Rich Edwards Stephen Williams Bureau of Land Management United States Forest Service Black Hills Forest Resource Association Wyoming Game and Fish Department Wyoming State Forestry Division Wyoming Department of Environmental Quality Devil s Tower Forest Products United States Forest Service Colorado State Forest Service University of Wyoming Introduction The forest lands of Wyoming are 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 grow the timber that contributes to our forested resource and helps sustain the forest products industry. In Wyoming, approximately 25-35 percent of the population relies on surface water collected from forested watersheds for their sole source of domestic water supply. With water being such a valuable commodity, it is essential that it is protected from non-point source (NPS) pollution. - 2 -

According to the Wyoming Nonpoint Source Management Plan (Silviculture Best Management Practices) NPS is defined as: Diffuse sources of water pollution that originate from any indefinable sources and normally includes agricultural and urban runoff, runoff from construction activities, etc. In practical terms, nonpoint sources do not discharge at a specific, single location (such as a single pipe). Nonpoint source pollutants are generally carried over or through the soil and ground cover via stormflow processes. Unlike point sources of pollution (such as industrial and municipal effluent discharge pipes), nonpoint sources are diffuse and can come from any land area. The following silvicultural activities are considered to be nonpoint sources of pollution: nursery operations, site preparation, reforestation and subsequent cultural treatment, thinning, prescribed burning, pest and fire control, harvest operations, surface drainage, and road construction and maintenance from which there is natural runoff. (WY DEQ, 2004) Without foresight on the potential impacts, forest management activities can lead to the degradation of ephemeral and intermittent water courses. This can include an increase in sediment delivery, rise in water temperature, accumulation of organic debris causing the depletion of dissolved oxygen, and a change in the chemical concentrations from fertilizer or pesticide applications. In addition, roads, skid trails and landings can act as man-made drainages carrying sediment when improperly planned, located or constructed. According to the EPA, in 1990, twenty-four states identified silviculture as a contributor to NPS pollution. In 1992, with 42 states reporting, forestry practices were responsible for nine percent of the NPS pollution going to rivers. (http://www.epa.gov/owow/nps/mmgi/chapter3/ch3-1.html#pollutant). In order to be proactive, many states, including Wyoming, have implemented Best Management Practices (BMPs) for forestry and silviculture activities. The State of Wyoming has approved, published and distributed copies of the Wyoming Forestry and Silvicultural Best Management Practices, which is available on the Wyoming State Forestry Division website (http://slfweb.state.wy.us/forestrydivision/forestryprograms/bmpguidecomplete.pdf). It is also available through the Wyoming DEQ and State Forestry District Offices. The BMPs act as a set of water quality protection measures and guidelines to prevent NPS pollution and provide direction on issues such as planning, harvesting, roads, chemical use, and fire management. Implementation of Forestry BMPs in Wyoming is administered within a non-regulatory framework. The initial BMP audits were conducted on twelve federal, state and private harvest sites in 2000/2001. The audits in 2004 and 2007 also consisted of six sites apiece. The audits were conducted by an interdisciplinary team comprised of professionals in the fields of forestry, hydrology, fisheries, agronomy, geology, and engineering from federal, state, and private sectors. Each site was evaluated on key components of the timber sale such as planning, roads, harvesting, slash treatment, re-vegetation, chemical use, and fire management using the field audit rating guide criteria. 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. Each previous audit showed acceptable levels of BMP compliance that met or exceeded standards. Typical departures tended to relate to road construction and drainage, along with - 3 -

SMZ concerns. As a result of these findings, the 2007 audit team included recommendations that focused on these departures. Upon this recommendation, WSFD took over the BMP program in 2005 and completed a revision of the BMP Field Guide in December of 2006 funded through a 319 Grant, Federal Environmental Protection Agency Clean Water Act. Since that time, field audits have been conducted in the summer of 2007 and again in the summer of 2011. As in the past, the purpose was to evaluate whether BMPs were being properly applied and if they were effectively limiting non-point source pollution. Five sites were selected; again on federal, state, and private land, and were associated with ephemeral or intermittent water courses. This does create a bias in the results by focusing on sites with a high probability of delivering sediment to watercourses in the event of improper application of BMPs. This report details the findings of the 2011 BMP field audits. 2011 Audit Objectives The role of the 2011 audit team was to evaluate the voluntary compliance to BMP standards detailed in the publication Wyoming Forestry Best Management Practices: Water Quality Protection Guidelines. The overall goal was to monitor in a proactive manner, the implementation of the state silviculture BMPs and evaluate the effectiveness of each of the BMPs. The 2011 objectives were the same as what was set forth in the 2007 audit report and include: 1. Monitor the effects of silvicultural activities on soil and water quality, and compare the results against the 2007 audit. 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) in riparian areas under 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 forestry and logging fields for handling and storage of hazardous substances and spill contingency planning. 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 auditing sales to include not only completed timber sales, but also those still ongoing. 8. Monitor the effectiveness of voluntary audits in promoting BMP compliance. - 4 -

Audit Process Site Selection Sites were recommended and selected by the audit team from a pool of forest management projects on state, federal, and private forestland. In order to establish an equal representation of forestland ownership and to focus on timber sales with the greatest potential to affect water quality; baseline criteria were used to select timber sales from the list of potential sites. Baseline criteria included: 1) Harvest must have been completed within the last two years. 2) Timber sale must have harvested a minimum of 1,000 board feet per acre. 3) Timber sale area must include live water crossings, riparian areas, federally designated wetlands, perennially or ephemerally saturated soils, or other important hydrologic features or resources. 4) One audit site must be a re-audit from the 2007 BMP Field Audits The minimum 1,000 board feet per acre harvested requirement ensured against the selection of sales with only marginal potential to affect water quality. In addition, a great number of the forest management projects 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, five new forest management projects 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 one on private land. Figure 1 displays the general location of the audited timber sales. In addition to the five new sites, one site that was audited in 2007 was re-evaluated. This was an attempt to determine the environmental effects of departures found in the initial audit as well as look at post harvest treatments such as seeding that are difficult to assess so soon after implementation. - 5 -

Overview of Selected Sites Figure 1. Map of 2011 Audit Sites Audit Sites Roger s Research Site: Located on State land in Natrona County, RNG 71, TWP 26, Section 3/10. This sale was 320 acres with 1-5 MBF removed per acre on approximately 10% of the area. CP&L Power Line Clearing Unit #10: Located on USFS land in Carbon County, RNG 78, TWP 12, Section 9. This was 13.6 acres with 8-10 MBF harvested per acre. Teton Valley Ranch Camp: Located on private land in Fremont, RNG 108, TWP 42, Section 19/20. This sale was 55 acres with 4 MBF removed per acre. Hat Butte: Located on State land in Fremont County, RNG 108, TWP 42, Section 16. This sale was 240 acres with 3 MBF removed per acre. Buffalo Valley: Located on USFS land in Teton County, RNG 113, TWP 45, Section 35/36. This sale was 457 acres with 3.9 MBF removed per acre. Re-Audit Site Garden Creek Sale: Located on State land in Natrona County, RNG 79, TWP 31, Section 9/10/16. This sale was fifteen acres with 8.5 MBF harvested per acre. -6-

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. At each location personnel directly associated with the timber sale briefed the audit team on the details of the harvest. Areas of particular importance such as the stream management zone, roads, and landing areas near the riparian corridor were identified. The members of the audit team had an opportunity to conduct their own inspection of the area. No effort was made to inspect each acre of the harvested 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 project 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 seventy 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, not all harvest sites require the construction of temporary roads and in these cases; the BMPs pertaining to temporary roads are not applicable. In addition, within a large timber sale area, the audit team may not have been able to see firsthand 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. Once the audit team establishes that a given BMP is applicable, an application rating for the BMP is determined based on the criteria listed in Table 1. Table 1. BMP Application Ratings and Criteria Rating Criteria 5 Operation exceeds requirements of BMP. 4 Operation meets the standard requirement of BMP. 3 Minor departure from the BMP. 2 Major departure from the BMP. 1 Gross neglect of the BMP. Figure 2. BMP Audit Team reviewing the CP&L Line Clearing project Upon completing the application ratings (Figure 2), the audit team evaluates how effective the applied BMPs were. This assesses whether or not the BMPs were successful in the protection of water quality, and one can differentiate ineffectiveness due to improper application. Table 2 displays the rating criteria for BMP effectiveness. - 7 -

Figure 3. Wyoming BMP Audit Ranking System 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 and water resources. 1 Major and prolonged impacts to soil and water resources. Definition of Effectiveness Terms Adequate: Small amount 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. - 8 -

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 act as a spot check, 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 postsale activities to which BMPs apply. With the past audits it was 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. Field Audit Results Tables 3 and 4 describe the application and effectiveness scores recorded in the 2011 field audits by landownership. The data in these tables represents the occurrence of each rating and the application percentage compared to the ownership total. BMPs that were recorded as not applicable or not reviewed are excluded from the total. Figure 3 illustrates the occurrences of application and effectiveness ratings as a percent of the total points compiled across all land ownership categories. In 2011 the timber sale operators met or exceeded the BMPs 85 percent of the time for all ownership groups (120 of 142 rated items). Minor departures occurred thirteen percent of the time across all three ownership groups with private landowners having the highest occurrence. All observed major departures occurred on USFS land, with a total of four counts. State timber sales scored the highest among the ownership groups in application, having met the BMP standard 89 percent of the time. Table 3. Wyoming Forestry BMP 2011 Field Audit Application Results by Landownership Ownership Exceeded BMP Met BMP Standard Minor Departure Major Departure Gross Neglect Total Private 0 20 3 0 0 23 0% 87% 13% 0% 0% 100% WSFD 0 54 7 0 0 61 0% 89% 11% 0% 0% 100% USFS 1 45 9 3 0 58 2% 78% 15% 5% 0% 100% Total 1 119 19 3 0 142 <1% 84% 13% 2% 0% 100% Table 4. Wyoming Forestry BMP 2011 Field Audit Effectiveness Results by Landownership Minor/Prolonged Ownership Improved Conditions Adequate Protection Minor and Temporary or Major/Temporary Major and Prolonged Total Private 1 21 1 0 0 23 4% 92% 4% 0% 0% 100% WSFD 0 53 8 0 0 61 0% 96% 1% 3% 0% 100% USFS 0 47 10 1 0 58 0% 81% 17% 2% 0% 100% Total 1 121 19 1 0 142 <1% 85% 13% <1% 0% 100% - 9 -

The 2011 field audit effectiveness and application results showed a 1% improvement to pretreatment conditions as a result of forest management activities. The applied BMPs did prove to adequately protect 85 % of the time across all ownership groups. Thirteen percent of the time the effectiveness of the BMPs were found to result in minor and temporary impacts to soil and water resources; in addition, less than one percent of the time there were major and temporary or minor and prolonged impacts to soil and water resources. For both, the majority of occurrences were found on USFS land. Like the application rating, the State timber sales scored the highest on effectiveness with 89% of the applied BMPs providing adequate protection. Application Minor Departure 13% Major Departure 2% Met BMP Standard 84% Gross Neglect 0% Exceeded BMP 1% Effectiveness Adequate Protection 85% Minor and Temporary 13% Minor Prolonged or Major Temporary 1% Major and Prolonged 0% Improved Conditions 1% Figure 4. Comparison of application and effectiveness ratings - 10 -

Discussion Many of the audit items were properly applied and effective across all ownership groups. This included soil and water resource monitoring and evaluation, knowing and complying with regulations governing the storage and handling of hazardous substances, and establishing proper sites for servicing and refueling to prevent spills from entering the water. With consideration to topography, soil type, and season; each site established an appropriate logging system and location for skid trails. Road use and construction was avoided during wet periods. Finally, all sites minimized soil compaction and displacement during skidding operations and provided sufficient drainage for landings. Table 5 shows the 2011 BMP application and effectiveness results for all landowners compared to the results of the previous three audits (2000/2001, 2004 and 2007). The 2004 audit shows progress in application and effectiveness scoring compared to the 2000/2001 audit. Table 5. Comparison of BMP Application and Effectiveness Results by year. 1 Exceeded Met BMP Minor Major Gross Application BMP Standard Departure Departure Neglect Total 2000/2001 2% 90% 8% 0% 0% 100% 2004 4% 93% 4% 0% 0% 100% 2007 0% 86% 10% 3% 0% 100% 2011 <1% 84% 13% 2% 0% 100% Effectiveness Improved Conditions Adequate Protection Minor and Temporary Minor/Prolonged or Major/Temporary Major and Prolonged Total 2000/2001 3% 90% 7% 0% 0% 100% 2004 3% 92% 6% 0% 0% 100% 2007 0% 92% 4% 4% 0% 100% 2011 <1% 85% 13% <1% 0% 100% The most notable change between 2007 and 2011 is an increase in the Minor departure category under both the application and effectiveness categories. Roger s Research Site: This site is an example of the non-traditional timber sale sites we visited throughout the week and will continue to see in the future. Overall, the BMP s were well maintained on this site with a few minor departures. Timber harvest activities on the site followed BMP standards with the exception of not properly marking the SMZ prior to harvest. The only other departures on the Roger s Research Site were related to road maintenance and drainage. In particular, there was one two track road that had moderate erosion the entire length of the slope with no maintenance or water bars present. There was obvious sedimentation coming off the road, though not enough to reach live water. These departures can be easily remedied with minor road maintenance. 1 Table 5 is intended to be used for reference purposes only and is not designed to be used in statistical analysis - 11 -

Carbon Power and Light Power Line Clearing Unit #10 This Carbon Power and Light Project occurred on USFS land in the southern Medicine Bow National forest. The project was created in response to public safety issues caused by the mountain pine beetle epidemic. Departures that occurred on this site included improper marking of the SMZ s prior to harvest, inclusion of slash in streams, lakes, and bodies of water, and not avoiding unimproved stream crossings. Much of the project was completed during the winter months in order to minimize any damage to the riparian areas present on the site; however, it appeared as though the ground was not frozen to the extent necessary to prevent any damage. Our recommendation is to use skidder bridges in the future to avoid breaking through frozen ground. Hat Butte Timber Sale The Hat Butte timber sale is on State land in Fremont County. The timber sale began in 2009 and is still ongoing. The departures on this site are exclusively limited to road drainage, design, and construction. Upon entering the timber sale area from BLM land, there is new road construction on a steep slope. At the time of the audit, there were no energy dissipaters on that slope, leaving an opportunity for erosion. Including rolling dips on that slope will remedy that issue. Since this is an open sale, the contractor has the opportunity to perform road improvement operations as the sale is finished. In the center of the sale area, an issue developed on the main haul road. Record snowfall the winter before led to a new spring developing in the haul route. The operator did not know the spring was there until attempting to drive his equipment further into the sale. The audit team felt the operator did an excellent job of removing his equipment from the spring and ceasing all operations until either the seep dried up or an alternate route could be found. Teton Valley Ranch Camp Fuels Reduction Project This fuels reduction project took place on private land in Fremont County. The purpose of the project was to reduce fuel loading and to create a fuel break for the Camp. The contractor and landowner followed the BMP standards well with just a few minor departures. In a few locations within the project area, logs were placed into the creek to be used as a bridge. This method is an effective means of protection for the creek; however those logs were not removed following the completion of the project. In order to comply with the BMP s the logs need to be removed from the creek to allow for natural flow of the creek to resume. The other minor departure occurred below the camp on an area where beetle-killed timber was removed. The steep slopes had some Figure 5. Fuels reduction and aspen restoration at the Teton Valley Ranch Camp slash scattered throughout, but there were a few skid trails that needed a greater amount of slash to prevent erosion. The operators on the project did an excellent job throughout in minimizing soil compaction and displacement and were rated as a 5 in that category. - 12 -

Buffalo Valley Timber Sale The Buffalo Valley Timber Sale took place on USFS land in Teton County. The sale was 457 acres in size and took place over several different parcels. The Buffalo Valley Timber Sale had three major departures from BMP standards in the application category. Those departures were all related to the streamside management zones. The SMZ s were not accounted for in the planning of the timber sale, nor were they marked on site. Because of this there was evidence of harvesting equipment within the SMZ in several locations within the sale. Minor departures within the sale area included leaving slash in isolated wetlands, operating in isolated wetlands, and not installing a culvert in one instance. The audit team also noted that a few of the skid trails were sub-optimal and could have been designed to better alleviate the concentration of Figure 6. An example of a slashed-in runoff. Road maintenance, design, and construction were skid trail on the Buffalo Valley done well on this timber sale, and adequate slash was Timber Sale. found throughout the sale to minimize runoff. Better layout and sale administration would help with issues like these in the future. Recommendations 2011 Audit Team Recommendations The selection process for which projects will be audited may need some refinement since the recent inclusion of non-traditional forest management projects. During the 2011 audits, many of the categories in the worksheet were not applicable to the projects the audit team was auditing. An additional issue in the 2011 audits was that sites selected did not have stream crossings. Had we audited timber sales with stream crossings, many of the N/A ratings would have been filled in. In past Audits, the projects to be audited were selected by Sale Administrators. In order to conduct a more unbiased audit, the Audit team would like to receive GIS information about every project completed and use a random selection of applicable sites to select which projects are audited. The Audit team will meet to revamp the worksheet. Throughout the audit process the team felt the worksheet was vague and lacking clarity in several categories. A meeting with the Audit team prior to the next field audit will help to clarify these issues for future audits. - 13 -

Develop and conduct BMP training statewide for contractors, private landowners, and state and federal employees to develop an understanding of the expectations and importance of following Best Management Practices. Encourage agencies to conduct logger training throughout the state. THE REST OF THIS PAGE LEFT INTENTIONALLY BLANK - 14 -

Appendix A. 2011 Forestry BMP Field Audit Raw Data and Rating Guide Criteria THE REST OF THIS PAGE LEFT INTENTIONALLY BLANK - 15 -

APPENDIX A 2011 Field Audit Data and Rating Guide Criteria Timber Sale Name Land Ownership/ Management Roger s Research Site Hat Butte Timber Sale Teton Valley Ranch Camp CP&L Power Line Clearing Unit #10 Buffalo Valley Timber Sale State of WY State of WY Private USFS USFS PLANNING Application Effectiveness Application Effectiveness Application Effectiveness Application Effectiveness Application Effectiveness A. Soil and Water Resource Monitoring and Evaluation The federal agency, state, or private is in compliance with monitoring plan standards. B. Sanitary Guidelines for Construction of Camps Adequate sewer and soil waste considerations on site to protect water quality if camps are present. C. Oil and Hazardous Substance Spill Contingency N/A N/A 4 4 Know and comply with regulations governing the storage, handling, etc. of hazardous substances. D. Riparian Area Adequate SMZ width maintained N/A N/A 4 4 3 4 4 4 N/A N/A 2 3 SMZ Properly marked? 3 4 N/A N/A 4 4 4 3 2 2 Exclusion of broadcast burning in SMZ SMZ retention tree requirements met. (Larger trees retained to provide shade and a source of large woody debris). Exclusion of equipment operation in SMZ except on established roads. 4 4 4 4 N/A N/A 4 4 N/A N/A 4 4 4 4 N/A N/A 4 4 N/A N/A 2 3 Exclude construction of roads in the SMZ except as needed to construct crossings 4 4 N/A N/A 4 4

Exclusion of road fill material deposited in SMZ except as needed to construct crossings. Exclusion of side-casting of road material into a stream, lake, wetland or other body of water during road maintenance. Exclusion of slash in streams, lakes or other bodies of water. 4 4 4 4 4 4 N/A N/A 3 3 3 3 3 3 ROADS Application Effectiveness Application Effectiveness Application Effectiveness Application Effectiveness Application Effectiveness E. Road Planning and Location Minimize number of roads necessary. Use existing roads unless aggravated erosion will be likely. Avoid long, sustained, steep road grades. Locations avoid high-hazard sites (i.e., wet areas and unstable slopes). Minimize number of stream crossings. Choose stable stream crossing sites. N/A N/A 4 4 3 4 4 4 N/A N/A 4 4 N/A N/A N/A N/A 4 4 N/A N/A N/A N/A 4 4 N/A N/A N/A N/A F. Road Design Design roads to minimum standard necessary to accommodate anticipated uses. Vary road grade to reduce concentrated drainage. N/A N/A 4 4 N/A N/A N/A N/A 4 3 N/A N/A G. Road Drainage Provide adequate road surface drainage for all roads. Design ephemeral draw culverts with adequate length and size to prevent erosion of fill. Minimum size 15, maintain cover. 3 3 3 3 4 4 N/A N/A 4 4 N/A N/A

Design all relief culverts with adequate length and appropriate skew. Protect inflow end from erosion. Catch basins where appropriate. Install culverts at original gradient, otherwise rock armor or anchor downspouts. Provide energy dissipaters at drainage structure outlets where needed. Route road drainage through adequate filtration zones before entering a stream. H. Construction / Reconstruction Stabilize erodible soils (i.e. seeding benching, mulching). Provide effective sediment control on erodible fill slopes (ex. Slash filter windrow). Cut and fill slopes at stable angles. Avoid incorporating woody debris in road fill. Excess materials placed in location that avoid entering stream. Sediment from borrow pits and gravel pits minimized. Reconstruct only to the extent necessary to provide adequate drainage and safety. N/A N/A 3 3 N/A N/A 4 3 N/A N/A 3 3 N/A N/A 3 4 4 4 4 4 N/A N/A 4 4 4 4 4 4 N/A N/A 4 4 N/A N/A N/A N/A N/A N/A 4 4 N/A N/A Stream diversions are carefully planned to minimize downstream sedimentation. I. Road Maintenance and Construction Grade roads as necessary to maintain drainage. Maintain erosion control features (dips, ditches and culverts functional). N/A N/A 3 3 4 3 4 4 N/A N/A 4 3 4 4 Avoid cutting the toe of slopes. N/A N/A 4 4 4 4

Avoid use and construction of roads during wet periods and spring breakup. Abandoned roads in condition to provide adequate drainage without further maintenance. J. Stream Crossings and Stream Bank Protection Proper permits for stream crossings obtained. Cross streams at right, if practical. Direct road drainage away from stream crossing site. Avoid unimproved stream crossings. Sediment minimized from structural abutments in natural waterways. K. Installation of Stream Crossings Minimize stream channel disturbance. Stream crossing culverts conform to natural stream and slope. Proper sizing for stream crossing structures. Prevent erosion of stream crossing culverts and bridge fills (i.e., armor inlet and outlet). Minimum cover for stream crossing culverts provided. L. Existing Stream Crossing Culverts are maintained to preserve their hydrologic capacity. Adequate lengths to allow for road fill width. Rock armoring. Maintain fill over culvert. M. Harvest Design Suitable logging system for topography, soil type and season of operation. N/A N/A N/A N/A 4 4 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 3 3 4 4 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 4 4

Design and locate skid trails to avoid concentrating runoff. Suitable location, size, and number of landings. N. Revegetation of Disturbed Areas Practices have been completed to ensure adequate revegetation in areas disturbed by harvest. 3 3 3 3 4 4 N/A N/A 4 4 O. Other Harvesting Activities Skidding operations minimize soil compaction and displacement. Avoid tractor skidding on unstable slopes and slopes that exceed 40% unless not causing excessive erosion. Avoid operation of equipment within isolated wetlands. Adequate drainage for landings. Adequate drainage for skid trails. 4 5 4 4 N/A N/A 4 4 N/A N/A 4 4 3 3 3 4 3 4 P. Slash Treatment and Site Preparation Treat slash so as to preserve the surface soil horizon. Scarify only to the extent necessary to meet resource management objectives. Activities limited to frozen or dry conditions to minimize soil compaction and displacement. 4 4 4 4 N/A N/A 4 4 4 4 5 4 4 4 Equipment operations on suitable slopes only. 4 4 Water quality protected from slash treatment in sensitive 4 4 N/A N/A 4 4 areas. PESTICIDES, HERBICIDES FERTILIZERS AND CHEMICALS Application Effectiveness Application Effectiveness Application Effectiveness Application Effectiveness Application Effectiveness Q. General Proper sites were selected for servicing and refueling to prevent contamination of waters from accidental spills. 3 4

Pesticide materials have been properly applied and effects monitored. Fertilizers have been properly handled and applied so as to reduce possible adverse effects on water quality. N/A N/A N/A N/A FIRE MANAGEMENT Application Effectiveness Application Effectiveness Application Effectiveness Application Effectiveness Application Effectiveness R. Protection of Soil and Water from Prescribed Burning Effects Soil productivity is maintained, erosion is minimized. Ash, sediment, nutrients and debris is prevented from entering surface water. 4 4 S. Stabilization of Fire Suppression Related Work Damage Areas impacted by fire suppression activities have been stabilized. T. Emergency Rehabilitation of Watersheds Impacted by Wildfires Corrective measures have been applied to minimize the loss of soil productivity, deterioration of water quality, and threats to life and property, both on-site and offsite. N/A N/A N/A N/A

Appendix B. Garden Creek Timber Sale Re-Audit Introduction The Garden Creek timber sale was initially audited for BMP implementation and effectiveness during the summer of 2007. The sale is under state ownership and located within Natrona County, WY (T.31N., R.79W., Sections 9, 10 and 16). The sale is approximately 15 acres in size with an average of 8.5 MBF removed per acre. Harvest was initiated in November, 2004 and completed in November, 2006. The state BMP Audit Team conducted a re-audit of the sale on 08/08/11. Findings Summary Figure 7. Regeneration of lodgepole pine on the Garden Creek Sale A major concern of the audit team was the amount of thistle and other noxious weeds that would be established following the burning of the slash piles. While the thistle did take over those small sites, the thistle is decreasing over time and is converting back to native grasses and shrubs. Slash piles were located on slope above the SMZ. There is adequate vegetation buffer between the stream and the slash piles so sediment would not be transported to the stream. No evidence of soil or ash reaching the stream. The burn areas were reseeded. Skid trails had reseeded, and has slash that was placed on the trails prevented soil erosion. Native vegetation was reseeding well throughout. There was still evidence of skidding while the soils were wet, though no additional rutting or erosion is apparent since the previous audit. Overall, the departure and other concerns that were noted in the previous audit were not found to be a factor in degraded water quality. The vegetative cover was adequate to limit any soil movement. - 22 -

Comparison of Worksheets from 2007 and 2011 Timber Sale Name 2007 Audit - Garden Creek Timber Sale 2011 Audit - Garden Creek Timber Sale Land Ownership/ Management State of WY State of WY PLANNING Application Effectiveness Application Effectiveness A. Soil and Water Resource Monitoring and Evaluation The federal agency, state, or private is in compliance with monitoring plan standards. B. Sanitary Guidelines for Construction of Camps Adequate sewer and soil waste considerations on site to protect water quality if camps are present. C. Oil and Hazardous Substance Spill Contingency Know and comply with regulations governing the storage, handling, etc. of hazardous substances. D. Riparian Area Adequate SMZ width maintained SMZ Properly marked? Exclusion of broadcast burning in SMZ SMZ retention tree requirements met. (Larger trees retained to provide shade and a source of large woody debris). Exclusion of equipment operation in SMZ except on established roads. Exclude construction of roads in the SMZ except as needed to construct crossings Exclusion of road fill material deposited in SMZ except as needed to construct crossings. Exclusion of side-casting of road material into a stream, lake, wetland or other body of water during road maintenance. Exclusion of slash in streams, lakes or other bodies of water. - 23 -

ROADS Application Effectiveness Application Effectiveness E. Road Planning and Location Minimize number of roads necessary. Use existing roads unless aggravated erosion will be likely. Avoid long, sustained, steep road grades. Locations avoid high-hazard sites (i.e., wet areas and unstable slopes). Minimize number of stream crossings. Choose stable stream crossing sites. F. Road Design Design roads to minimum standard necessary to accommodate anticipated uses. Vary road grade to reduce concentrated drainage. G. Road Drainage Provide adequate road surface drainage for all roads. Design ephemeral draw culverts with adequate length and size to prevent erosion of fill. Minimum size 15, maintain cover. Design all relief culverts with adequate length and appropriate skew. Protect inflow end from erosion. Catch basins where appropriate. Install culverts at original gradient, otherwise rock armor or anchor downspouts. Provide energy dissipaters at drainage structure outlets where needed. Route road drainage through adequate filtration zones before entering a stream. H. Construction / Reconstruction Stabilize erodible soils (i.e. seeding benching, mulching). Provide effective sediment control on erodible fill slopes (ex. Slash filter windrow). - 24 -

Cut and fill slopes at stable angles. Avoid incorporating woody debris in road fill. Excess materials placed in location that avoid entering stream. Sediment from borrow pits and gravel pits minimized. Reconstruct only to the extent necessary to provide adequate drainage and safety. Stream diversions are carefully planned to minimize downstream sedimentation. I. Road Maintenance and Construction Grade roads as necessary to maintain drainage. Maintain erosion control features (dips, ditches and culverts functional). Avoid cutting the toe of slopes. Avoid use and construction of roads during wet periods and spring breakup. Abandoned roads in condition to provide adequate drainage without further maintenance. J. Stream Crossings and Stream Bank Protection Proper permits for stream crossings obtained. Cross streams at right, if practical. Direct road drainage away from stream crossing site. Avoid unimproved stream crossings. Sediment minimized from structural abutments in natural waterways. K. Installation of Stream Crossings Minimize stream channel disturbance. Stream crossing culverts conform to natural stream and slope. Proper sizing for stream crossing structures. - 25 -

Prevent erosion of stream crossing culverts and bridge fills (i.e., armor inlet and outlet). Minimum cover for stream crossing culverts provided. L. Existing Stream Crossing Culverts are maintained to preserve their hydrologic capacity. Adequate length to allow for road fill width. Rock armoring. Maintain fill over culvert. M. Harvest Design Suitable logging system for topography, soil type and season of operation. Design and locate skid trails to avoid concentrating runoff. Suitable location, size, and number of landings. N. Revegetation of Disturbed Areas Practices have been completed to ensure adequate revegetation in areas disturbed by harvest. O. Other Harvesting Activities Skidding operations minimize soil compaction and displacement. Avoid tractor skidding on unstable slopes and slopes that exceed 40% unless not causing excessive erosion. Avoid operation of equipment within isolated wetlands. Adequate drainage for landings. Adequate drainage for skid trails. P. Slash Treatment and Site Preparation Treat slash so as to preserve the surface soil horizon. Scarify only to the extent necessary to meet resource management objectives. Activities limited to frozen or dry conditions to minimize soil compaction and displacement. Equipment operations on suitable slopes only. 4 4 3 4 3 4 4 4-26 -

Water quality protected from slash treatment in sensitive areas. PESTICIDES, HERBICIDES FERTILIZERS AND CHEMICALS Application Effectiveness Application Effectiveness Q. General Proper sites were selected for servicing and refueling to prevent contamination of waters from accidental spills. Pesticide materials have been properly applied and effects monitored. Fertilizers have been properly handled and applied so as to reduce possible adverse effects on water quality. FIRE MANAGEMENT Application Effectiveness Application Effectiveness R. Protection of Soil and Water from Prescribed Burning Effects Soil productivity is maintained, erosion is minimized. Ash, sediment, nutrients and debris is prevented from entering surface water. S. Stabilization of Fire Suppression Related Work Damage Areas impacted by fire suppression activities have been stabilized. T. Emergency Rehabilitation of Watersheds Impacted by Wildfires Corrective measures have been applied to minimize the loss of soil productivity, deterioration of water quality, and threats to life and property, both on-site and off-site. - 27 -