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BMP Compliance Report


Fiscal Year 2015-2016

As technology improves, the importance of Alabama’s natural resources becomes more evident. As a natural resource management agency we must continue to help protect these natural resources and educate the stakeholders that own, use, or work in Alabama’s forests which provide many of these natural resources. For instance, better technology has improved river and stream channel delineation, increasing the number of miles that we try to protect from 77,242 miles to 132,419 miles—almost doubling what we previously thought to exist. With 23.1 million acres of commercial forestland—primarily under private ownership—and a vibrant forest products industry, the Alabama Forestry Commission helps protect the natural resources that come from the forests by administering Alabama’s Best Management Practices for Forestry Program (BMPs).

Program components and accomplishments are:

Complaint Resolution

The AFC investigated 46 water quality complaints that were initiated from silvicultural activities. Of these complaints, 27 were actually deemed as valid complaints needing remediation. Four of the 27 were land use conversion and were transferred to other agencies. The remaining 23 were strictly silviculture in nature and the educational remediation process was applied. If the sites are not successfully remediated through education, they are turned over to the Alabama Department of Environmental Management—the regulatory agency for water quality in Alabama. The AFC also worked with the State Implementation Committee of the Sustainable Forestry Initiative (a third party certification program) to mitigate two inconsistent practices cases.

Education

Alabama’s rivers and streams are among the most biologically diverse waterways in the world. To put it in perspective: There are more species of fish in the Cahaba River alone than in the entire State of California. The AFC utilizes Alabama’s Best Management Practices for Forestry as a framework of sound stewardship practices that, when consistently applied, will contribute positively to maintaining a high degree of water quality flowing from the forest. This year the AFC conducted 29 BMP training sessions that were attended by 1574 forest landowners, AFC staff, loggers, foresters, and the general public. The AFC also conducted four bottomland hardwood classes that were attended by 346 forest landowners.

Prevention

The AFC completed 66 internal BMP audits on work performed by AFC associates on private forest landowners. This is to ensure AFC staff implement BMPs in all of our performed duties. The AFC also inspected 26 additional sites by requests.

Implementation

In following a framework that was developed cooperatively among the 13 southern states of the Southern Group of State Foresters, the AFC has conducted multiple recurring detailed site surveys on closed-out logging jobs to determine the extent of forestry BMP implementation and assess each BMP’s functionality. In 2016, 253 randomly selected sites were inspected across the entire state resulting in the following BMP implementation rates:

Harvesting BMPs when needed = 97.7%
Site Preparation BMPs when needed = 97.1%
Forest Road BMPs when needed = 95.5%
Stream Crossing BMPs when needed = 97.1%
Streamside Management Zones when needed = 96.9%
Firelane Stabilization when needed = 95.7%
Forest Chemical Application when needed = 95.2%
Overall BMP Implementation on the entire tract = 98.2%

To view the annual reports for previous years, visit www.forestry.alabama.gov and view the BMP section. Implementation surveys have been completed for the following years: 2009, 2010, 2013, 2016. In the years in between the implementation surveys, inspections are made on active logging sites for prevention and education—usually 250 inspections per year based on the previous year’s timber volume removal.


Submitted by: James P. Jeter, R.F. #88
 


Fiscal Year 2014-2015

Alabama timberland covers 23.0 million acres, the third largest commercial forestland in the nation. Approximately 94 percent of the state’s timberland is privately owned, and 6 percent is publicly owned. Forest industries (companies that own a wood processing plant) own approximately 7 percent of Alabama’s timberland, while 87 percent falls into the non-industrial private forest (NIPF) sector(1). In 2010, total sales of forestry and commercial logging was $1.0 billion and total sales of forest products manufacturing was $10.2 billion(2). To say the least,
forestry and the private forest landowner are very important to Alabama’s economy.

The forestry community is constantly under a microscope for non-compliance of environmental issues whether it be threatened and endangered species habitat, water quality, and/or wetland preservation. The Alabama Forestry Commission’s Best Management Practices for Forestry (BMP) program is dedicated to ensuring protection of the
environment, educating all the stakeholders, and prevention of the degradation of Alabama’s natural resources from any silvicultural practices.

Components of the BMP program with 2015 accomplishments include the following:

Complaint Resolution

The AFC has MOUs with the Alabama Department of Environmental Management and the U.S. Army Corps of Engineers to assist them, as the forestry technical expert, when addressing complaints that may be the result of a silvicultural activity. This year the AFC investigated 49 complaints alleged to have originated from silvicultural activities. Of those, 22 were deemed as a “not valid” complaints or “not related to silvicultural activities.” The
other 27 complaints were deemed “valid” and remediation actions taken. The AFC also worked with the State Implementation Committee of the Sustainable Forestry Initiative (a third-party certification program)
to mitigate two inconsistent practices cases.

Education

Environmental laws and regulations are very dynamic and change rapidly at times. To keep all forestry stakeholders informed the AFC is committed to be the most up-to-date forestry technical agency dealing with and relating these
changes through BMP program events. This year the AFC completed 29 such events, reaching 1,367
stakeholders. The agency was also able to donate 15,000+ BMP manuals to the State Department of
Education (ALSDE) for distribution to agriculture teachers in support of their teaching efforts in
classrooms throughout Alabama. They will also be used as part of an in-kind match for an Appalachian
Regional Commission (ARC) Forestry Worker Certification Program grant.

Prevention

As part of the ongoing effort to monitor the implementation of forestry BMPs, the AFC completed a total of 360 inspections: 265 inspections of randomly-selected, active logging jobs; 29 landowner invitations to inspect; and 66 internal AFC fire-line audits. Inspections on active tracts target deficient areas that showed up from inspections on closed-out tracts during the implementation monitoring cycle that is done every third year. These inspections on
active tracts enable AFC personnel to interact with the loggers as they work, and provide one-on-one active
instruction.

1 – Alabama Forestry Commission, 2014 Forest Resource Report
2 – Economic Impacts of Alabama’s Agricultural, Forestry, & Related Industries, 2013


Fiscal Year 2013-2014

Based on 2013 Forest Inventory Analysis (FIA) data, 869,394 acres of forest land in Alabama underwent some type of timber harvesting activity annually for the years 2001 through 2013. This acreage figure does not include all the acres that had some other type of silvicultural practice each year. It would be fair to say that each year for the past 12 years there was close to one million acres of forest land per year in Alabama that incurred some type of silvicultural practice. Alabama’s Best Management Practices (BMPs) for Forestry help producers perform silvicultural practices while protecting the waters of the state and waters of the United States.

The Alabama Forestry Commission implements many initiatives that ensure forest landowners of the state have the freedom to exercise their private property rights while protecting water quality.

The following BMP initiatives were addressed and implemented by the AFC in fiscal year 2013-2014:

BMP Educational Programs: 27 individual programs were presented to over 1,047 participants. The participants included landowners, loggers, foresters, university students, elected officials, and AFC staff.

Third Party Certification Programs: There were 16 requests for information from program participants that were fulfilled.

BMP on the ground inspections for education and prevention:

Active logging sites: 258 inspections statewide were completed
AFC was invited to look at another: 24 sites
Other random inspections: 8 sites
290 total on the ground inspections made

AFC Internal Audits on AFC work completed: 73 on the ground inspections made

Silvicultural Complaint Resolution: Through our written memoranda of agreements with the Alabama Department of Environmental Management and the U. S. Army Corps of Engineers, the AFC investigated 51 complaints that were allegedly caused by silvicultural activities. All 51 complaints were resolved or deemed a non-valid water quality complaint for this fiscal year. There were 23 valid complaints, 27 invalid complaints. One tract received two complaints.


Fiscal Year 2012-2013

Best Management Practices for Forestry are non-regulatory guidelines (except for U. S. Army Corp of Engineer’s 15 mandated BMPs for forested wetlands) suggested to help Alabama’s forestry community maintain and protect the physical, chemical, and biological integrity of waters of the State as required by numerous state and federal acts.

Alabama has 22.8 million acres of forest land. Of that acreage, over 33% (7.5 million acres) is certified under one of three third party certification programs; some maintain dual certification. Each certification program mandates the use of Alabama’s BMPs for forestry; therefore, they are not voluntary guidelines for participants of any third party certification.

The Alabama Forestry Commission accepts the responsibility to maintain and update these BMPs whenever necessary. The AFC also accepts the responsibility to monitor the implementation of BMPs so that the forestry community will have an unbiased implementation rate to prove the good stewardship being enacted by the private forest landowners of the State as well as Alabama’s forest industry.

The following is a listing of accomplishments and results toward the goal of proving good stewardship.

A total of 386 BMP inspections were completed by AFC associates:

83 AFC internal firelane inspections
45 Invitation and courtesy inspections on active logging jobs
258 Inspections on completed logging jobs, randomly selected over the State for BMP implementation rate scoring

This year’s implementation rating for BMPs in the following categories are:

Harvesting = 97.14%
Site Preparation = 96.77%
Forest Roads = 93.09%
Stream Crossings = 93.44%
Streamside Management Zones = 98.39%
Fireline Establishments = 96.83%
Forest Chemical Application = 100%
Overall BMP Implementation = 97.75%

Out of these 258 inspections, only two tracts resulted in having a Significant Risk to water quality as a result of failed BMP implementation.

The Commission will work in a cooperative manner with all state and federal agencies when dealing with water quality complaints that are a result of a silvicultural activity. This year the AFC responded to 30 complaints; 17 of which were deemed as being invalid or non-silviculture in nature while 13 were deemed as valid complaints. All 30 complaints were thoroughly investigated with resolution being made with all but two. The two open complaints will be carried forward to the next fiscal year for resolution.

The AFC also conducts BMP training for any interested party. This year, 26 BMP programs were presented, reaching over 1,700 foresters, loggers, landowners, and students.

The AFC also provided information dealing with BMP implementation to 22 forest products companies for their third party audits. These same implementation numbers were submitted several times to professional forestry organizations for their use.

The AFC has worked with many groups this year dealing with water quality:

Alabama Water Agency Working Group Forest Stewardship Council
Office of Water Resources Sustainable Forestry Initiative
Alabama Department of Environmental Management U. S. Endowment for Forestry
Alabama Clean Water Partnership The Forest Foundation
Alabama Forestry Association U.S.D.A. Forest Service
Environmental Protection Agency Alabama Tree Farm
U.S. Department of Justice U.S. Army Corp of Engineers

All trying to make sure Alabama has clean water while working forests remain working.

Submitted by: James P. Jeter, R.F. #881


Fiscal Year 2011-2012

This fiscal year brought all types of challenges for the Alabama Forestry Commission in defending numerous attempts, at various levels, to regulate the activities of private forest owners as they manage their forestland in Alabama. The agency met with a variety of groups and submitted several written documents in this defense.

In March of 2012, the AFC met with representatives of the Southern Environmental Law Center (SELC) to discuss the management of and harvesting of cypress in Alabama. The meeting was very informative for both parties. A common understanding was reached and an understanding of how both entities operate in Alabama was achieved.

Following this meeting, there was a request and a push to reply to the request of the Environmental Protection Agency (EPA) for comments on the “Forest/Logging Road Ruling” made by the 9th Circuit Court. The Commission provided information from our existing Best Management Practices (BMP) program in the form of a formal reply to EPA directly, the Southern Group of State Foresters, and the National Association of State Foresters. Alabama’s Attorney General also sent a reply. This case will be heard by the U. S. Supreme Court and could have major consequences for forest landowners across the nation.

The AFC also continued to work with and improve our knowledge of environmental issues pertaining to forestry in Alabama by implementing the signed Memorandums of Understanding (MOUs) with the Alabama Department of Environmental Management and the U. S. Army Corps of Engineers (USACE) – Mobile District. These relationships have proved invaluable to the forest landowners of Alabama.

Education, training, and prevention were key elements of the 2012 BMP program. Existing partnerships were maintained and enhanced as well as new ones being developed. An example of a new partnership is the Alabama Water Agencies Working Group (AWAWG). The Commission was asked by this group for input as a major stakeholder, meetings were held, and input was developed and submitted.

The forest industry is supported by this AFC program as information is gathered and compiled to show auditors that voluntary BMPs are working and providing water quality protection.

Activities for 2012

  • Education and Training: 26 programs were presented and 1,514 people attended including loggers; professionals; landowners; foresters; elementary, high school, and college students

  • Prevention and Education: 293 random inspections were conducted on active logging sites representing 30,393 acres and 226 different landowners. Nine inspections by invitation were performed before harvest activity was started.

  • Compliance and Education: 42 silvicultural water quality complaints were addressed by the AFC in conjunction with ADEM and USACE; 22 were valid complaints, 20 were not valid.

  • AFC Education and Prevention: 71 AFC internal audits on AFC work completed.


Fiscal Year 2010-2011

Fiscal Year 2010-2011 started off with Alabama hosting the annual meeting of the Southern Group of State Foresters’ Water Resources Committee in Auburn, the last week in October 2010. The meeting was well attended by representatives from 11 of the 13 southern states and representatives from the Southern Group of State Foresters, Environmental Protection Agency, Auburn University, and the Alabama Farmers Federation.

This year some changes/modifications to the BMP program were implemented. These changes were a result of the program review that took place in August of 2010. The Water Resources Review Team made some suggested changes that would improve Alabama’s program. The changes are as follows:

Program Focus: Changed from an annual implementation survey to an every third year implementation survey. The two years in between will facilitate an increase in BMP program presence by using those years to complete courtesy checks on active logging jobs. This will strengthen the education and prevention components of the program.

Education and Training: BMP Coordinator taught the BMP portion in the initial training sessions for the Professional Logging Manager (PLM) training as recommended by the review team.

Institutional Arrangements: A Memorandum of Understanding (MOU) with the U. S. Army Corps of Engineers is in the process of being signed.

Funding: AFC may lose 319 Base Funding next year - $65,000.

Accomplishments:
245 courtesy inspections completed
229 different landowners on 24,080 acres
53 other inspections completed
74 AFC internal fire lane audits completed
31 BMP programs presented reaching 1,777 loggers, landowners, students, foresters, and other professionals

Thirty-two water quality complaints related to silviculture were investigated by AFC personnel with 16 of those being valid resulting in more action while 16 were not valid resulting in any further action not being needed.

NOTE: Complaints in total as well as valid complaints for 2011 were 50% less (32 vs. 62) than in 2010. This may be attributed to the increase of inspections on active sites or strictly weather, maybe both.

BMP Coordinator continues to work and communicate with the following Committees:
Tree Farm Committee
Logger’s Education Committee
State Implementation Committee – SFI
Clean Water Partnership – Basin Groups

Regulatory Agencies that we deal with on a consistent basis:
U.S. Army Corp. of Engineers
Alabama Department of Environmental Management
Environmental Protection Agency


Fiscal Year 2009-2010

Fiscal Year 2009-2010 set another benchmark by the Alabama Forestry Commission with the Best Management Practices for Forestry Program. The Southern Group of State Foresters (SGSF) Water Resources Committee conducted a Program and Technical Assistance Review during August 2010. This review noted no deficiencies and stated the program had made vast improvement since the 2006 review. The Alabama Forestry Commission is now considered to fully adhere to the SGSF framework for the first time in the program’s existence.

Other accomplishments include:

  • Published a white paper on “Woody Biomass 101 for Alabama Forest Owners”

  • A “Selling Your Timber” campaign was developed that stresses the use of BMPs. (Additional information under the “Outreach and Education” section)

  • Another round of BMP implementation inspections was completed that included 245 closed out tracts. Percent of implementation of BMPs for forestry was evaluated for the following categories listed in the table below.

Category Year Implementation # of Sites
Harvesting 09 96% 246
  10 98% 245
Mechanical Site Prep 09 98% 70
  10 98% 50
Forest Roads 09 93% 243
  10 93% 243
Stream Crossing 09 96% 125
  10 96% 94
Streamside Management Zones 09 92% 202
  10 97% 207
Firebreaks 09 90% 84
  10 97% 70
Chemical Application 09 100% 120
  10 98% 108
Overall Implementation 09 97% 246
  10 97% 245

Alabama’s numbers still beat the southeast regional percent of implementation by at least 10 percent for each category. However, these inspections showed five tracts to have a significant risk to water quality as compared to only two tracts last year. These inspections covered 187 different landowners representing 24,474 acres of timberland.

The AFC worked with Auburn University and the Alabama Forestry Association to try to pinpoint what areas need more attention during logger education.

Twenty-eight programs were presented that targeted private landowners, loggers, contractors, foresters, and students. Over 1,984 contacts were made.

There were 61 water quality complaints addressed by AFC staff. Fifty-eight of those have been resolved at the AFC level; the other three are still being investigated. Of the 61 complaints, 29 have been determined to be “not valid” as a silvicultural complaint and 32 have been classified as “valid” silvicultural complaints.

Seventy-two additional inspections were made statewide on active logging operations to promote BMPs and our educational effort. Seventy-three internal audits were made on AFC installed firelanes as well.

Federal and State agencies as well as partnering non-government organizations (NGOs) have been very helpful in establishing and/or re-establishing good working relationships that have continued to move this program forward. Successful 319 funding has bolstered the program funding and has also helped sustain the level of activity in this program.


Fiscal Year 2008-2009

This is the first year the Alabama Forestry Commission (AFC) collected Best Management Practices (BMP) implementation data based on the protocol set forth by the Water Resources Committee of the Southern Group of State Foresters. This data will aid in the educational efforts of the AFC and Forest Industry when dealing with silvicultural practices that may affect water quality in the waters of the state. Traditional silvicultural practices include logging, road building and maintenance, reforestation, site preparation, prescribed burning, herbicide application, fertilization, and any other silvicultural activity. The Alabama Forestry Commission, through a Memorandum of Understanding with the Alabama Department of Environmental Management, monitors implementation of BMPs for forestry on an annual basis. This year a total of 246 sites were randomly selected for the survey. The sites were located on 188 different landowners and represented some type of harvest on 26,550 acres. Each site was visited on the ground and implementation was evaluated for the following parameters: timber harvesting techniques, site preparation, forest roads, stream crossings, streamside management zones, firebreak stabilization, forest chemical application, and overall implementation of BMPs on the tract. If we found that a needed BMP practice was not implemented or implemented improperly then the significant risk to water quality was evaluated.

Significant risk to water quality from failure to implement a BMP was found on three tracts that were evaluated. Two more tracts showing significant risk to water quality were discovered through inspections for technical assistance for federal or state cost-share practices. Educational activities corrected the problems.

Parameters Number of
Sites
Alabama 2009
% Implementation
13 Southern States
1997 - 2007
% Implementation
Harvesting 246 243

89

Site Prep

70

98 90
Forest Roads 243

93

86
Stream Crossings 125 96 85
Streamside Mgt Zones 202 92 88
Firebreaks 84 90 73
Chemical Application 120 100 97
Overall 246 97% 87%

The rate of implementation for each category of practice helps show where and what kind of education is needed as well as which audience needs addressing whether it be the general public, private landowners, or forest industry. This year alone 30 training and/or public presentations were made that dealt with BMP education.

    7 presentations for 200 private landowner contacts
    2 presentations for 55 high school or college students
    8 presentations for 234 AFC associates
    6 presentations for 163 state or local government officials
    7 presentations for 357 forest industry contacts

All of these presentations were accredited for Continuing Education and/or Professional Logging Manager points for attendees. There were 72 invitation and/or courtesy checks made on active logging sites representing another 6,731 acres where PLM credit was awarded.

Internal AFC audits were performed on 68 sites across the state representing another 9,655 acres where some type of silvicultural activity took place and work, mainly fire lanes, was accomplished by AFC crews.

Jim Jeter, Alabama’s BMP Coordinator represented the AFC by participating on two subcommittees of the Southern Group of State Forester’s Water Resources Committee which published information for Bottomland Hardwood Management (Silvicultural Operations) and Woody Biomass Guidelines. He is active with the State Implementation Committee of the Sustainable Forestry Initiative (SFI) and all 10 Clean Water Partnerships in Alabama.

The AFC successfully completed the first year of the 319 grant with the Alabama Department of Environmental Management and is half way through the second year. Two Coastal Alabama Forestry Preharvest Planning Workshops were held to educate loggers, landowners and natural resource professionals on the benefits of Preharvest Planning in Alabama’s Coastal Counties.

Thirty-two (32) Alabama companies are currently SFI members with the numbers growing every day. BMP implementation data continues to be in high demand for this program and is an integral part of SFI audits by third parties.

Complaint Resolution through Education involved 45 complaints, statewide, 40 of which have been resolved at the AFC level.

    23 Invalid complaints/not a forestry issue
    22 Valid complaints
    40 Complaints resolved at AFC level
    8 Complaints sent to ADEM for further action
    5 Complaints still being resolved


 Fiscal Year 2007-2008
The Alabama Forestry Commission is proud to be partnered with the Alabama Clean Water Partnerships, a group that represents the ten major river basins in Alabama. The AFC provides a technical forester to each basin represented. It is vital that we protect these waters in every way possible. Alabama landowners have completed some type of harvest on an average of 812,000 acres per year for years the 2001 to 2007. It is imperative that silviculture is not a significant risk to water quality during these operations. Fiscal Year 2007-2008

The AFC completed 300 random ground inspections on 92 harvested sites
and 208 active sites, representing
31,051 acres. Overall implementation
rate for the 92 completed tracts was
96%, representing 6,903 acres.

Past research has proven that if forestry practices are conducted while following Alabama’s Best Management Practices (BMPs) for Forestry (EPA approved guidelines), water quality is protected. The Alabama Forestry Commission’s role is to ensure that Alabama’s BMPs are followed when implementing forestry practices. This is done by randomly monitoring forestry practices for BMP compliance and investigating BMP complaints received from concerned citizens.

The AFC also provides education and training to landowners and loggers (pre-harvest consultation), and serves as technical advisors on clean watershed partnership committees.

The Commission is striving to improve the BMP program by meeting the framework set forth by the Water Resources Committee of the Southern Group of State Foresters (SGSF). This will allow Alabama to have a measure of its program effectiveness along with the other 12 southeastern states.

Education is achieved by AFC associates talking to landowner and forest industry groups. This year over 300 individuals received BMP training at nine different programs around the state.

Internal training consisted of 66 AFC employees learning how to better serve the BMP needs of the state. Commission personnel also participated in the Sustainable Forestry Initiative’s Environmental, Logger Education, Landowner Education, and Inconsistent Practices committees to encourage the proper implementation and maintenance of BMPs.

This year the AFC has responded to 46 complaints statewide. Of those complaints, 18 were invalid, 9 did not result from silviculture and have been sent back to ADEM, 36 were resolved at the AFC level through education, and 1 is still in the process of being resolved.

The sites were then examined on the following categories:

  • Streamside Management Zones adequate
  • Stream Crossings adequate
  • Forest Roads adequate
  • Timber Harvesting adequate
  • Reforestation/Stand Management adequate
  • Forested Wetland Management adequate
  • BMP adequately implemented during overall operation(s)

Upon the recognition of a problem in any of these categories, the site was deemed out of compliance and further action was taken to achieve compliance.

Alabama's Best Management Practices for Forestry

The BMP Program | BMP Publication  (online) (PDF) | BMP Random Monitoring Report (pdf version)|


Additional Information:

http://www.adem.alabama.gov/
http://www.epa.gov/
http://www.aces.edu/waterquality/