United States Region 10 SPA-10-iD-WGMP-l-79
Environmental Protection 1200 Sixth Avenue
Agency Seattle WA S8101
,
Water March 1980 EPA 910/9-79-060
&EPA Environmental
Assessment
Idaho Forest Practices
Idaho Statewide
Water Quality Management Plan
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U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE
Seattle, Washington 93101
?A. ,-P
"two? M/S 443
1^2 1 0 1980
To All Interested Government Agencies, Public Groups and Citizens
Pursuant to Section 102(2)(c) of the National Environmental Policy
Act of 1969 and Section 208 of the Clean Water Act of 1977, I am
forwarding for your review this Final Environmental Assessment for
the Forest Practices element of the Idaho Statewide Water Quality
Management Plan. The final assessment contains a summary of the
draft environmental assessment, an errata section, letters of
comment on the draft environmental assessment, and responses to
those comments. This assessment forms a technical appendix to the
Water Quality Management Plan. The Plan was certified by the
Governor of the State of Idaho on January 8, 1980 and has been
submitted to EPA for aporoval. EPA expects to complete approval
by April 30, 1980.
If you have any questions or comments, please submit them to:
Additional copies of this document may be requested at the above
address.
Sincerely,
Craig Partridge
Environmental Evaluation Branch
EPA Region 10
1200 Sixth Avenue, M/S 443
Seattle, Washington 98101
'Donald P. Dubois
Regional Administrator
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FINAL ENVIRONMENTAL ASSESSMENT
IDAHO FOREST PRACTICES
Idaho Statewide Water Quality Management Plan
Prepared By:
U. S. Environmental Protection Agency
Region 10
Seattle, Washington 98101
With Technical Assistance From:
Jones & Stokes Associates, Inc.
2321 P Street
Sacramento, California 95816
Responsible Official:
Donald P. Dubois
Regional Administrator
MAR 10 <980
Da C3
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TABLE OF CONTENTS
Page
SUMMARY 1
Chapter 1 - INTRODUCTION 3
History and Purpose of Proposed Plan 3
Purpose and Content of the Final Environ-
mental Assessment 4
Chapter 2 - SUMMARY OF PROPOSED ACTION 7
Forests of Idaho 7
Environmental Effects of Nonpoint Source
Pollutants 11
Conservation Programs for Idaho Forest Lands 13
BIBLIOGRAPHY 18
Chapter 3 - ERRATA 19
Chapter 4 - RESPONSES TO COMMENTS 21
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SUMMARY
The Clean Water Act (PL 95-217) and its amendments set
forth the objective "to restore and maintain the chemical,
physical and biological integrity of the nation's waters."
Under Section 208 of the act, each state is authorized to
develop a statewide water quality management plan to.1).identify
nonpoint source water quality problems, 2) develop strategies
for their solution and methods to implement such solutions
and 3) develop a process for evaluating plan effectiveness
in meeting goals of the Clean Water Act.
In Idaho, forest practices, such as road construction
and maintenance, timber harvesting and transport, reforestation,
slash management and chemical application, can adversely
affect water quality through introduction of nonpoint source
pollutants such as sediment, organic matter, dissolved nutrients,
fertilizers, pesticides, herbicides and other chemicals.
Vegetation manipulation that alters solar radiation levels
can influence water temperature regimes. Field investigations
have revealed that the majority of water quality problems
are related to road construction and maintenance practices,
particularly when they occur in the Batholith region - an
extensive forested zone in central and south-central Idaho
and the panhandle region, characterized by steep slopes and
shallow, highly erodible granitic soils. Sediment is the
primary nonpoint source pollutant resulting from two processes:
1) surface erosion from newly-constructed or poorly-maintained
roads, and 2) mass erosion from roads constructed on steep
and unstable slopes.
Idaho's nonpoint source pollution problem associated
with forest practices has been addressed in the Draft Water
Quality Management Plan for Forest Practices prepared by
the Idaho Department of Health and Welfare - Division of
Environment (IDHW-DOE) (1979). This document presents
1) an assessment of the nonpoint source pollution problem,
2) and evaluation of the Idaho Forest Practices Act (IFPA)
and its Rules and Regulations as Best Management Practices
(BMPs) and 3) an evaluation of forest practices and admini-
stration on state, private and federal forest lands. The
resulting plan recommends adoption of revised IFPA Rules
and Regulations as BMPs coupled with improvements in admini-
stration and enforcement. An action plan for implementing
recommendations and evaluating overall effectiveness of the
plan is also presented.
1
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In keeping with objectives of the Clean Water Act, imple-
mentation of Idaho's water quality management plan for forest
practices should have a beneficial impact on overall water
quality. The degree of improvement will depend primarily
on the appropriation of additional Idaho Department of Lands
(IDL) staff to administer and enforce the IFPA revised Rules
and Regulations on state and private lands, and adoption and
enforcement of the IFPA Rules and Regulations on federal
lands.
Adequate enforcement coupled with education and voluntary
compliance by logging operators should beneficially impact
water quality. Associated resident and migratory fish species
would be benefically affected by reductions in: 1) sedimentation,
2) serious drops in dissolved oxygen levels, and 3) detrimental
water temperature changes in spawning, rearing and migratory
streams. Other downstream uses, such as domestic and industrial
water supplies and recreation, should also be benefically
affected.
Additional potential benefits of plan implementation
include: 1) reduction in losses of native riparian vegetation,
2) improved wildlife habitat, 3) reduction in soil and soil
nutrient losses, and 4) improved forest productivity.
Negative impacts of implementing the water quality manage-
ment plan for forest practices are primarily economic in
nature. Implemenation of BMPs by the logging industry will
require greater capital outlay. It has been estimated, however,
that these additional costs will be relatively insignificant.
Significant economic impacts will be experienced by governmental
implementing agencies. Specific tasks or personnel needs
associated with implementation of the forest practices 2 08
plan include hiring 10 additional IDL forest practices officers,
their assistants and equipment; hiring an IDL soil scientist
conducting land systems inventories on state and private
lands; classifying Idaho streams in terms of their importance
to fish and as drinking water supplies; conducting pilot
watershed studies; evaluating and upgrading the 208 plan
by a forest practices audit team; and coordinating plan imple-
mentation by the IDHW-DOE. Costs associated with these tasks
are estimated to be under $1,000,000 annually.
2
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Chapter 1
INTRODUCTION
History and Purpose of Proposed Plan
The Clean Water Act or Federal Water Pollution Control
Act of 1972 (PL 92-500) and its amendments set forth the
objective "to restore and maintain the chemical, physical
and biological integrity of the nation's waters". To achieve
this objective, the act established water quality improvement
programs. Section 208 of the Clean Water Act authorizes
each state to develop a statewide water quality management
plan. This plan must contain a detailed identification of
nonpoint source water quality problems*, a strategy for their
solution, a program for implementing such solutions and a
process for evaluating their effectiveness in meeting stated
clean water objectives. Section 208 provides for federal
funding of state planning efforts through the U. S. Environ-
mental Protection Agency (EPA).
In Idaho, forest practices (silviculture), including
road construction, timber harvesting, reforestation, application
of chemicals and fertilizers, and slash management, have been
recognized as signifciant contributors to the state's nonpoint
source pollution problems. As a result, a significant portion
of the total Idaho 208 planning grant was designated for
development and implementation of a water pollution abatement
plan to eliminate or reduce any pollution arising from forest
practices.
The agency responsible for statewide water quality manage-
ment planning is the Idaho Department of Health and Welfare,
Division of Environment (IDHW-DOE). The IDHW subsequently
contracted with the University of Idaho College of Forestry,
Wildlife and Range Sciences, who established a forest practices
Technical Review Team (TRT) to develop background information
for use in the water quality management plan dealing with
silvicultural activities. Key elements of the planning process
*A nonpoint source can be defined as any origin from which
a pollutant is discharged in a diffuse, unconfined and
unchanneled manner including but not limited to drainage
and runoff.
3
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necessary for effective implementation of a water quality
management plan for forest practices included: 1) an assess-
ment of existing nonpoint source water pollution problems
associated with Idaho forest practices; 2) an evaluation
of forest practices, administration and enforcement; and
3) technical evaluation of applicable legislation and re-
commendations for promulgation of new, or modifications of
existing, rules and regulations of the Idaho Forest Practices
Act of 1974 (IFPA) "best management practices" (BMPs). The
State of Idaho has submitted to the EPA the state's plan for
regulating forest practices, Water Quality Management Plan
for Forest Practices (1979) .
Purpose and Content of the Final
Environmental Assessment (EA)
This Final EA has been prepared to respond to comments
and discuss environmental issues raised with regard to the
Draft EA, as required by the National Environmental Protection
Act and the implementing guidelines and EPA regulations.
Recent changes to the Council on Environmental Quality (CEQ)
guidelines for preparing EAs allow the Final EA to take several
forms. The Draft EA can be revised in its entirety to reflect
project changes and/or public comment, or a supplemental
document may be prepared that includes only comments, responses
to comments and changes in the Draft EA. Because it is felt
that comment on the Draft EA did not raise substantive new
issues or create major changes in the approach to the forest
practices 208 plan, this Final EA has been prepared as a supple-
ment to the Draft EA.
This introduction is followed by a summary of the proposed
action and a number of issue-oriented statements that respond
to comments on errors in the EA and on the plan's major environ-
mental impacts. All letters of comment are attached at the
back of this report.
Copies of the full Draft EA may be obtained by: writing
to Mr. Roger Mochnick, U. S. Environmental Protection Agency,
Region X, 1200 Sixth Avenue, Seattle, Washington 98101. Copies
of the report are also on file at the IDHW office in Boise.
Distribution of the Final Environmental Assessment
EPA is distributing this EA to the following parties:
4
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FEDERAL AGENCIES
U. S. Department of Agriculture
Soil Conservation Service
Agricultural Stabilization and Conservation Service
Area Conservationist
State Conservationist
Forest Service
U. S. Department of Commerce
National Marine Fisheries Service
U. S. Department of Defense
Corps of Engineers
U. S. Department of Health, Education, and Welfare
U. S. Department of Housing and Urban Development
U. S. Department of Interior
Bureau of Land Management
U. S. Fish and Wildlife Service
U. S. Department of Transportation
Federal Energy Office
Advisory Council on Historic Preservation
Department of Fish and Game
Department of Parks and Recreation
Department of Water Resources
ORGANIZATIONS
Idaho Conservation League
Idaho Environmental Council
Idaho Wildlife Federation
North Idaho Forestry Association, Inc.
Potlatch Corporation
5
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Chapter 2
SUMMARY OF PROPOSED ACTION
Idaho is the most heavily forested state in the Rocky
Mountain region. Lumber production in Idaho ranks fourth
in the nation behind Oregon, Washington and California. In
Idaho, timber is the third largest industry in the state
with agriculture and mining ranking as the number one and
number two industries, respectively.
Forests of Idaho
Forest lands in Idaho total 21.6 million acres or 41
percent of the state (Figure 2-1). Nineteen species of conifers
occur in Idaho forests. The four predominant commercial
species are Douglas-fir, grand or white fir, Idaho white
pine and ponderosa pine. These species (including larch,
which generally is associated with harvesting of Douglas-
fir) account for approximately 71 percent of the commercial
harvest annually (Idaho Division of Tourism and Industrial
Development [IDTID], 1977). Other commercial species are
Engelmann spruce, western red cedar, lodgepole pine and western
hemlock.
Of the 21.6 million acres of forest lands in Idaho 15.9
million acres (74 percent) are considered to be commercial,
meaning they are capable of providing 20 cubic feet of fiber
per acre per year. The remaining 5.9 million acres of forest
are noncommercial, either unproductive timber land and juniper
woodland or wilderness, primitive or recreation areas on
lands preserved for those purposes.
Approximately 71 percent or 11.3 million acres of
commercial forest lands in Idaho are managed by the federal
government. The U. S. Forest Service (USFS) (Regions I and
IV in Idaho) is the largest federal agency managing commercial
forests as mandated by numerous acts and related amendments
beginning with the Organic Act of 1897 and continuing through
the National Forest Management Act of 197 6. Approximately
95 percent of federally-managed commercial forests are under
their [jurisdiction. Other federal agencies managing sub-
stantial acreages of commercial forest land are the U. S.
Department of Interior, Bureau of Land Management (BLM), and
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Vegetation Type
Table 2-1
ACREAGES OF FOREST VEGETATION TYPES IN IDAHO
Acreage (millions)
Percent of State
Commercial
Ponderosa Pine
Douglas Fir
Lodgepole Pine
Spruce Fir
Larch
White Pine (Cedar-Hemlock)
True Firs
Other
Subtotal
Noncommercial
Productive Reserved
Unproductive
(Juniper Woodland)
Subtotal
Total Forest Land
1.5
4.7
2.4
. 7
. 9
1.5
2.4
1.7
15.9
i.a
3.9
(1.6)
5.7
21.6
2.9
9.0
4 . 6
1. 3
1. 7
2.9
4 . 6
3.2
30.3
3.4
7.4
(3.0)
10.9
41.2
SOURCE: Sharp and Sanders, 1978.
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Figure 2-1
F022S7 TYFSS IM THE
STAT 2 0? IDAHO
- LEGEND-
M WHITE PINE
PONOEROSA PinE
loogepole pine
OOUGlAS flP
~ fin t SPRUCE
NON - CO MM£nClAL
| j NCN - rOflEST
- ISI —
NOTE Stvtrol Kinds Of Trvtft Art Usually
Found Growing in Th# Some Ar«a
Tor Eiomolt whit* Fir,C«dar, And
Httntoc* Ar« Commonty A%»ocici«d
Wiin white Pine
^'"W^ A ^
v ¦¦ -
.(rrc4!an |
JCiiCviu f /
7"-lQ ^
Twi* mis
Jb-hioc*
I 3*£lOi 0 ("J " ' * \
O' ns ""'M\ \
>J 2 V A S
H
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Bureau of Indian Affairs (BIA). Minor holdings are administered
by the U. S. Department of Agriculture (USDA), Agriculture
Research Service, Bureau of Reclamation, and U. S. Army Corps
of Engineers.
The State of Idaho owns and administers approximately
880,000 acres (6 percent) of commercial forest land (Idaho
Department of Lands [IDL], 1978). Approximately 491,000 acres
of state land are included in state forests. An additional
18,000 acres (<1 percent) are owned and managed by counties
(IDTID, 1977) . State and county lands are administered by
the IDL under direction of the State Board of Land Commissioners.
Privately-owned commercial forest lands, primarily in
northern Idaho, exceed 3 million acres with forest industries
controlling approximately 31 percent, farmers 26 percent,
and woodlot owners 43 percent (IDTID, 1977) .
Forest operations are divided into four general categories
for the purpose of examining nonpoint source pollution: timber
harvesting, road construction and maintenance, site preparation
for reforestation, and application of silvicultural chemicals.
Timber Harvesting
The physical act of falling, yarding, loading and hauling
timber will without question impact the forest environment.
Soil erosion resulting in stream sedimentation, is the most
serious nonpoint source pollution associated with timber
harvesting.
Road Construction and Maintenance
The initial on-the-ground activity associated with a
forest operation is the development of a road system to remove
harvested forest products. Sediment control during and after
road construction is of primary concern. Many studies m
Idaho label road construction as the number one accelerated
source of sediment in forest streams (Megahan and Kidd, 1972;
Gonsior and Gardner, 1971; Megahan, 1977).
Site Preparation for Reforestation
Site preparation for reforestation includes those operations
necessary to prepare a site (usually after harvest) to receive
tree seedlings or seed with reasonable expectations of survival.
10
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Two methods are discussed m this section: slash burning
and mechanical scarification. Chemicals, particularly herbi-
cides, are widely used in reforestation.
Silvicultural Chemicals
In recent years forestry has increased its use of chemicals
to control forest pests and undesirable vegetation. Chemicals
have also been used to increase forest soil productivity.
The use of chemicals in the forest is usually motivated by
a desire to increase or restore fiber production on narvestable
timber acreage.
A comprehensive review of current data related to the
use of silvicultural chemicals and their impact on water
quality has been published by EPA (1977).
Environmental Effects of
Nonoomt Source Pollutants
According to the Draft Water Quality Management Plan
for Forest Practices (IDHW, 1979) the severity of water
quality degradation caused by silvicultural activities is
dependent upon climate, characteristics peculiar to a watershed
and the practices applied by man. In general, water quality
problems caused by forest practices in Idaho are localized
and restricted to the particular stream where the activity
is conducted. However, downstream uses, including domestic
and industrial water supplies, fish habitat, recreation,
etc., may also be impaired by the cumulative effect of silvi-
cultural activities upstream.
At times the water quality impact of silvicultural
activities is difficult to distinguish from natural sources
of sediment and other pollutants. This is because trends
are slow and changes may not be perceptible using existing
water quality measurement techniques. The most obvious water
quality problems have occurred as a result of extensive develop-
ment of sensitive or unstable watersheds in combination with
extreme climatic events.
On an areawide basis, the Idaho Batholith is considered
to have the greatest potential for water quality problems
related to silvicultural activities (Figure 2-2). The
16,000-square-mile Batholith area, which contains valuable
timber reserves, is characterized by steep topography and
shallow, coarse-textured soils overlying granitic bedrock.
11
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12
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Soils derived from parent material of this type are highly
erodible and susceptible to landslides. Several studies
have been done in Idaho describing the erodible nature of
the Batholiuh area in relation to silvicultural activities
(Gonsior and Gardner, 1971; Megahan and Kidd, 1972).
On a site-specific basis, identification of water quality
problems in Idaho streams is provided in the Idaho Water
Quality Status Report (IDHW, 1973) . According to that report,
forest practices were considered minor or major contributors
to water cuality problems at 18 of 33 samolmg stations (Table
2-2) .
Conservation Procrams for Idaho Forest Lands
Federal Programs
U. S. Forest Service (USFS). Management authority of
the USFS is mandated by numerous federal acts and related
amendments. Some of the more important acts governing silvi-
cultural activities on USFS land are:
1) The Organic Act of 1897
2) The Weeks Act of 1911
3) The Multiple Use-Sustained Yield Act of 1960
4) The National Environmental Policy Act of 1969 (NEPA)
5) The Clean Water Act of 1977 (which revised the
Federal Water Pollution Control Act of 1972 [PL
92-500])
6) The National Forest Management Act of 1976
Bureau of Land Manacement (BLM) . The BLM is responsible
for the management, of 502,000 acres of commercial forest
land in Idaho. Although a small area when compared to the
acres managed by the USFS, the BLM is involved in significant
timber sale activity in this area.
The NEPA of 196 9 and the Clean Water Act and amendments
mandate forest management activities of the 3LM. Therefore,
BLM timber sales are subject to detailed environmental analysis
and subsequent preparation of Environmental Assessment Reports
or Environmental Impact Statements as is the USFS.
Acricultural Stabilization and Conservation Service
ASCS). The ASCS administers two programs relating to forest
resource conservation. These are the Forest Incentives
Program (FIP) and the Acricultural Conservation Program (ACP).
Each program is designed to provide cost-iharing for non-
industrial private forest owners.
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Table 2-2
STREAM SEGMENTS WITH SIGNIFICANT NONPOINT
SOURCE POLLUTANT PROBLEMS RELATED TO
FOREST PRACTICES IN IDAHO1
Trend Analysis Station2
Upper Snake Basin
2. Henry's Fork near Rexburg
7. Blackfoot River near Blackfoot
9. Rock Creek near Twin Falls
11. Malad River above Malad Canyon
Bear River Basin
2. Bear River at Soda Springs
4. Bear River at Preston
Southwest Idaho Basin
3. Boise River near Parma
4. Payette River near Payette
5. Weiser River near Weiser
8. Snake River below Hell's Canyon Dam
Salmon Basin
1. Salmon River at Whitebird
Clearwater Basin
1. Clearwater River at Spalding
2. Snake River at Anatone, Washington
Panhandle Basin
1. Kootenai River near Copeland
3. S. F. Coeur d1 Alene River at Enaville
4. Coeur d' Alene River at Enaville
6. Spokane River at Post Falls
7. St. Joe River at St. Maries
Contribution of Forest Practices
to Water Quality Problems
Minor
Minor
Minor
Minor
Minor
Minor
Minor
Minor
Minor
Major
Minor
Minor
Minor
Minor
Ma]or
+
Major
1 SOURCE: Idaho Water Quality Status Report. Draft. Volume I,
Idaho Department of Health and Welfare - Division of
Environment. 1978.
2 Trend analysis stations shown in Figures 2-3 to 2-8 for each
hydrolocic basin.
3 Nonpoint source pollutant contribution from forest practices not
designated specifically as major or minor.
14
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Soil Conservation Service (SCS). The SCS in cooperation
with local Soil Conservation Districts (SCD) and the IDL
maintains a Woodland Conservation Program designed to protect
and improve privately-owned woodland for both commercial
and noncommercial objectives.
State Program
Idaho Department of Lands (IDL). The IDL governs forest
practices on state and private lands as authorized by the
IJPA (1974) and its rules and regulations adopted in 1976.
The act (Title 38, Chapter 13, Idaho Code) and its rules
and regulations specifically address the harvesting of timber
species and related road building, reforestation, application
of chemicals and fertilizers, and slash management as they
relate to economic, social and environmental considerations.
Harvesting is defined in the act as a "commercial activity."
Primary responsibility for compliance with the IFPA
is assigned to the logging operator. The act requires the
operator to notify the IDL before a forest practice is commenced
and to comply with rules prescribed by IDL.
Administration of the IFPA involves a number of activities
including notification procedures, inspection procedures
and schedules and enforcement and appeals. Details of these
activities are described in Chapter V of the Draft Idaho Water
Quality Management Plan for Forest Practices (IDHVJ, 1979)
wnich integrates the IFPA into the 20 8 water quality management
plan as best management practices.
Concsot of the Best Management Practice (BMP) . Nor.point
source water quality problems related to forest practices
can most effectively be controlled through application of
preventative or mitigative measures on the site of forest
practice. Such measures are termed BMPs. A BMP can generally
be defined as a practice or combination of practices which
is found to be effective and practicable (technologically,
economically, and institutionally) as a means of preventing
or reducing water pollution resulting from nonpomt sources
to a level compatible with water quality goals.
In developing a water quality management plan (WQM?),
the IDHW, having primary responsibility for 203 planning
in Idaho, recognized that a number of agencies at the present
time administer or otherwise regulate forest practices and
thus, would have the ability to implement 3MPs under a proposed
20 3 plan.
15
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Therefore, a Forest Practices Work Plan was designed
by IDHW in 1975 to evaluate present programs of these agencies
and make recommendations to improve forest practices or the
ability of each agency to ensure BMPs are applied.
Upon completion of several tasks, a draft and final
report entitled 20 8 Forest Practices Project (University
of Idaho, 1978) was submitted to IDHW, the Forest Practices
Technical Advisory Committee (FPTAC) and the Silvicultural
Subcommittee of the Policy Advisory Committee on the Idaho
Clean Water Program for review and subsequent endorsement.
The Idaho WQMP recommends that the rules and regulations
of the IFPA, with slight modifications, be adopted as BMPs
for protecting water quality in the State of Idaho. This
recommendation was based on evaluations of the IFPA rules
and regulations.
Proposed Implementation and Operation of the Forest
Practices Water Quality Management Plan. The IDL was designated
to implement applicable portions of the statewide 208 plan
on state and private lands and the USFS and BLM on their
respective federal lands. The IDHW was designated to coordinate
overall monitoring and implementation of the plan. The IDFG
was also designated and assigned specific responsibilities
under the plan. Figure 2-3 is an organizational chart of
implementing agencies and their major responsibilities.
Other agencies including the EPA, SCS/SCDs, the ASCS,
IDWR, the USDA CES, and the University of Idaho, as well
as representatives of private industry were not specifically
designated as implementing agencies but are key to the success
of the statewide WQMP.
Specific actions to be taken by implementing agencies
and target dates for their completion are detailed m Chapter
II of the draft 208 plan for forest practices (IDHW, 1979) .
16
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FIGURE 2-3
WATER QUALITY MANAGEMENT PLAN -
IMPLEMENTING AGENCIES & THEIR RESPONSIBILITIES
II. S. IJ'A^
1. GuitLi oiid eu^ort statu
iii|>liaikJitLation of 200
2. iii developing
wuLcr ijiulity ciitcria
oiU uonitoung
TlHtW. ItJlSi
Y. Cooidinaio imp) anon tat Ion of plan 1. Miter quality monitoring
2. lx.vo)up uuttr qtulity criteria oj4
i)V"Mll l»Jl IIKJ pL'OgLVfin
3. At>;>ii>t in evaluation and iqpgiadlng
(aullt
4 I'iciuiu biuuiidl atdtiis iqxat ai
208 plan
5. Uiiui ijiulity monitoring
6. Cmkliict b|juJiaI water quality
bt iiJic^
inffi.
1 Piijbist in btrciin classification
2 Ai>-.ibt in developing u.iier (jiulity
ciileilu u/ilI iuniltorimj piOjiuiQ
3. in uvjUi.itiui oj«I
(dulll Lcuiit)
4 K±ul*L in utucatlOd Oiti tiaitung
ptojt kflll
ioi,.
1. In^lemjnt applicable portions
ot ilri pldi) on uml
pi IV IdlKiii
2. Absisl in ci-velcpiny water quality
cirituUd uikl in^nitoriiig program
3. LVdlmlc din) U|nji4ido plan {internal
tiikl With difclit tctfti)
4. Col louL land bybtiiuy infomutiui,
cluijslfy bLieumu
5. ConJikut udii^tion and training
6. St limit meiuual status report
to JbUtf
IbFS t UIMi
1. Adopt and a|j|>)y IPPA feilcs and
li^julutiom as EMl*i» on ftxleral
foicbL ldlib
2. in developing wat^r qiulity
ci Iter id and aioni taring ptogium
3. /b&lbt iii tvdliuuui and iii*j lading
(inunul aikj with auht lean)
4. Ojjktict and dSdluc ill udujotion ajfl
training piugiuiQ
5. Cuntinuu to oolluct land sysUiiui
inroinut ion
6. WjLci qui 11 tv nrmi taring
7. Sxdiait bicjuilal status report
to HUM
wn v/Are njaurrcv^
) /l...iuL la ov.iluatic*) and
uj»ji kIiii'j (uikiiL U.>«u)
2 RilLlClp.lt£ 111 1141
(ilk) ll Illllivj
3. iy
iun<;
1 CroidinaLe ailmnibtration
of Llw- :>Lri.uH) clmine*!
aluiatlon piisji<»n with
11)1.
mi v. or mAiio/asi
1. Assist in oulii^itlon anrl
training piogua
2. A:.£n~.l in cvuluition and
np>ji.nlinC Criiios
\ ist in education and training pixxjr^fu
2. OmiUiio1 to djjh.t private Luiduwnuij
id • I**— I ir
3 l ,i|vlu aiot ui on
fi jraQ
It-U'a arc |-io-
xnl>'»J in plajui
2.
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BIBLIOGRAPHY
Gonsior, M. J., and R. B. Gardner. 1971. Investigations
of slope failures m the Idaho Batholith. U. S. For.
Serv. Res. Pap. INT-97.
Idaho Dept. of Health and Welfare. 1978. Draft Idaho water
quality status report. Vols. 1,2.
1979. Draft; water quality management plan
for forest practices.
1978. Fourth annual report, 1977-1978.
Idaho. Division of Tourism and Industrial Development. 1977.
Idaho almanac.
Sharp, L. A., and K. D. Sanders. 1978. Rangeland resources
of Idaho. Idaho Rangeland Committee and College of
Forestry, Wildlife and Range Sciences, Univ. of Idaho,
Moscow. Misc. Publ. 6.
1977a. Silvicultural chemicals and protection
of water quality. EPA 910/9-77-03S.
University of Idaho. 1978. Final report, 208 forest practices
project. College of Forestry, Wildl. and Range Sci.,
Moscow.
18
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Chapter 3
ERRATA
The following corrections are made to the Draft EA:
Idaho Forest Practices, Idaho Statewide Water Quality Manage-
ment Plan, July 23, 1979. The Environmental Protection Agency,
Region X, Seattle, Washington.
1. During the binding process, pages were placed out of
sequence. In particular:
Pages 2-5 and 2-6 are located between pages 2-19 and
3-3.
Pages 3-1 and 3-2 fall between pages 2-4 and 2-7.
2. Page VI, paragraph 4, line 11, delete words..., or engineer;...
3. Figure 5-1, page 5-2, change in items under IDL, i.e.,
rewrite item 1 so that it reads:
1. Implement applicable portions of the plan on state
and private lands.
19
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Chapter 4
RESPONSES TO COiMMSNTS
The following pages are devoted to responding to
individual comments received on the Draft EA. Individual
letters including attached materials are included, and the
comments in each letter have been numbered. Responses,
numbered to correspond to the comment, immediately follow
each letter.
21
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United State* Department of the Interior
Fadtfrjl lullJlci|, Bdi 0(2
3J0 U Fore Scr««c
fioI•t, Idibo 6)724
k«pt«ab«r 20. I*i1
hO
ttr Cr«lg r«xcrlJ|«
H/S ttl
Covitooa«oc«l Cviluadoa Bfjocb
CnvlcooMnctl fioticdon Af«ucy
1200 SUih Av«au*
S««ul«, U«»hlii|ioo 96(01
Du«r Hx Pircrldt*.
RECEIVED
tip 2 4 19<
rpA r "
U« hi«« ravliwid (hi EavlconaaocAl inr ch« Idaho
foriit rriciicia, IfA ilO/9-79-06O, iad Ii4v« found no objidlaai
Ut irt currently uorMo® ulcb ch« Sc«i* D*|)«ro«nc o( U««lih
«nJ U«l(«r« Cue (h« purpua* of I Ay1«**nt 1 n® ib« Forest fracclcaa
propo««l it It «ppll«« to Lb« public landi lo td^ho U« billivi
ih« proposal will o(f«r May iaprov«o«ni* lo ch« uo«iiaaai of
Idaho's tl*b«r touurc* icid look forwed IO cb« full lupl«u«nl*( loo
of lh« plia
I)i«nk yo*» fdi th« oppoctmitcy Co p«r(lclp<(« lo Ch« piipmtioa
ind i«wt«u at (hi plin If w« cu bi of furctitr mlitinci, plin*
Jo 41431 tlOllJt* CO 4kk
Sincerity yuur«.
/Th«uJori C IlnfliM
ACCIng Si*(« Olcactos
1
lamLAhIa 9
jjii fi/»|) iinii You Sifv* 4/nt/tCj'
U S OoojrfPcnt of Interior, Duteju of Land Hanaoca«nt,
Idino Sticd'ofCicq* ThaQdora G Bingham, Acting' Stato
Oiractor" t^otejfatr To,
No response !• r«quirod
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/2\ Unntd Sliiti
' Department at
AjiKuliuie
Soil
Con>»r\ jtion
Service
Rooa JO
North 8th Sir«et
ftolfl*. IJano d3702
Stpicobti 19, 1979
NJ
U>
/.
2.
RECEIVED
Craig Partridge *1/S *43 _ iQlO
Cnvtonoincjl Evaluation Branch £ £? b 3 Is'J
Environoental Procectloo Agtncy, Region 10
1200 Slath Avanut r* "¦
Seattle, Washtngcoo 93101
0«j( Mr Partridge
U« have the following eo«Mncs on tha Environmental Assessxent, Idaho
Forest Practices, Idaho Statewide ^«r Quelle/ Hanagesent ?lao
1 Page VI, fourth paragraph, fourth tent«nc«, " hiring a
•oil scientist or engineer " Ic should b« specific as to uhi^h
pOlttiOQ Is needed
2 Page 2-2, fifth paragrapn. first sentence - Heeds clarirlcstlon
change to read, " the SCS, SCO's and IDL provide technical
assistance Lo identifying »oil profiles, inpleeentlag toil
conservation practice* and
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i
MQRTH i&AIIQ FORESTRY rec0VEO
—A33QClATtQN, IKQ.— 0CI10.979
coiua d mams, iuaju) uii«
aC at* ummi
c/o P 0. 30tt 1016 Lowtaton, CO 0JSO1
a.on
October S, 1979
Ctstg Partridge ti/S 441
Environmental Evaluation Branch
Environmental Protection Agency, Region X
1200 Sixth Avenue
$««ccU. WA
98101
Oear nr. Parcrldqei
w« horowitli submit [Attichnant l> our Anociition'i etatemant on the
July 1979 tAviroiw«nt»l ^sttttsMnt, Id*ho (oc*it Vrictlcaa, Idaho 9ui«*
wide Weter Quallcy Management Plan.
W« compliment EPA Elaqion X on publlahing an Environmental Aas«esm«nt
report which provides a generally excellent technical appendix to the
Idaho Forest Practices Mater Quality .lanagement Plan. Uowdvar, w« feel
the CAR la deficient in addressing the total aocio~econoalc lapects of
administering all watar quality-related beat management practlceei our
ecstaoent concentrates on critiquing this deficiency.
In addition, w« f«al the distribution list should have included private
forest landowner organisations. This oversight caused unnecessary delay
In providing opportunity (or comment at the public meetings scheduled lo
August and In submitting written stacanants by the original request dace
of September 24. We appreciate the ascension of the coonent tima to
October 9 as iurtlcated in Mr. Oubola' September 21 oeao.
We specifically request that our Aaaoclation be placed on the nailing lie
for future pertinent CPA Region X reports Please nail cot
Louie* Shedduck, Executive Olrectoc
NORTH IDAHO F0R£STJ»* ASSOCIATION
P O. fto* 65>
Coaur d'Alane, 10 91414
Attachment 2 ts our Aseoclation'* August 19 statament on ehw Draft Stace
oi l3aho 200 Hater Quality Management Plan. This will giv« you sojoe back
ground on the UIFA, an indication of our support for essential and work-
able watar quality management programs and our endorsement (with a few
Crel
-------
marts mm fobsstoy
—AS3ae8ATIO% me,—
ri) 101 in • coiur tfAiue. iaaho imi«
T«iMfc— AC IIM47-U4I
October S# 1979
Statement on
environmental Assessment
Idaho Forest Practice#
Idaho Statewide water Quality Management Plan
Published July, 1979
by the
U.S. environmental protection Agency, Region X
The North Idaho Forestry Association (hereinafter termed NIFA) com-
pliments EPA on publishing an Environmental Assessment report (EAR I which
provides a generally excellent appendix to the Idaho Forest Practices
Water Quality Management Plan (IP? Plan). The two documents in turn pro-
vide more than adequate support for the Forest Practices element of the
State of Idaho 200 Water Quality Management Plan (Z 208 Plan). Also#
the CAR and the IPP Plan combined serve as a source of touch useful infor-
mation which is of great valua to not only NXFA's members but to everyone
having 20B responsibilities.
Overall# th« EAR is, with a few exceptions# a comprehensive, rational
treatment of the environmental impacts of administering the IPP Plan. Our
principle criticism is that the EAR does not adequately address the socio**
|economic aspects of implementing water quality protective practicee.
The EAR appears to be based mainly on the Pinal Report# 200 Forest
Practices Project, published October 12# 1918 by the Forest, Wildlife and
Range Experiment Station# University of Idaho. While this University
NIFA Statement
10/5/79
Page 2
report is generally a comprehensive and acceptable document# It la weak
oo economics. Mora specifically, it falls to adequately analyze the
* toCal costs to forest landowners and operators, as well as Idaho's tax-
payers# of implementing best management practices for all usee affecting
water quality. Thie deficiency is carried over into the EAA.
One example is the etstement in the last paragraph, page vl of the
EAR, i.e., *Implementation of BHP's by the logging industry will require
greater capital outlay. It hae been estimated, however, that these addi-
tional costs will be relatively Inaiqnlfleant.* (Emphasis added). The
emphasised statement is not factual# because the approach used by the
Technical Review Team (tRT) which prepared the report failed to Include
•11 coate involved—not Just those which would result from the TRT's
1 recoomended revisions to the Idaho Forest Practices Act (IPPA) Rules end
Regulations. A cass in point is the exclusion of the aubetantial cost
of the essential practice of terminating logging during wet weather to
minimize soil disturbance and stream eiltatlon. These costs Include the
maintenance of more equipment end larger labor forcee than would otherwise
be necessary and the down time costs of depreciation on idle equipment#
lost wages to production vockari and unemployment compensation by the
joperator.
We also feel that the TRT's approach did not adequately reflect the
costs of road deelgn, surveying and construction in conformance to stan-
darda designed to protect water quality. We recognize that the TRT un-
fortunately did not have sufficient time for an lndepth study, but this
does not mitigate the inadequacy of the coet analysis.
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•ilfA Sttuaonc
10/5/79
Pa••< o( accomodating public recreation. Two coati
•ca involved* iJLttrt fire protection and tuppreiaion required by the
increased risk fro® public accessi and 2)Kxtc* road auintsnance to pre-
vent d«a«4« And eoil ereaion, aip«ci*lly troti four-wheeled traffic during
wet weather on the thousands pLeoentatlon. If you have any questions
or dssire additional information* we will be pleased to rospond.
Thank you (or ths opportunity to coment.
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4
_ Atcachatnt 2
MOaiTM H5ASS«3> FORESTRY?
-ASSCStATIGS), OHO —
TdiplMM AC IM-Mf-IIU
^•3? HMBWIWIIWM,
P a AOX t» •«• COtUR VALlMt. IftAHO «U1«
Sortb Idaho Toraacry Association
3t«Cca«nt oo
Orafc State of Idaho 20d
Wacar Quality naoaganant ?L±n
CO
Idaho Daparcisaac of UeAlcb And Uallars
Division of Gnvlcoaaanc
ac
Coaur d'Aleaa. Idaho
Auguac 29, 1979
1 aa Hlk« Walling, an of f Icar of cha (torch Idaho Foraacry Aaaoei-
atloa. Wo art pita*ad to hava iMi opportuolcy to praaaoc a imhwc
for the racord oa cha Orafc Idaho Uacar QufUcjr Maoagaaaoc flan dAtad
July, 1979. Although we Umoc tha ahorc pa clod of claa aXlovad Co acudy
And prapara our coanenta oa cha 203 page 4ocuatac, wa do appraclata the
UtfOJ' a acbadullag aq sacra —ting la raapooaa to our aad ochar'a
ra^uuc. Ua hop* you vlU p«ac ua mc« Um co aubelt a final viictu
atacaaaac.
Racktrouod on HIFA
The North Idaho Foraacry AjaocJacloo ia om of tba oldasc forasc
casourca coaaarvscioa organization* lo cba Uolcad Scacaa. having baaa
foraad la 1908. Our aaabarablp la coopoaed of 00 forasc Landowners and
oparacora or chair rapraaaacaclvas
Tha purpose of ch« Association, aa aec forth In lea original Conati-
cutloo, Lai "The coosecvaclon of the foraac raaourcas of oorchara IdAho
gaoaraLly and parclculadr (Aftd) the promotion of practical forestry
Since tha fouodlog of cba AaaociatloQ. Ica atsbare Uva aadaavorad
0XTA iuttcant - Orafc IdAho 20ft W.Q.M.f.
Auguat 29, 1979
Jags 2
to hold trua co chia ori|lul purpose by auppoiclni and working for
aoimi foraauy legislation And raiurcii, development aod application of
affacUta, practiceL auiclpl* foraac raaourea aamiaMnr.
3oae of cba forestry-oriented leglslat-lva acca wa have aupportad
arai lha Idaho forestry iet of 1925 (tha flrat auca forestry Lav), cha
IdAho UfaiMucian Law enacted la 1929} cba Cooperetlve Suataloed Tlald
UlscxAct Ace of 19)7* cha Idaho Streea Channel Aitsratlon Acc of 1973;
and cha ¦oat vacaoc law, cha IdAho Pareee Practices Ace of 1974
Our tuccuoc chia evealag vlU necessarily ba laaa decAllad Uua
va would Uka. Ua aajr aubalc core decailad coamca la vrlclag it Cha
teparcaaac of ttaalcb And Welfare franca auffIcianc claa.
Coeoanca oa cha
-------
Ml Fa Si<(M«nc - Draft Idaho 204 W.Q h.P.
Au^utt 29, 1979
P«l« 1
C*jBM«nc» on Form Practlcaa tlwo(
Ua (iu«»U]f approva tba farMt riicclcu U««ai, but u»
It oaada 1«f*——r* U* luiu*( b«d tuidUuC om to tn»yi« ouZ
coocarna aod rarna^anrtarlnna fully, but brlafly. tb«7 u«i
1 - Tl« uuCMQt |lv«Q to Um co«(a ol applylog Wat
pruiuti (Uff'i) to protest ut«r ^uiitji la ludt^uu. Ua hna *'—rr^
aothlug oo chla aubjact la tb* tut of Uu Foiut riicticu
-------
HIT A St«cu«o( - Dr»ft Idaho 200 V.Q.H.P.
lusuac 19. 1979
rit« i
Tor tbac ruaOD, wa ara daaply lacaraatad la having lha prlvata (otuc
laaduwoara of north proparly rapraaantad. Ua doc* due tua
Mabarahlp La co la&litda a rapraaaatatlva of tha "prlvaca iicui1*, whlclk
la cooaandabla If It aaana a raprcaaatatlva of prlvata foraac landowner#
aod oparatora.
Ua racnoaand chac tha Worth Idaho Foraacry Aaaodaclon b* ooa of
tha arga-n-lxaclooa iuchorizi4 to racoraaad a a«ab«r for appalaoaaoc to
tha caaa. U« hava aavaral paopla la Bind wbo wa faal ua fully quallflad
co fLll tba poaldon.
} * EFJL'a rola la providing "axp«rdaa la avalu*clng aifactlvaaaaa
of BKf'i aad davaloplng watar quality ulc*rU for foraac praedcaa".
hJ Culdanca and aaalatanea froa ISA ut b« approprlata, buc wa faal
VO
Idiho1 a acaca agandaa ai^ foraac laodowoasa ahould provlda tha oo-cba-
grouiul axpacxlaa on acaca aod pnvaca land* aad cba USTS aod BLH oo
fadaral linJa. Through cooperation eaoa£ 44 coda a aod private land-
OHMtat adequate expardae could ba provided.
4 - Uacar qvhallcy aoalcorlag
U« cacogaLaa tha need (or a method co determine the affactlva&eaa
of BMP'a, but CD a text of the flan la uadaar aa co what kind aad bow
ucb ¦oaltoclag will ba expected of Cha landowser/oparecor If lc
locludaa actually collectlog water aaoplea 00 all oajor screaaa at
fraquaac Intervale, lc could prova co ba prohibitively axpeoalve 00
aactar wtM doaa Lc. Ua realise the ooaltorlng prograa will hava co ba
developed before lc can ba lopleaaatad. Ua reapectfully raquatc that
ouc Aaaoclatloa ba included la cba dcvalopaant procaaa.
3 - La ad Sjretam* Inforaedon
Tba Plan, aa wa raad lc, propoee* aucb a ayatea for all foreatlanda
la cha acaca — federal, icaCa and prlvata. k laod claaalflcacloo
NllA ScateaeaC - Drafc Idaho 208 U.Q.tl.P.
Auguac 29, 1979
Page 6
•faces doea have value, li proparly dona aod applied. but tc ba aade
overly caaplax. Soaa of our mb«n are already developing or ceo*
aldarlfl| refined 1and claaalf IcadQQ ayateaa fox chair ptoyattlta. ftuC
co au|«aac ctiac a daullad laod claaelf lcatlon Inventory aod application
ba uodartafcaa Cos ail Coremtlacda La tba tuta tuaa preaature to ua,
for aavaral cuiou which wa won't take tlae now to axpLMa. Tba cwo
ailfl cooearua ua coat aad how lc would ba appllad Co protacc wacar
quallcy.
Ho aaclaaca of coac la t<-v*a la cba Plan. Ua racoaoaod cbac tba
Plaa locluda a aora coaprabaoalva daacrlpclon of tba problaaa lavolvad,
aa aadaaca of tb* eocal coat aad bow lc would ba fuadad.
6 - Propoaad aMadsaaca to cba Bulaa aod Bagulatlaoa Of cbo
foraac Pra^clraa Acc coaulaad la tba foraac PrMClcta Uacar Qu*Ucy
ttaaageeaac fLaa.
Uchough cba propoaod aaaa4anu a till coacalo a f«w alaor f lava,
wa aadora* thaa aa wrlccaa aad ncowaBd TH*
-------
ttl/A SC4C«*4£C - Dealt l«l*ho 200 W.Q rt.f.
Au(U»c 29. 1979
r*|a 1
cumiua.
| Ilia dtficliod** la tb« pcopo««d MujMau *r« r*ltUv«if aiaor la
our oplaioa tod do ooc M|it« owe of UcUob D of Qup(tr IV
of cli« IJiho Fococc Prtcacn Vac«r Quollcy tUaifiMac flio If ptobl«M
itii* la Um lapi«a«ot4Cloa of S«ctldaa filJ.Ob(l) ia< lit.03(11) «fi«r 4
I y**r or (M of crlal, tbijr c«a U« carrwt«4<
Cjro«uc» on tnvl roannci L Atmitnt td«Ko fo<«n ?cictU«i. l>l«tw
Sc4tetfiJ< Wic«f Quality Plan. July. 1979
Ouc ciuiuti b«v« ooc tud clu co tniM (bu t»poi(. la (ut,
mm ot U>m tad war of auc whin b«v« not y«c ob(«iaod coplti.
CauM^tModjr, «m uic d«l«r mk csawii until u« b««« boJ um co ocudy
LJ
O th« ctptitc. U« bop* Co bo obi* Co pt«p*r« *a4 Mil our cocmaci c« E?A
by tb«lr r«qu«oCod d«t« of Sopcoaboc 24. If u« 4o, w« will «*ad • copy
M you.
U« uodaritMd cbo U report km pr*p«r«<4 uadoc coatrtcc Co DA. U*
NcunAiid cb«c cb« cmkwc eooc of ptiptfiui • liacuatoi bo glvaa la tb«
locroduccloa or ea 4 apodtl i«ixwulad|Moc PM*
Tbaafc you for b««ria| our iut«a«ac
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Northern Idaho Foreatrv Association. Inc . Lawiaton. Idaho.
Jamas L Johnson," President (October 5, 1»79)
Letter grow Jamaa L Johnson to Craig Partndqa (October $. 1979)
1. Information noted and responses to comments made Ln
reference to attachment I.
2 The Northern Idaho Forestry Aaaoclation will ba added
to tha distribution liat tor the final EA.
3 Information noted and responses to comments made in
reference to Attachment 2
Attachment I to letter from Jamas L Johnson to Craig Partridge
IQctob.r 5. 19791
1. Ho response required.
2. This information la nocad, refer to comment/response
number 3.
3 The statement. "It has been estimated, however, that
these additional costs will be relatively insignificant",
is intended to apply to the change in the rul«s on an
industrywide scale. It is not intended to say that
the cost of compliance in total with IPPA rules is
insignlfleant for operators Certainly, the data available
to aeasure the Impact are scant, but the data in Tables 6-2
and 6-3 and the text in psges 6-4 through 6-7 indicate that
tha average effect on the Industry will be insignificant
as indicated in the NIPA comment, effects on individual
operators under particular operating conditions nay
in fact be significant. Oetailed case studies to eaeimate
dollar amounts for particular situations have not been done
The University of Idaho attempted to gain a store individualistic
type economic analyais using questionnaires (see Oraft EA,
appendix A), but the response from the industry, 1 e ,
operators, was minimal Out of ISO questionnaires.
14 operators responded and 12 of these responses provided
useable information The information obtained was
Inadequate to project the economic effects of IPPA rules
on individual operators
4 Same response as comment 3
5 The added coats to operators and land owners resulting
from the recreational use of private forest lands was
not estimated It is recognized that recreational use
may add costs and water quality effects such as those
identified in the comment. The £PA does not beLieve
these oversights to be significant relative to approval
of the Idaho 208 Water Quality Management Plan
6
Comments are noted and no response is required
7 Ho response required.
6 This is a matter to be worked out between the NIFA
and the State of Idaho
9 Ho response required
Attachment 2
1. The comments were made by the NIPA on the Draft State
of Idaho 208 water Quality Hanaqement 91an» as such,
they are pertinent to the evaluation of the Oraft CA
of the plan and are Included here as such Since they
are not comments on the Oraft EA no response is required.
-------
Potlc^ch
Saptoobar 26. 1979 PtdMt*
M»M Pi«A«u W»»i«n Oiiiiiii
*l> tm 101*
ImlM M«ft* «JU)I
Craig Portridg. M/8 4<] W« ,H>» U» JUJ
Environmental evaluation Branch H^CEIVED
Environmental Protection Agency, Region 10
1200 Sixth Avenue 2j 1970
Seattle, Hiihlagcon 96101
D««( Mr. ^trtrldq*!
Attached is our Hestern Olvlslon's ic*taiunt on the Environmental
Assessment, Idaho forest Practices, Idaho Statewide Watar Quality
Management Plan* published by EPA Region 10 in July 1979.
Briefly, w&th a («w exc«ptlona as noted la our etacements, we an-
dorae the Bnvirono>entel fcaseaenent «a a comprehensive, readable
report. Overall, It la a rational treatment of the aeny coop lax
considerations involved w It-h lnpUMOtlnq forestry beat management
practices deelgned Co carry out the intent of Saction 206 of the
federal Hater Pollution Control Act and ita ammendasnta the EAR
together with the State of Idaho Potest Practices Water Quality
Management Plan dated July 1979 should adequately document the
validity of the forest practices element of the Stats of Idaho 208
Water Quality Management Plan. He have already recommended thet
Che comprehensive Idaho 200 Plan be Certified by the Governor and
forwarded to CPA for review. Enclosed for your ceference la a
copy of our atateaont to ths Idaho Oapartmant of Health and Welfare.
Our principle concern about EPA Heglon 10'* Eovlronaentel Aaeeesoent
is that it does not adequately addreae the total coats of imple-
menting all watar quality ralated tllvicultural BMP's. We have
offeced some euggeetions tor future conaidaration.
Nevertheleea, we believe the EAA confined with the Idaho Poreic
Practices WQMP provide a wealth of information which will be highly
ueeful to all those involved with continued planning and imple-
mentation of Idaho's 208 program
We apologise tor being two daya late in aubtsitting our consents.
We hope our support and critique will still be helpful and con-
structive. We appreciate the opportunity to consent.
environmental forestry
£UjC/1)C
cct Terry Reyes, LDHW
StAtaaont to
U.S. Environmental Protection Agency
Region X
by
Potlatch Corporation
Western Division* Hood Products Group
Lawletoo, Idaho
8«pcetaber 24, 1979
on
Environmental Aaeeesoent
Idaho Forest Practice*
Idaho Statewide Water Quality hannqement Plan
Publlahed July, 1979
-------
Rotlatch Corp. Statement
9/24/79
Pago 1
Wo compliment EPA on publishing a profeeelonally praparid and
informative Cnvironmentel Aihibbmc report. Overall, the EAR provldea
a valuable supplement to the Idaho Foratt Practices Water Quality
Management Plan (P.p. Plan) and the Poreat Practices element of the State
of Idaho 208 Water Quality Management Plan (I 208 Plant. Although the
BAR la basically a condensation of the February, 1979 draft of the
P.P. Plan, it doee contain several additions and expansions which en-*
hance the background Cor the forest practices 208 program.
However, the SAA le deficient in a few areas* particularly economic.
The reason for these deficiencies apparently is that the CAR extends
some of the misleading conclusions contained in the reports of the
University of Idaho Technical Review Team (TRT) which provided the baale
for the r.P. Plan.
We have commented on these deficiencies in considerable detail
in our August 27, 1979 etateaent to che Idaho Department of Health and
welfare (XDUW) on the Draft 1 206 Plan, a copy of which la attached.
We offer the following critique specific to the EAR. Our coosaente
are briefed where they have elready been covered in our 8/29 statement
to I0HW. Por more detail, you may refer to the 8/29 statement where
noted by Item and page numbers.
SUMMARY
The two page summary condanaee a highly complex subject into con-
cise, •asily understood language. However, as with most lumaariee, it
ie not sufficiently comprehensive, which could leed to misunderstanding
by hurried or casual reeders.
Fotlatch Corp. Statement
9/24/79
Page 2
We heve criticiame on two ltema briefed in the Summary. The
Clret pertains to the text on the top helf of page vi re. the 'bene-
ficial* impacts of implementing the Idaho's forest Practices Water
Quality Management Plan. There is no doubt that the BMP's should have
a beneficial impact on water quality and downstream usee. But some of
the "additional" benefits listed are debatable, particularly number 4
"improved forest productivity". In evaluating this claim* ono suit
distinguish between "per timber acre* and "per forest" productivity.
Reduction of erosion and maee eoil movement on timber growing acres will
tend to lncreese productivity on those acres. But the amount of timber growing
eorea may dscrsase, as la separately recognised in the report in para-
graph 3, page 6*1 and paragraph 2, page tf-J. To explain further.
Stream Protection lones detract from the timber growing acres, as do
any additional roada, etc,, associated with going around streams and
high erosion potential areae. Thle decrease In timber growing land
baae ceducea the productivity of the total forest. X mote definitive
enelysis of the trade-offs should have been made in the report and
mentioned Id the Summary.
Second* under "Negative Impacts" on page vl, last paragraph, the
atatement "It has been estimated, however, that these additional (logging)
costs will be relatively ineigniflcant" la mleleading. The statement
is a direct quote from a TRT report end also appaers in the forest
Practices element of the Oreft I 208 Plan on page J-15. The statement
may be true with reapect to the additional costs of implementing the
TftT's recommended revisions of the Idaho Porest Practices Act (FPA)
Rules and Regulations, but It la false when the total costa of imple-
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Potlatch Corp. Statement
9/24/79
Pago 1
aienting *11 vACtf quality raUtsd r«9ul«cioaa of ch« PPA and ot-har
Idaho laws era conaldered.
I Another coat taccor overlooked by tha EAB la tha extra expensa
Incurred by the landowner lo Qeintaiolng foreat roada Cor public recreetian
eccoaa. This was a lao omitted In the I 200 Plan, aa overalght which wa recoa-
unJod ba corrected.
The above diacuselon point* out ooa rscurrlng deficiency in the
lak (and the documents on which it la baaed), i.e., tha (allure to
equate the envlronnentel impacts of forest practices to their not
uffacts on people—not }uat on wet.ee quality, vegetation, tolls, wiId-
life, ate. The presumption may be made, of courae, that if the
rooourcea are all beneficially Impacted, then tha end reault will
S benefit people, but thia la not always automatically true In a coat-
benefit conctxt. Son* recognition of this concern la given In the
laat paragraph of the Suasury under "negative lapacts", and again in
paragraph 1, page t-l under 'lapaati on Water Quality". But we feel
that more enyhaile ahould have been given to the overall socio-economic
lmpecta of implementing BMP'a.
In summary, we believe the LAB and the T8T reports on whioh it la
baaed are woefully weak in addreaaing the sconoaic Impacts of lapleaen-
v cinq water quality related BMP* •. rot mora detail, see Items J.23 and
) 24 on pagee 7 and 9 and Item 5 on page 1$ of our 0/27/79 •(¦tenant
to 10HW.
1
INTRODUCTION
Thia aactlon also la concisely written. However, again we havs
two concarna. Plrat la the definition of "nonpoint aourca* at tho
Potlatch Corp. Statement
9/24/79
Page 4
bottoa of pegs vii, which we believe to bo inadequate. It la almost
Identical to tho definition given on page 41 of tho P.P. Plan. We
rscounended a aors comprahenslvs definition to 10UW— see item 4.24.
page 12 of our 1/27 statement.
Second, the Use oo page Is of organltatlons to which EPK dlstrl-
butad tha CAB doas not loclude any forest land ownar groupa. This
apparently was an overaight, but It cauaed unwarranted delay in receipt
of tha report by landowners, which has mads it difficult to study and
consent on such s complex document by September 24. As a result, land-
owner response aay ba aevaraly Halted unlaea you extend tha commont
period.
Tha North Idaho forestry Assn., tha Southern Idaho forestry Aeon,
and the Idaho woodland Council ahould havs bean on tha distribution
Hat. Pleaaa note thla for future dlatrlbution of pertinent CPA report!.
CHAPTERS
Chapter 1, "THE rORCST USOUBCS INDUSTRY IN IDAHO". This chapter
is en excellent review of the history, ownership, management and timber
production potential. It la particularly valuable In pointing out the
importance of tha foraat induatry to Idaho and tha nation.
Chapter 2, 'HOHPOltIT SOURCE POLLUTION PROM POBEST PRACTICES"
This chapter Is s rational discussion of nonpoint source pollution from
forest operatione and should prove highly ueeful to avoryona involved.
Of particular value are the tabla of *Strean Segments with Significant
Hoopoiot Source Pollutant Problems Related to forest Practices" and
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Potlatch Corp. Statement
3/24/79
Pago 5
tha maps of the major nvir basins showing the trend analysis stations
and straaa segments.
Chapter 3. "RESOURCE CONSERVATION IN IDAHO". This is an excellent
rovl«w of existing federal, scata and private foraat raaoorca conser-
vation prograna In Idaho. The recognition that Idaho'a Forest Practlcea
Act Rules and Regulations, with minor changee, should conetitute BMP'a
under 208, is particularly appropriate (p. 3*6) . Also we appreciate
your recognition of the Tree Para Program and Potlatch's Woodland
Development Program (p. 3-3).
Chapter 4. 'HONPOINT SOURCE PLANNING IN IDAHO". This chapter
adequately reviews the TRT's findings end recommendations. The concept
of BMP * s on pages 4-1 and 4-2 Is particularly good. The TRT's recom-
mendations for revision of the IFPA Rule* and Regulations and admini-
stration and enforcement (pages 4-3 to 4-9) are generally acceptable
and should prove more than adequate for implementing Idaho's 208 forest
practices BMP'a.
He do have a few minor concerns which ere diecusaed in itema
4.26 and 4.27 on pages 13 end 14 of our attached 8/27 statement.
However, we endorsed the P.P. Plan and recommended its adoption by
appropriate Idaho State agencies (see item 4, page 10 of our 8/27
statement).
The TRT's recommendations for an education and training
program (page 4-9 to 4-11) are good as far as thay go* but we recommended
that forest landowners and operators or their associations be utilized
in the development of the program. (Sea item 4.28, page 14 of our 8/27
statement.)
Potlatch Corp* statement
9/24/79
Page 6
Chapter 3. "PROPOSED IMPLEMENTATION AND OPERATION OP TUB POREST
PRACTICES HATER QUALITY MANAGEMENT PLAN*. The description of imple-
menting egenoiee* reeponsibilitiea and procedures la generally accept-
able! but we have two concerne. First, in figure 5-1 on page 3-2 under
¦ICL" (Idaho Department of Lands) responsibilities* a new item 1
should be added stating 'Implement applicable portions off the plan on
atate and private lands.* This responsibility is Indicated in para-
graph three, page 3-1. but it should be specifically included in the
chart so there will be no misunderstanding. For more detail on our
positive comments on administration, see item 3.12, 3.13 and 3.14 on
page 6< and items 4.12, 4.14 and 4.17 on pagee 10 and 11 of our 8/27
statement.
Our eecond concern pertains to gvaluetion Methodology on pages
3-4 and 3-3. The dlecuasion of the problems associated with developing
e method for evaluating the impact of SMP's on water quality is generally
well stated. However, we are concerned about the TRT proposal number
4, "Consider tHe need for water quality criteria for nonpolnt sources
and a sediment standard." He have given this detailed discussion in
our 9/27/79 statement to the I0HW so we will not repeat here. Instead,
we refer you to item 4.29 on pages 14-16 of our attachment.
Chapter 6, "IMPACTS OF IMPLEMENTING AND OPERATION OP THE PROPOSED
208 PLAN—FOREST PRACTICES". The text La appropriate froca the stand-
point of indicating positive Impacts on water quality through proper
implementation of the IFPA Rules and Regulations. However, the concerns
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Potlatch Corp. 8t«UMnt
9/24/79
Paga 7
|wo aip(«aied In coonflats about ti)« Suad«ry U«aa apply hart coo.
We «|
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Potlatch Corp Statement
9/24/79
Page 9
This ia a good example of trying to complete e complex assignment
In too little tine, aa emphasised io the Comptroller General's report
cited in item 2.6 on pa?* 5 o£ our 9/27/79 statement to IOHW. He hope
a more definitive, indepth study of the total coats of implementing
all water quality related BMP'a can be undertaken In the near future;
it would be a good project for the U of Uaho College of Forestry or
a qualified consultant.
Chapter 7, "BIBLIOGRAPHY". The list of literature ciced includes
some SO reports which Are in eddition to those listed in the PP Plan.
Together these lists comprise an excellent source document refereoce.
We eapecially commend the authors of the EAR for their extensive
use of references end proper citation throughout the text of the report
Appendix Including the TRT's economic analyses reports in the
EAR rather than in the PP Plan was a logical procedure.
SUMMARY /WD CONCLUSION
We coosoend EPA for preparing an Environmental Assessment which,
with exceptions as previously noted, provides a compreheneive and
readable analysis of the environmental considerations involved in
implementing water quality related forest practices. The EAR and the
PP Plan combined will aerve as a valuable and useful compendium for
all people who have 208 forest practices raeponsibllltiss and intereeta
Our major concern about the EAR and the 206 plan It addresses
centers on the net social-economic impact on people. The cost, both
governmental and private, of carrying forward the 209 program is a
paramount problaa, particularly in states such ae Idaho where the
voters heve mandated a It property tax limitation. The importance of
Potlatch Corp. Statement
9/24/79
Pago 10
allocating available funds to the most coat effective programs was
emphasised at SFA's Region 10 Water Management (208) Conference in
Seattle, September 19-21. Several EPA officials stressed that 208
money probably would become increasingly difficult to obtain and that
the federal* state and local agencies involved would need to coordinat
their efforts to prioritize projects and concentrate first on those
which would produce the greateet water quality benefits for the dollar
spent. We coaaend and support this concept.
Thank you for the opportunity to comment.
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Attachment
Potl^jtch
Saptuabet 10. U79
Nlllltl CX|K|DM
Mm4 Ei>eiiu Wiiim Qaaaiaa
'0 J*. IQI«
WMlfOtl Ml I'll
Tarry K*yaa
Oiviaion of environment
Stitdhou««
Boiae, ID
81720
Daar Mr. Keyeet
la chocking over our Au?uat 2? Bevlaed Stateoant oo the Oreft
State of Idaho 206 Witee Quality Hanagaaeat Plan t note • Com
errore—noetly la the croaa referonwee to it am* and p*«« nuatoera.
R*th«c than put you to the trouble of hand correcting the copy
to attached to nr. Horrie' cover lattar of Auguat 20, I am sanding
00 you another copy with all correationa aada.
t reapeotfully requeat that you diacard uia August 27 revision
and roplici it with thia fiaptaab«r 10 correction.
Thank you for eatanding the eonaent p«rlod.
Sincerely youra.
Royce u. Cox« Manager
Lnvlronmental Foreatry
KGCiat
Att.
J. a. Morria
bcci T. Haddock
J. McAdoo
0. HcGraar
j onciAur
U
With copy of corrected atateaent.
Potl^tch
itwiHvn
Mtaftl
Ma iMUtfl
Au^uat 26, 197%
Tarry Keyea
Division of Environaent
Stetehouee
5oiae, ID 91720
Dear Mr. leyeei
Ma Urtvith lubait our Weatera Olvisloa'a atataaant (attached)
on the Oraft Stat* of Idaho 206 Hater Ouality Hanegoaent Plan
da tad July* 1979* This written atataaant la a auppleaent to
the oral itattMnt presented for our division by Oala McOreer
aft the public aeetifig in Uwlitoa on August IS.
kfi«Uy# we aodoree the Draft flan, with iom reaervetiona which
ara datailad la our written statement. If our concarna and
recosaandetione ara adequately addressed la tha final plan, we
raooenend ite certifIcatioa by tha Govarnor for subaiaslon to
tha O.S. environmental froteotion Aqaocy ta an adequate document
to lflplaa«a( Idaho'a reepenaibilltles under tha iotant of
fiootlon 206 of tha Pederel Meter Pollution Control Act and ita
aaendaenta.
Mo alao racooMnd tha adoption by appropriate State agenciee of
tha propoaad aaefldnents to tha fculee and ftaaulatioaa of tha
Idaho foraat Practices Act contained lo tha State of Idaho roraat
Practlcee Water Quality Hanagaaent Hab of July, 1919.
We coaaend tha Idaho Oapartaant of Health and Welfare for pros-
pering a generelly acceptable document which will be of utaoet
importance to the oltiiena of Idaho* We will appreciate youc
Giving careful conalderetlon to the concerna and recoosaendacione
Io our detailed atataaant.
for your convenience, we have prepared a auxamaey which precedes
our detailed atateaent. If you have any questions or deaire
additional input, we will be pleaaed to ceepood.
Thank *ou for tha opportunity to present our atateaent Cos the
record.
Baapectfully,
-------
Stacoaent co
Idaho Department of Health and Waiters
Division of Environment
on
Dris overall Oraft Plan, except for our recoenended revisions# as
an adaquat* document for the Governor to certify and the U.S. Environmental
Protectioo Agency to approve. (See Item 2.1-2.4 in our detailed atatoment.)
5. Ma have two general concarns about the Oraft Plan, first is the protocol
of the Ststa'a submission and E?A*s approval of the supplementary documents
accompanying tha Plan ae part of the overall 208 document. We recommend
that the Governor's certifying letter b« composed so as to avoid any
suggestion that EPA nay isiuu legal authority over actual Idaho laws and
their rules and regulations. (Iten 2.3)
6. Our second concern la that the Draft Plan doas Dot adequately addreaa
loglatlc and cost probleme of laplamenting a statewide 208 water quality
manegement plan. We recoanend that this subject be addreesed in tha Plan.
(Item 2. «) *
COMMEtrrS OH ELEMENTS Of THE PIATT PLAM
7. Our consents are mainly on those elements pertainina to the Forest Prac-
ticee element.
forest Practices Element
Supportive Cements
8. We also ganarally endorse the forest Prectices element and recommend its
certification by the Governor, provided our concerns and recomondations
are adsquataly addressed in the finsl draft. (Items 3 and 3.16) We believe
the forest Practices element sdsqustely provides fori Necessary minor
revisions in the Idaho forest Practices Act Rules and Regulations (Item
3.ll)i Designation of State and federal Agancy authority (].12)j Provision
for publia Involvement (3.13)i Positive end aegetive environmental impact,
with a few exceptione (3.IS).
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Sumurv
6/27/7#
Fag* b
Concprna and HacoBMaondatlona
'• Again, wa urgs tha Stats not to ancouraya gPA to jujga or aaauaa any
jurisdiction ovar th« Idaho Poraat Pi«ctic«i Act kuU« to In tiia
Nr«4t Pficticti alaaant (1.21k.
10. wa r«ooawu4 that * psga numbsr rofarsnos to forastry ralaeod anvlroaaantal
inpaces bo cauaad,
a.g., '...aadiaant loaa fro* foraat londa (1st astlaatad at laas than 4%
ot ch« total MA-uda aadioaitc In tha tiation'a watsra* (1.23).
COMMENTS OH TUB SOPPLBHEtfrAftY DOOJMJUIT *ITATt Of IDAHO
q roaxar practices hate* quality management puui
Juppocclva Coawnti
14 Ua sndorsa tha'lfPHQH? for tha Govarnor'a cartlflcation, if raqulrod, aa
an adaquata aupplaAantary docuatnt to tho ovsrsll Idaho 200 Plan, aubjaat
to a nuotMr of raccuMndatlona tor rsvisions (Itsa I, paragraph I).
13 wa atcongly andoraa tho propoaad aaandaanta to tho Idaho Foraat Prautlcss
Act Bale* and tabulations and rscoaaand thair approval Aud adoption by
approprlata Idaho Stats aqanoiaa (Itaa 4., paragraph 2).
16. Our aupportlva coananca of tho IPPWQKP conoludo thata Tha docuacot Is
prolaaalonally praparadj it adaquataly addcaaaas tha "Eapactatlona «nd
Raquiraaanta* llatad bv SPA Jtagion Ij tha eoocapt of aita-apaciflo BMP'a
La a«callant» tha previa ion Id tha propossd aatodMnti to tho IFPA Aula*
and fiagulatlona for a varianca froa a apaclflc ragulatlon whao Justifisd
la workablaj tha rafaraocs in tho propoaad amandnanta co tha Idaho Strsaa
Chajinal Alteration Act and tha Idaho Paaticids Law ara appropriate and
ahould halp oparatora avoid violationsr tha dlagraaa depicting tha aaquence
of procedures relating to enforcement of tha 1PPA ftuLea and Bagulatlone and
procsaalng of violationa «c« excellent and will prove helpful to everyone
Involved (4.11 to 4.17).
Concema and Bacotnaandationa
17. Ma oaKl'attention to our ccraoents relative to EPA approval of tho IFPWQHP
Suaaery
A/27/79
Pago c
18. Ho cacoowad that tho EPA bo Invited to provida "guidance" rathar than
'expertise* lo evaluating effsctlvsnsss of CHP'a and developing water
quality crlurit for foroot practices (4.32)•
1ft. Ua gacocMond Umc a notad reference to Section Hi.12 of tho irPA Aulas
and Regulations ba added to avoid confualon of tha oporatora ovac tha
oonitorlnq of choaical application* 14.231.
20. Ma racoaanorid a bottar daflnitlon of *oonpoint aourca* (4.24).
21. Ho raquoat an opportunity to ravlav and cowant on th# davolopmant of tho
classification ayataa for stxoaa olaaaoa I and 11 undai tho pxopoaad tavl-
alona to Sao. 111.24 ot tho 1FPA fculaa and Rogulatlooa <4.2)1.
22. tho propoaad ct<{ulrauoc in Sac. IIS.06(1) of tha IFPA hilsa and ftaiulatlona
to *Plaeo notarial and othac alaah outaldo tha Claaa I Stroan Protaccion
Sono..." would do aoro harm than
-------
DETAILED STATEMENT
Thla itacuMnt reflect* the concerns and racoanendatlone of Potleteh
Corporation•¦ Wood Products Croup, Micarn Division.
background on Fotiatch Corpocatloo
PoelAteb Corporation is • tros farmer and wood converter, owning
1.3 billion *crea ol tiab*rlaul In bkmiAi, Idaho And Mlonaaou, And
operating wood and paper converting plants In 12 states. Corporate officss are
located La S*n Prencieco, California.
Our "Corporate Objectives* Include achieving a proving profit At a
reasonable rate of return, opticus vanagament of our natural resourcse
and providing quality products and services within competitive 1iniit»—
all within the context of maintaining ethical standards, open forthright
relationships with all publics and a dsep concern for the environment. In
recognition of the eultlple use values of our forest resources* cur fee-
4>
I—» owned forestlands are open for public recreation except when access must
be denied to protect eoployeee, property or the public.
Background on our Weetern Division
The company's Western Division manages more than half a Billion
acres of tlobarland in northern Idaho and oparates production facilities
in eight locations. He directly employ approalmeteLy 4,500 persone with
an annual pAyroll currently Averaging 9117 million. Indirect employment
is provided to logging contractors and auppllsrs of equipment, materials,
goods and services. Approximately 50* of our wood aupply ie producsd from
our fee-owned landa) the balance la purchaeed froo other ecurcas, primarily
state and federal managed lands.
western Division Interest in the rWQHP
Our Western Division has e strong Interest in the proposed Idaho
Mater Quality Management Plan (hereinafter referred to as the *0raft Plan*).
Potlatch Corp. Detailed Statement
8/27/7®
Page 2
Sustained, long-term, adequate suppliea of quality water are eeeentlal
to our wood converting operationa. We are aleo deeply concerned about
the necessity of providing adequate, eafe drinking water supplies foe our
employees and other residents of the coanunltlee in which we operate and
of achieving the national federal Clean Mater Act'e goal of *fishable-
svlanable watara*. Clean weter ie basic to a healthy* vigorous socio-
economic environment, which benefits not only the forest products industry
but all elements ot our society.
We welcome tbe opportunity to present the following consents for the
publie record. We nay suhoit additional written cossaents efter we have
had core tlae to study the Draft Plan.
1 - Schedule of public meat Inge and coanent period
1.1 We ffomend the pzocese of holding meetings to receive cooMntf
from the people of Idaho who will be moat affected by impleoentetion of
the Plan* We appreciate the LDHU'e scheduling ao additional meeting, in
reeponee to our and othere request* in Coeux d'Alene on August 29 ao as
to reduce the trevel distance and time of tboee Panhandle citizens who
may wish to participate.
1.3 We caccMend that the period for receiving written co^nti be
extended to at 1—at September 1Q, 1»7>. The tine allowed aince the
Draft Plan was distributed 1a late July has been too short for people to
review and cooeent on e complex, 203 pege document which has teksn over
three and a half years to develop. An extension of the cotmMnt period
would help sssure ^equate public input. Me feel this is e reasonable
request in view of the numerous past delays by IPX and the State.
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Potlatch Corp. Oatailod Statement
8/27/7*
Paqa 1
I - Conwnti on tht OwftU Pratt Plan
2.1 u* htv« not had tlM fa* liui«pth atudy of tb« «ntir» riui, but
based on our review of elaoents dlecueaad herein, wo contod the Idaho
Dopartoanc of tod H«lfir«a01vlalon of CnvlronMQt Cor ptaparing a
proHaaalonally-vrittao, well-organl aed, coa^falianilM and <)an«ctlly
adequate Jocunant. All the dedicated people who contributed to developing
the Draft Plan daiarvc the thanka of Idaho's oltliaof.
2 2 Tt\« OtftCt Plan does * f«o4 )ob of auaaaciiin^ a tranaodooalY
coAplax und«(taXUi9 Into 20) pages. Um document l« difficult
Coc the waU*la(otMd to digest ud undarataiul, and such aora difficult
for th« Jay parson who baa aot followed the 301 plaonlog process. Hany
paopla aay ba ao ovarvbaload by the ddouaaot Uut tbey will doc raid it
la lufflcitac detail to be ibLa to offer apeolfio critique.
2. ] Chapters L and 2 contain wsh valuabl* ioferoatlM on the Clau
H#tar Act's Section )0t planning procaaa and Idaho history pertaining to
uatar quality wbioh abould bo of qreat latacaat to Idaho's coneacaad oltl"
ssns.
2 4 In ^anacal, we acron^Ly endorse, ao conditions ai noted later,
the Draft Plan aa aa edsquate docuaaat for Uia dovarnoc* a cutLtlculon
and tit* U.8. fnvironMiital Protection Agency's approval. Hltti a fat*
minor revisions, the Draft plan should be aora than sufficient to iaplaMnt
the intent of faction 201 of Uta rederal Water pollution Control Aoc and
lea aoandnanta.
2.I One of ouc major concerns about tbe Draft flea la the protocol
of Its presentation to the U.S. C.P.A. The Draft Plan fee we aeeiuae the
fine! version will ba| ie eeeeotially e nneiry docuaent, end therefore.
Potletch Corp. Detailed Statement
l/2?/7»
Page 4
quite general. Me uadartUnd that a auaber of tupplaaeatal reports da-
•crlbio? details of th« Plan'a alaaeDti will bo pare of the overall docu-
atat to bo certified by the Governor end autaiUui to the U.B. C.P.A.
That le ee it should be# provided the supplemental information la presented
end rocaivad 1a the proper contest.
To explain fur than Tbe Clean Water let called for the stataa to
develop profane and proceaaee for control of nonpoint pollution. E.p.A,
baa subsequently Isauad directives detailing tiwie iteas constituting en
adequate 20t process and Meter Ouality Plan. Wills S.P.A. is vssted with
the eutberity to approve Idaho's approach to noepoinc source pollution
control, nowhere axe they given authority to approve or dleepprove specific
ftuiee and Modulations, or any subsequent revisions. In submitting the
euppleeeotal dwioeata of Idaho's Plan to S.P.A* • it should be oleerly
understood that Idaho Is sot asking B.P.A. Cor their Judgsaent of spealtio
ftulee sad Regulations which nay be contained therein, in euopla is che
dosuseat State of fdaho Foraat practices Water frjallty Hanagensnt Plan,
which oooteLne propoead laendaaati to aoee of the Idaho roraat Practices
Aot Bulee and Regulations. I.P.A. lie?ion X'l twelve 'Sllirloultura Nonpolnt
Source Pollution Control expectations end Requirements" are given on pegas
2 and 1 of the IFPWQHP. Xf the Idaho plan Is developed in compliance with
these 12 *&rpeetaciODe and Requlremente* (and we believe the draft plan
la)« then l.f.A, mist approve the plan. But this compliance does Dot
require or Lastly i.l.l.'s approval of or Jurisdiction over the Rules and
tefulatiooe per ia, tn fact, l.P.A. bas indicated that a 200 ailvicultural
propria nay ba implemented on e voluntary* noo-regulatory basle if it provee
effective la seecio^ tiia Clean Mater Act 99ala.
The protocol for the atatee1 206 planning process, the governors*
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Potlacch Corp. Detailed statement
8/27/79
Pago 5
review And certlfleatlon and B.P.A.'i review and tpprovtl la briefed la
ptra^rtpb 4, page 1-2 of tb« Draft Plao, This brU< may be adequate for
lta pufpoae, but It doesn't addraaa our coocaro. we racoareand that tha
Governor's certification letter to s.? A. Include appropriate language
clarifying tha understanding we hava offarad abova.
2.6 Another of our concerns la tha logistic and coat problama of
Implementing a statewide water quality plan. Thla daaarvaa much mora
aarloua conaldaraelon than appeers to hava been given to data. Eatlaataa
of the total coat ot loplaoancing tha 108 program acacavid* ara not avao
m*nt-ion«d la tha Oraft Plan.
Idaho's vast watersheds task* tha task of implementing a statewide water
quality control plan cooat difficult. The cost will be enormous If moni-
coring to aaeese aMP's la conducted In all wateraheda.
A more affective approach would be to aelact a few critical wateraheda
for long-tern research monitoring programs.
Aa aupport for thla suggeetion, we urge a careful reading of a December
11, 1978 report by the comptroller General of the United States entitled
Water Quality Management Planning la Hot Comprehensive And Kay Hot Be
Effective Tor Many Years. Among other things, this report eoneludee that>
"The environmental Protection Agency haa propoaed, and GAO agreaa, that
potential aolutiona to water quality problems ahould be teatad in selected
river beaina before being applied on a netioawide baaia."
Wo racocanend that an eatliaete and brief dlecuaaion of the total coat of
and funding sources for planning and implementing the 208 program In Idaho
be given in the introduction.
Potlatcb Corp. Detailed Statement
8/27/79
Page 6
3 - Cooaente on roreat Practicee element of the overall Oraft Plan pages
1-67 through 3-121 {hereinafter termed F.P. Blement),
Again, thla element contains a number of valid conclusions and recom-
mendations which will enhance its acceptance and lmpleoentetlon. If the
concerns and recooaendatlona In 3.2 of thla statement are eufflclantly
addreaeed in the final plan, <*e endorae the Forest Practicea element and
reooautend lte certification by the Governor aa an adeguete element of the
overall 208 Water Quality Management Plan to be submitted to E.P.A.
Our detailed comenta on thla element are divided into Generally
Supportive (3.1) and Critical (3.2).
3.1 Generally Supportive CDtmaentsi
3.11 Page 3-7S» The statement is cede "The selected Water Quality
Management Plan for Foreet Practicee recoeoaende that the ftulee and
Regulation* of the IFPA, with slight modification* be adopted aa
BMP'a for protecting water quality...* This is a moat appropriate*
beela recommendation becauae the XFPA ha a been generally accepted by
forestland owners and operators aa a practical* workable program.
1.12 Pagse 3-75 to 3-77i Ttie designation of authority under the Plan
among the Idaho Oepartaent of Lande, the IDOW-OOB and other atate
and federal agenclee appeare to have been appropriately placed.
3.13 Pagaa 3-77, 3-78i Provlalon for public involvement appears
to have been adequately covered.
3.14 Page 3-79« Plans for implementation of the Plan are logical
and appear to be adequate, although they may be difficult to achieve
by the targeted datee.
3.15 Pagea 5-14 through 5-161 The cocmaentary and conclusions on
positive and negative Impacta on foreat practicee are generally well
etated (except «• noted berelnefter)*. The statement on 3-14 *lsxple-
mantatlon of the water quality management plan for foreat practicee
should have a beneflal impact on overall water quality* ahould prove
valid.
'Please note our comments under 3.2.
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Potlatch Corp. Detailed Statement
0/27/79
Page 7
3. 16 Coni*qu«Dtly# m tadoci* the Vocaie Prtctica* tltMnc of tht
Orate Plan In g Critical Con—nt»i While we endorae tha Poraat Practicee Element
In ^anaciU It contains mm deficiencies. These ara i
1 >1 Again, we urge that tha State of rdaho not give any ancouragiaant
to I.> A. to challenge tha technical iJtqmcy of tha ai>aclfio Rules
and Bagulatione of tha Idaho Toraat Pcactlcea Act (reference to item
2.5 of this statement). Hot only li it Inappropriate, but io fact
lacking In statutory authority for C.P.A. to approve or dlaapprove our
State regulationei It will ba unacceptable if La Um futura K.V.A.
^ eseerte approval authority over any deeired changee to our Coreat
practices rulaa.
1.22 Environmental lapactn Tta f.P. Element par aa cootalns ooUlof
on poaitlva or negative anvlroniMntal iapacca ralatad to forestry)
thaaa ara found undar CBiPTKB 3 of tha overall Draft Plan *3unwary of
Environmental Impacts* on pages 5-4, 5-5, 3-lJ# 5-14, 3-13 and 3-14.
Thia la highly confuting to people not familiar with tha Plan format.
The preaaot location of thaaa iopecta la acceptable, but we recoroand
that an epphealied page nua^>er reference ehould be added at the conolu-
a ion of tho forest Practices Clamant on page 1-10. Thia comment also
appllaa to other eleaenta of tha Plan.
1.21 Economloet We be1Leva the treatment given to direct economic
lapacte on foraet berveatlo? operatlona ia woefully weak and therefore
mlaleading. Again, there la oo teat In tha Poraat Practice* Elementj
but on page 9*13 of tha overall Draft Plan under 'Negative Impacts...*
tha statement ia mede, *lt baa bean eatlmeted, however, thet thaaa
additional coats ('to tha logging industry1) will be relatively insig-
nificant.* (Baphasis added.) Tttla ateteaent nay ba trua with raapact
'Please note our comments under ) 2.
Potlatob Corp. Detailed Statement
8/27/79
Page •
to tha additional coata of implementing tha Plan's cacossoended
ravlalona of tha Idaho Poraat Practicee icf(i Rules and Regulationei
but tha atateaant la falaa with reapeot to tha total coata involved.
Tha raaaoa ia that Idaho's forest praotlcaa to protect water quality
have baen of a relatively high order because of laws paaaad and
voluntary practicee undertaken prior to the Sactlon 208 program.
Tha principle poiot is that the Idaho Poraat Pcacticaa Act of 1974
already requlree praotlcaa which provide for aubatantial watar quality
protection and thereby incur coata of regulatlone which have been
ignored La the Plan's dlscuasloo of BMP coat.
Wa reconwand that tha teat of tha Plan ba changed to reflact the
total coata of Implementing all BMP* a contained in tha IFFA Itulea and
lone. Thia ooat preaentation ehould encompaee tha affect of
water protective requirementa on road design# construction, uaa and
maintenance including apeolal water control etructurea aucb aa culverta
and croae ditching i aeeding cut banks* fill alopaa and landings* iccaoa-
sida vegetation management! control of puhllo access* and tha coat
of a hutting down aqulpaane and production workers to prevent aoll
erosion during wet weather.
Wa will ba plaaaad to provide cost details If you raguaat.
|.2< Outdoor recreation! Potlecch's Cee-owned lande in Idaho ara
generally open for puhllo recreational uaa and en)oymant. (Note
Attachment 1 for no re detail.)
Although no feea ara charged for thia service* it does require
additional coat* principally in fire protection and road maintenance
coata. Road maintenance has become an especially coatly item, parti-
cularly sloce tha advent of four-wheel drive and other 'off-road*
vehiclea following World War II. Wheal traffic on unsurfsced roada
during wet weather damage spaoiaily constructed watar bars and create
channels which conduct runoff water downhill in tha wheal tracka during
heavy rain and spring snowmelt. Tha watar may cauaa severe road
surfeae erosion and washouts which* in turn* contribute to stream
aedimeotatlon. The problem ia ooat sarvara on steeper gradea.
Speoiel practicee muse ba applied to stop or control thia watar
runoff* Including one or more of the followlngi DCloaura of certain
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Potlatch Corp. Detailed Scacaoent
8/27/79
Page 9
roids co whMltd'Vttilolis during All or part of th« yeeri 2)Extra
BAiotanuc* of eulvtrti and surface cross drains to channel Mattr
off the roads onto the undisturbed forest floor where it ie absorbed
before carrying eilt into etroaaai 31 Seeding of road turfacei with
soil*bindlng grasses and legumes.
All of these extra practices are costly. Yet nowhere is the pro-
blem of public use of private forest roads even mentioned io the Draft
Plan or in the supportive Idaho rorest Practices weter Quality Hanago-
Mat Plea or the E.P.A. Region X Environmental Assessment. We feel
this is a serious oversight, which must be corrected. Public aware-
ness, understanding and cooperation is essential if a 208 program is
to be successfully planned sod Implemented.
Wo urge that a section on public recreational uee of forest roads
be added to the Plan. Again, we will be pleaaed to offer more speci-
fic input if requested.
3.25 Pages 1-67 to 3-70 rorest practices' proportionate share of
total nonpolnt source water pollution! identification of the forest
practices "problem* is generally well stated. Bowever, placing the
contribution of forest prectices in perspective in relation to other
nonpolnt sources, both natural and man-caused, «*>uld be appropriate.
For example# on e notional scale, silviculture is not considered to
be a major source of pollution. This conclusion is supported by a
quote of Mr. Douglas Costle, Administrator of the Environmental
Protection Agency (July 10, 1979 statement before tbe Subcommittee on
Oversight and Review Committee on Public Works and Transportation,
U.S. House of Representative)t
"Sediment Is the primary pollutant from silviculture,
with sediment loss froo forest lands estimated at
less than 41'of the total man-made ¦ediment In EEs
Nation's waters." (Emphasis added.)
'Leae then 4%- is significant beceuse better than a third of the
Nation is occupied by forests. Silviculture may contribute large
quantities of sediment, but this is generally limited to specific
sensitive sitae, and sven then occurs for only a few years during
the long cycle of forest growth.
Potlatch Corp* Detailed Statement
8/27/7®
Page 10
While m have no comparable figures for Idaho* we suspect that
silviculture's contribution to the totai weter pollution problem le
substantially less than from other men-caused and natural sources.
We raconmend the addition of appropriate teat.
4 - Cocmaente on the eupplesiental document State of Idaho Forest Practices
Water frjallty Hanagemant Plan ("Pinel* draltj Idaho bepartment of Health
and Welfare, Division of Environment, July, 1979, (hereinafter referred to
as P.P Plan)
Except for our concerns end recoaoondatlons in 4*2 of thle statement,
we endorse the IPPWQHP es en adequate supplementary document to the overall
208 Plan, and we reccnoend its certification by the Governor if required.
He also strongly endorse the proposed amendments of the Idaho Forest
Practices Act Rules end Regulations contained in Chapter IV, section D of
the Idaho FPWQK9. Consequently, we recommend that the proposed amendments
be approved by the Idaho Department of Lsnde* foreet Practices Advisory
Committee and the Idaho Board of Land Commissioners and adopted by the I PL.
We do have e few concerne ebout some details of the proposed amendmente
which are dlecuesed in 4.23# 4.25 4.26 and 4.27. However, thoee are gene-
rally minor and can be corrected later if neceeesry.
4.1 Supportive commentst Our supportive consents on the P.P. Bloment
on the oversll Dreft Plan under item 1.1 alao apply to the P.P. Plan. More
epeclflc consents follow.
4.11 The Foreet Practices Plan is also a professionally prepared
document. Robert Braun, DOE's 200 foreet prectices coordinator, and
his staff deserve high mirks for a yeoman effort.
4.12 Page 2 o' ".he IFPWOMPi We believe the IFPWQHP adequately
addreeeed the twelve 'Expectations and Requirements* for a 208
ellvicjltural nonpolnt control progrran. We commend you on a good
Job of coo^lylng with such complex requirements.
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Potlatch Corp. Datallad stataaant
6/27/79
Paga 11
4.13 Paga 4li Tba concapt Of aita-apaolfic application of SMP*a
la •ictllaat.
4 14 Ptga 31, with Juatlficatlon on paga 4i, paragraph ]i Tha pro-
vision for a apaclfio prooadura to obtain a varlA/ica tioa a praotica
via a writtan raquaat to tha IOL (Sao. >12.01) appaara to ba workabla,
provided tha IDL has adaquata ataff to procaaa raquaata within 10
day*. Bavlaion of tha rulaa nay ba naeaaaary 1£ ajtparianca provaa
tha procaduxa to bo too cuabaraooa.
IS Paga S31 Tha addition of a apaoiCle cafaraoca to tha Idaho
Strata Oiannal Altaration Act and tha Idaho Watar Quality Standard*
and Waatawatar Traataont Raquiraoaota (Sao. 112.01(2)1 la aa Impor-
tant additioo. Thia ahould halp oparatora to avoid violation of
Idaho law and ragulationa which ara in addition to tha roraat Practical
Act, although it will add to adainlatrativa ccaplicatlona.
^ *14 Paga 73 to 71 "Uaa of Chaaicala and rartiliaara'i Tha connanta
q\ undar 4.IS apply bora alao. Bowavar, tha "auggaatioo* oo paga 7)
that "tha Idaho Dapartaant of Landa provida tha ftulaa and Raqulacloaa
of tha IPL (Idtho Paatloida Law) to thoaa indlvlduala upon racaipt of
notification* would halp allavlata tha problaoi. Wo racocanand that tha
IDL follow thia auggaatioo.
4•17 Paga S)*|}i Tha dlaqro&a dapictinq tha aaquaaca of procadura
pertaining to anforcoaaot ara a*callant. iaauain^ thay ara accurata
Iwa havao't chaokad), tha diafiuu clatrly illuatrata tha cooplax
procaduraa raquirad undar tha irpA partainlnq to inapactiona, anforca-
nant to rapalr daaaqaa cauaad by violatlona, appaal by tha oparator
(raquaat haaring) and court action by IDL to racovar coat of repairing
daaagoa if nacaaaary. Thia will prova halpful to avaryona involvad.
4.2 Critical Cooaontai Our comanta undar J.2 alao apply to tha
P.P. Plan. In addition, wa offar tha following.
4.71 Wt call your attanclon to our c""""^nta ralatlva to | p.A.
approval la Itaaa 2 3 and 3.21 of thia atataiapnt.
Potlatch Corp. Datallad Stataaant
1/27/79
Paga 1)
4.22 Paga 20a, paragraph twoi "B.P.A. ahould alao provida axpartlaa
La •valutilo9 offactlvanaaa of SUP'S and davaloptnq watar quality
critaria for foraat practlcaa.* Thia la tha kind of wording wbich
cauaaa our coocaro axpraaaad in itaaa 2.3, 3.21 and 4.21. Zt nay
ba approprlata for C.P.A. to provida guidanca, aa in tha *Cxpactatlona*
oo paga 2# but wa faal atroogly that watar quality critaria ahould
ba davalopad at tha Stata# rathar than radarai laval, aa provldad for
lo Saotloo 201 and othar aactlona of tha fadar*l Watar Pollution
Control Act. Ma ballava tha Stata of Idaho ha« aufflciant axpartlaa
to do tha Job—by paopla who ara cloaa to and asparlancad in tha pco-
bUai.
ba aubatltuta^ for *aypartlaa*
lo tha aantanca cltad abova.
4.23 Paga 30i "Monitoring of oparatlona during chaaical applicatiooa
ahould ba aeooapliahad by tha oparator.* IN agraa that tha oparator
abould follow avary raaaooabla pracautlon and raport auapactad con-
tamination of watar aa raquirad by tha tpagl^lo raqulationai but tha
atataaant oltad abova could ba confuaiog to tha uninforaad bacauaa it
iapllaa that tha oparator la raapooaibla for conducting loauaaa
taating to datanalna chaaical concentration, which could ba prohibl-
tivaly aapanaiva and la not raquirad undar tha propoaad raviaad raqu-
latlona*
Wa racownd that thia confualon ba allmlnatad by adding 'NOTE
SactIon 816.12 of tha fTPA fejlaa and Baqulatlooa, paga 78.*
4.24 Paga 41, paragraph onai Tha definition of 'nonpolnt aourca*
could ba arronaoualy conatruad to aaan that culvart dlachargaa of
natural runoff watar ara point aourcaa. Wa rocoaaaand a bottar
definition of nonpolnt aourca, which would include tha concapta that
Poonpolnt pollution occuara ovar wld^apraad araaa in aaaoclatlon
with natural clle^tlc avanta (precipitation), and 2)can boat ba
controllad through application of BMF'a rathar than watar traataent
or *and of tha pipa* tachnology.
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PotLatch Corp. D«t«iled Statement
8/27/79
Page 13
i. 25 Page 49, Sec, Oil.24i Tt»e cavU«d itcatA def inltione (Cltasoi
C and til , although not perfect, are « big Improvement--it noc
misinterpreted. The retarded definition of "stream protection* xones
together vicik trie new eccoopanylng diagrams will help clarify appli-
cation of pertinent reguletlone.
Development of • eystea for classifying streams ie crucial and ie
diacuased on page 46. While the problea ie generally well stated,
we specifically ragmat an opportunity to review and eonaant on the
proposed claealfLcetlon system early In iti development,
<. 26 Page 59, Sec. 013.06(1}i "Piece removed oaterial and other
alaah out aide the Class I SUets Protection lone or otherwise treat
aa prescribed by the Department.* (Bopbaiia added.) Placing such
material above the high weter mark la reasonable, but we tubalt that
waving it to outside the SPI will be highly impractical and will cause
more soil disturbance in many sltuatlone than if treated in place.
Debris near atraembanks etabilitea rapidly and, aa shown by governaent
research, actually helps prevent sediaent f roa reaching streams. Ue
•till feel there la no technical juetificetloa Cor thie overly restric-
tive, unneceeeery and expensive requirement.
We ere not suggesting that the "final* f»P. Plan be changed at this
time, but we feel the IPL will need to nudy this requirement poat
carefully and possibly provide for some standard variances It proved
oecegsary by experience.
<.37 Pagea 6J-71, "Road Construction end Maintenance"! The propoaed
revision is substantial Improvement of existing regulations. However,
Sec. 914.03(13), page 64, on "ftause of existing roads..." is still
confusing. The stateaent "If such reuee la la temporary violation of
other rulee, the operator must obtain written approval from the
Director according to Rule 612.01* (eapheele edded) is the crux of the
confusion. first, reuee of roads constructed prior to peasege of
the IPPA nay not be temporary, Second, the operator cannot be held
in violation of current law for pest practices. So the question
ariaeei which other rules would be vlolated7 The answer, although
not readily obvious, la reuse where reconstruction, maintenance or
eiroalon control practlcea are involved.
Potletch Corp. Deteiled Statement
0/27/7$
Page 14
We believe the intent of theae revialona le good and essentials
but beceuee there ie a large mileage of roede conatruated prior to
the IPPA, we feel the problea and its solution would be more clearly
detailed by dividing Sec. 814.09(13) Into subsections covering new
ccnetructioa, re-coostruetion and reuse. Wa are not proposing any
revisions to the regulations now, but we recommend that thie should
be a high-priority item for the forest Practices Audit Teen and IQL'e
forest Practices Act Advisory Cocolttee to consider.
4.28 Pages 92, 96, 97, 102 Training and education Program
This is a highly Important section. Generally, it's veil done, but
we heve one recomaendetloa. Poreetland owners and operators or
their associations should be included 1a the development of educational
materials and progress. Such participation in development would tap
a lot of practical day-to-day knowledge and experience which would
help greatly to lnauxe credibility and acceptance of the prograa.
We recoaanaftd that IDL contact the Worth Idaho Foreatry Association
and the Idaho Woodland Council when _lt begins deyelognsnt__gf_j^he
TtB prograa.
4.29 Pages 123-125 re. weter quality aoaltorlng, criteria, standardsi
Ue coasend the IDHW for the additions to pagee 12S and 126 because
they briefly address scoe of our concerns ebout the Peb. 1979 Oraft.
Bowever, in our opinion, the text le still oversimplified and there-
fore aisleadlog. We ere particularly concerned about lithe baaic
concept and philosophy underlying the great eaphesis on nonpoint
"water quellty criteria"* "sediment standarde* and "water quality
monitoring0! and 2)development and application of the tame. Because
theae are highly Important and complex mattera, we offer the following
concernsi
4.291 Basic philosophy
We support the basic concept of regulating nonpoint aourcee
through use of Best Men*geaent Practlcee. Also, we understand
the need to eventually develop e method for aaaesslng the effec-
tiveness of SHP'si but atteaptlng to relate effectlvoness to water
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foilatcfe Corp. 0«tilU4 3tataaant
V2V79
?*qa 15
«
•atctM Qiturnl varl ability Id a glvM watarahad* ct which
thas« ai« is Idaho, It nonpoinr BMP*# tttolCOrtAf
la actually caqutrad
Q3 P*9* 2) of tha fab. 1179 Draft Ilu, uodar Part V* "Coaca And
4( fiaat ?ifeQtU«a*f l.a. t
•fli» flaal raaulta at t&aai proAtaaa ara that tha laauaa
ot 4*£lnls9 and aenitorinf *«t«r quality and aatahJlrblnq
auantlfUbU cauaa-affact tfalattgnahlpa baiMaa • ipacJ/lo
tOfoafcrY Dpar-atioa aid caaultlftq Im^acta on gatar quality
ni< aa y*t. unaolvad.* (ItapMata ourfc*]
Unlortuaae«lf« tbia pact waa eaitud (sea tha '"(leal* July
1979 9.9, Plan. Halthar la It adaquataly cowared la fci»a t.t.K*
BagIon X 'CnvlnnMAUl Aaaataaant*. Wa tMU«v« thla vaa m
aarloorf arror bacauaa It via a Kay aUo*ni.
Sil/Hdlvatai Vnpac-ta on watat quality occur oat ocvly a* a
raau]t of bad 'a aotlvitlaa but alao la c«ap«aaa ca natural
watarabad procaaaaa inctudisg fir* «aI major aacaorloqloal
av«ata auch aa flood#, drouphta and wladatortaa. Aa a raaolt,
natucal and aan-cauaad affaota ara lotarnixad ovar wldaapraad
ama. and vary tr«a«Adoualy tbrougb tlaa. Coaaaquaocly, it
la aktrwaLy dL(f Lcult to sataui* 'cftae^a* eauaad by land
aanaqajaaat activity, aapecially If tbaia ion* taca piocaaaaa
ara aaaaurad only (or abort parioda of tiai.
eotlateb Coip- oat.aJ.lad Stataoant
• /»»/«
paqa 16
4.291 tenitotinq Of WP'a afUctWan*»a
Ha «gia« that oyar tha long haul, avicaaaaful laplaaaoutlon
q< tha r.f, Han caata on a^Cacelva VMP4*..
k aathod lor aaaaaalnp tJ*e aCfactiva&aaa of 5XV'a atvould
Qfiiv ba dmvatapad in a rigofoualy controlimp, lo*>g-fcana raaaarch
approach. foraat practlcaa vatarabad raiaucb bara tn Idaho haa
cohtrlbutad alqclficantly to tha cuccant itata oC tha art and
o*jr Poraat Practlcaa Act Pulaa. Qthar haw raaaarch pro^acta ac®
Wdatvty, aa aaatloaad do pagaa 12J-JJ4.. Intaoaiwo affoct# auch
aa thaM ««a |UU kh«wl«d^« a< tha affacta o£ foraat (cactl^aa
oa watar quality4 and parbapa doc* tn^uantly on biological and
pbyaloal Inattaaa alfaotai but tbaaa c*Ucion«bLpa cannot ba
aacabiiiiMd *»y aAort-cara manltotlnq of low IPtanaity.
Watar quality wmltptlb^ can aatitUtb that Mhtn Wa aca
violatad, -wacar quality dat»rlora&aa* a ad aooUocLof abould b*
uaad to ^ravant ruch abuaaa. But naaaiiitg tha adaqua«ry of
BMP** to achlarvl&9 uatar quality fOala 1* aAOtbar oattar. ftlO->
loqlcal #dJ pbyaicai ig^aot* cannot ba avaluacad without taking
into acoooAt tha looq-tar* varlatloo lmpoaad by tha natural eye I a
of fcraat tiMth. da«ay» aataattophlo auaata (auch aa tica) and
inminf cappocary «ffacta on vitax quality^ Only lonq-taca
raaaarcH can aatabllab cauaa-a^facc
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Potlatch Corp. Dotailed Statement
8/27/79
Page 17
the PLon text or its appendices. The only reference to coet effeo-
tiveneas la the lait sentence In paragraph three* page 126 "Although
the coat nay be significant* the long-tern benefits of efficient
resource aanagement nay far outweigh the costs" (esphesls added).
This statement is true to a degree, but et som point* incremental
improvements in water quality nay not be Justified by the coats
required. In (act* proper balance of these factors is the real
definition of "efficient*.
Second, auch a syatea could lead to generalisation ebout management
auitabilitiee of an area* The system would need to be highly detailed
if it were to heve value for site-specifio application of BMP's. The
4> potential danger here oould be the tendency for inadequately informed
vo
people to try to enforce broad-based blanket rules and atondarde to
cover the great variability of alte conditions within a given wetershed
Third, the lend manager must heve flexibility to apply his Judgement
Flexible* appropriate management can only be preecribed perfonaed
on a site-speciflo basis. In thle regard* we agree that it Is desir-
able to recognise differences in management needs as physical and
biological factors vary geographically. The current IFPA Rules
recognise this variability* and for the most part, allow an appropriate
flexible approach.
In summary, we feel the recooaendetion for e etatewlde land
claaaification system is an example of a specific refinement which may
eventuelly be warranted* but which la not appropriate at this juncture
Certainly we should gala experlance with our new Rules before we can
jueclfy auch a eystsa. if future experience lndicetss that a statewide
Potlatch Corp. Detailed Statement
0/27/79
Page 18
land systems inventory ie desirable, it should then be proposed.
We urge that the probleme Involved be evaluated and that an
estimate of the cost be included early In the plan development.
4.31 Pages 129*132* Forest Practices Audit Teaai The appointment
of a rorest Practices Audit Team is a Xey new proposal; if adopted
as proposed* the Team will have a highly influential ovarall rol« in
evaluating the effectiveness of BMF's* advising IOUW in development
of water quality-related standards and recoonending chaogws in the
IWQMP, BMP*s and agency administrative procedures. However* as
presently worded, the makeup of the team is unclear, I.e., page 130.
paragraph one "In addition to representatives of IDBW and IDL, the
team may alao include Idaho Fish and Game* Forest Service* BLA,
University of Idaho* and the private sector." (Raphaels added.)
The word *®ay" is indefinite—it should be "will" ae has been the
case for Che PAC* FPTAC, etc. Also* 'private sector" should be
"private foreetland owners". We presuoe the IDBW will use balanced
judgement in appointing teem members but we strongly urge the specific
inclusion of e technically well-qualified member to represent the
industrial private foreetland owners of Idaho. The appointment
should be node on the joint recommendation of the North Idaho Forestry
Association and the Southern Idaho Forestry Association or the Idaho
Forest Induatriea Council. Another tagfntoer representing the small
private non-induetrlal woodland owners ahould also be appointed.
3 - CoBSDonte on the supplemental document Bivlronmental Assessment. Idaho
Forest Fraccicee, Idaho Statewide Water Quality Kanaqeaent Man, U.S. •,?.A.
Reqicn K, July*'l9')9
He have not yet had time to peruse the document sufficiently to cifer
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Potlatch Corp. Detai. l»d 8tac«nut
0/27/79
Page 19
•n Initptit oritlque* H« do intend co cooMiit directly to S.P.A. B«fioa X
b«for« Itl S«ptinb«C 24 d««dUna.
Briefly, out hucci«l v«vl«« leede ue co btlUvt that Um KM 1» pro*
(••¦louUy written, and la priMrily a cowlMUClofl and raurtAyiMot of
the Idaho fornt Pncticat 204 muc Qti*lity MiniftM&t Plan# which ia,
in turn, i condensation of the University ot Idaho*a Technical kevlew
Taaa (TBTI report. A Cat# addltlona to thai* earlier docuaanti Includes
1. A review of the Idaho foraat industry.
2. A review of the applicable Idaho and federal lawe, regu-
lations and pro9ra«e.
i. Severel tablee and «ape.
Ui 4. Chapter 4 on 'tapecte...*
O
Theee addltlona have been briefed la the Oraffc Idaho Water Quality
Management Plan.
Iteoa 1, 2 and 3 are valuable addltlona. Also, Chapter < la good
fro® the atandpoinc of indicating poaltlye iapacta oa water <{uality«
vegetation, aoila, wlldLiCe and Ciaherlea. however, the eectlon "Impacte
on roreac Operator* and Operations" (pagea 6-4 through f-7) la atill
tnadaquate becauaa it estende aorta of the nialeadlng conoluaiona advanced
by the TRT, e.g.. the additional coats of Isplaaiotiag tha 208 BMP' a
'will be relatively inelgnlfleant* (note our content J.21 on page 7).
Another weakneea ie aqaia the failure to point ouc that recreatlonaI
traffic la a major contributor to nonpoint aource itre*a eedlttent and a
major problem lo Coreat road melntananoe. Tbeae concerns should be
addraaaed la e supplement to the EAA. (Mote our cement J.2I on page • *)
Ttila concludaa our cocnenta for now. Thank you for thia opportunity
to present our statement.
Attachment I
(See ancloaed map for store detail)
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3 Action .ifto1*<*iennnq Agencies
-14-
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-18-
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