Document 51mLgrV3JGbDGKQD71NxDMeR

C Ss-M :i % %6 SI Georgiaa'sndFoWreastetsr Maintaining a clean and plentiful water supply for Georgians is critically dependent on our forests. For more than 30 years, Best Management Practices (BMP's) for forestry have successfully addressed issues affecting water quality. This is also the primary reason regulatory agencies have not found it necessary to add restrictions to normal forestry practices. Compliance with BMP guidelines has risen annually, with overall implementation in 2015 measured at 91.13%, a 1.2% increase since the previous survey in 2013. Five year southern region summary of state BMP implementation results: http://bit. Iy/2sxx35s. Recent Georgia forestry BMP surveys: http://bit.ly/2s6fUOF. To ensure continued success of the non-regulatory forestry BMPs, states provide ongoing training for timber harvesting professionals, regular monitoring of forestry practices, and enforcement when water quality issues occur. Shifting to greater federal regulatory authority would lead to confusion and uncertainty in the forestry community and hinder forestry's powerful impact on Georgia's water resources, jobs, revenue and income. Continued funding of these state programs is critical for sustained success. The silvicultural exemption for NPDES permitting has allowed common-sense and regionally-specific, science-based knowledge to oversee all normal ongoing silvicultural activities through BMPs. The Clean Water Act (CWA) mandated that states develop water quality programs, and along with this, the BMPs have been updated through the years as new scientific knowledge has become available. Georgia's latest guidelines are included in our 2009 manual, which represents the best collective knowledge and efforts to establish sound, responsible, guiding principles for silvicultural operations. Minor updates and further clarifications for Georgia are planned for early 2018. BMPs are: 1. Well established (30+ years). 2. Widely understood and accepted by the forestry community. 3. PROVEN SUCCESSFUL for all phases of forestry. Georgia has Forestry BMP Survey results dating to 1991. Water quality survey data proves the points above, with generally high scores of approximately 90% or better for the last decade. Because the current system is working effectively for forestry, additional regulation would only lead to excessive complications and costs. Three Core Tasks of the Georgia Forestry Commission's Water Quality Program: 1. Develop/revise Best Management Practices (BMPs) & educate forestry community and general public SMoausttheeraTsimtebrnerWHoaordvePsrtoedr u(MceTrHs)AWssoorckisahtioopns(SinWcPoAop)eloragtgioenr with SFI, UGA, education. DNR. Continuing Logger Education (CLE) for various forestry companies. Online learning (Harvest Planning, Roads, Stream Classes, Stream Crossings). Publications (website and printed versions). Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00132189-00001  BMP training for landowner workshops. BMP training and meeting with various NGO's: environmental groups, water planning councils, etc. BMP training and work with various government entities: GAEPD, USEPA, USACE, GADNR, etc. Site visits and detailed BMP advice for anyone in the forestry community and general public. 2. Monitor BMP implementation and compliance in an open/honest manner Biennial BMP Surveys of completed forestry operations. Continuous BMP Assurance Exams for ongoing forestry operations. Internal GFC Firebreak Inspections for pre-suppression and wildfire firebreaks. All types of forestry harvesting and management operations. All ownership classes; private, corporate, public. Large and small scale. 3. Investigate & mediate forestry water quality complaints in an open/honest manner All types of forestry harvesting and management operations. All ownerships classes; private, corporate, public. Large and small scale. Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00132189-00002