Updates to Pennsylvania’s Timber Harvesting Erosion and Sedimentation Plans

Best Management Practices (BMPs) are actions and procedures taken during timber harvesting operations to protect water resources from accelerated erosion and
sedimentation and other forms of pollution. Pennsylvania law not only requires that BMPs be implemented, but also that a careful plan for their use be developed before a harvest even takes place. These plans outline how, when, and where BMPs will be applied on a site.

In early 2017, the Pennsylvania Department of Environmental Protection (DEP) advised the conservation districts to discontinue the use of the Timber Harvesting Erosion and Sedimentation (E&S) Plans that are widely used to comply with Pennsylvania's environmental regulations and obtain DEP permits on nearly all timber harvests in the state. Foresters became unsure of how to comply with DEP regulations, and the situation created confusion and inconsistencies among the conservation districts.

Pennsylvania SFI Implementation Committee (PA SIC) staff led an ad-hoc working group made up of representatives from industry, county conservation districts, and state government with the purpose of developing a revised version of the plan that would satisfy current regulations. After nearly a year of work, the group finally reached consensus with DEP on a final draft and the updated E&S Plan was made publicly available through DEP's eLibrary (also available through the PA SIC website).

The new plan is considerably longer than the old version; however, this is mostly because of informative guidelines and specifications that are required to be included. There are also four additional BMPs that have been added: turnouts, water deflectors, compost filter sock, and wood chip filter berms. These are all DEP- approved practices that are sometimes used on timber harvesting operations, but were not previously included in the E&S Plan.

The recommended spacings have been changed for ditch relief culverts, waterbars, and filter strips. Of these, the most significant is the minimum forest filter strip width changing from 50 feet to 75 feet. The recommended seed mixtures and rates have also been updated.

The process for completing the form is nearly the same as it has always been, with a few exceptions. First, Sections 9 and 10 are new and address concerns related to natural geologic formations (as a result of the I-99 "disaster") and thermal impacts to surface waters. In most cases, these sections will simply be addressed by checking the "No" box.

Next, Section 12, Maintenance, now requires written documentation of BMP inspections on a weekly basis and after each stormwater event. This has been a regulatory requirement for some time, but not included in the E&S Plan. Our working group created a simple one-page Timber Harvesting BMP Inspection Template that can be used to document inspections. DEP has reviewed our template and concurs that it will satisfy regulatory requirements; however, because they declined to include it with the E&S Plan, it is not available through DEP's eLibrary. The inspection form must be downloaded separately by practitioners through the PA SIC website.

Lastly, Section 13, Site Cleanup, includes a requirement that a Preparedness, Prevention, and Contingency (PPC) Plan be written for the timber harvest site. This plan addresses hazardous materials onsite and has also been a requirement not included in the E&S Plan for some time. Again, our working group developed a straightforward PPC Plan template for timber harvesting that DEP has reviewed and considers to be sufficient for use. Several loggers also reviewed the plan and provided feedback. DEP also declined to include this with the E&S Plan, so practitioners will need to download it separately.

The Pennsylvania SIC would like to thank the staff from DEP's Bureau of Clean Water that cooperated with us on this effort and all the members of the working group for their input and efforts. We would also like to acknowledge the assistance we received from the Hardwoods Development Council and the Executive Secretary of the Pennsylvania State Conservation Commission.

For more information about the Pennsylvania Sustainable Forestry Initiative Implementation Committee, please visit the website or call 1-888-734-9366.