On October 3, NASF submitted joint comments with the Association of Clean Water Administrators (ACWA) to the Environmental Protection Agency (EPA) about their notice of proposed rulemaking regarding revised stormwater regulations specific to permits not being required for stormwater discharges from logging roads.
NASF and ACWA comments support EPA’s proposal that multi-sector National Pollutant Discharge Elimination System (NPDES) permits are not the most effective mechanism to control these dispersed sources nationally. The comments also agreed with the EPAs proposed revisions stating that a national requirement to issue NPDES permits to logging roads is not likely to be the most efficient way to measurably improve water quality or overall forest health.
NASF and ACWA comments reflected that the best way to handle permits for forest roads is for states to decide to issue permits to manage adverse water quality impacts from these and other types of discharges, including those that may result from logging road construction/operation.