Understanding Forest Practices Compliance Monitoring Program
How the Compliance Monitoring Program provides an objective assessment of Forest Practices rule compliance in Washington State.
History & Background
The 1974 Forest Practices Act established the Forest Practices Board, an independent state agency with thirteen members appointed by the Governor comprised of the public, stakeholder groups, and DNR representation. The goal of the act was to regulate forest activities on state and private lands in Washington state to protect public resources and ensure the continuation of a viable forest products industry.
Public resources are defined as water, fish, wildlife, and capital improvements of the state or its political subdivisions. The Forest Practices Board Manual provides technical guidance on implementing the Forest Practices Rules.
The Compliance Monitoring Program (CMP) was first established in the 1999 Forest and Fish report, which proposed increasing measures to protect water quality and riparian-dependent species on private and state forestlands in Washington, based on the best available science.
Study Design
Compliance monitoring is linked to DNR’s responsibility to ensure that operators and landowners follow forest practices administrative rules when they conduct forest practices activities. Monitoring provides feedback to the Forest Practices Program about the pattern of on-the-ground compliance with forest practices rules and identifies focus areas where training, guidance, or clarification is needed.
The Compliance Monitoring Program (CMP) began with a pilot study in the spring of 2006. Since that time, CMP has collected data yearly on forest practices activities post harvest in all parts of Washington state.
The CMP informs the Forest Practices Program by providing an objective assessment of rule compliance. The Forest Practices rules direct DNR to provide “statistically sound, biennial compliance audits and monitoring reports to the [Forest Practices] board for consideration and support of rule and guidance analysis" (WAC 222-08-160(4)). The results are compiled into a report, which is publicly available online . These results are presented to the Forest Practices Board at the conclusion of the biennium.
CMP staff visit over 200 sites over the course of the biennium, collecting data in the field to assess whether the Forest Practices rules were followed during harvest. These visits occur across the state of Washington, in all six DNR regions .
Eight types of resource protections are examined by CMP each year. These include:
- Fish streams with harvest allowed outside of inner zone ( NIZH )
- Fish streams with specialized inner zone harvest prescriptions applied, including Desired Future Condition 1 ( DFC1 ) and Desired Future Condition 2 ( DFC2 )
- Non-fish perennial streams (Np streams)
- Non-fish seasonal streams (Ns streams)
- Forested wetlands
- Non-forested wetlands (type A or B wetlands)
- Road construction, abandonment, and maintenance
Forest Practices Applications (FPAs) set to expire the previous year are screened for these prescriptions and added to a total population. A sample population for each prescription is determined based on previous year's data and statistical modeling.
The samples collected by the CMP need to be distributed proportionally amongst the regions. For example, southwestern Washington hosts the highest number of FPAs statewide and southeastern Washington hosts the fewest. Thereby, the highest number of field visits for CMP are in southwestern WA, and the lowest number are in southeastern WA. The CMP ensures the sample population is proportional to the total FPAs approved for that region each year.
Once populations are established, FPAs are randomly selected for potential field visits. Once selected for review, FPAs are submitted to their respective region to check that all forest practices activities have been completed. Field visits are set up with landowners and foresters regionally.
Each prescription involves a field visit to collect data to answer specific questions relating back to a unique forest practices rule. More information on sample selection can be found below.
Some visits may require measuring and counting trees, delineating the core, inner, and outer zones adjacent to the stream, drawing bankfull width, and walking the perimeter of the buffer to check for stumps.
Data is recorded in field notebooks alongside a team of experts from DNR, Department of Ecology, Department of Fish and Wildlife, tribal representatives from local Native tribal organizations, and Compliance Monitoring staff. Landowners and foresters are welcome and encouraged to attend each field review.
Following the field work and prior to leaving the site, CMP staff fill out forms alongside the team of experts. Forms include individual questions with reference to the Forest Practices rule appropriate for each question, and the team answers these questions together to determine compliance ratings for each aspect of the prescription. Forms are signed by attendees from DNR, Department of Ecology, Tribal Nations, Department of Fish and Wildlife, and the landowner or landowner representative.
Back at the office, data from forms are inputted and anonymized to remove identifying information. Field review visit forms are kept on file and sent to landowners as requested.
While the goal of the Compliance Monitoring Program is to understand rule compliance, deviations from compliance (instances in which the rules were not followed correctly) are sometimes found during field visits. The Compliance Monitoring Program is not a regulatory enforcement process. Once data has been collected on compliance, it is uploaded to the CMP database without identifying markers.
However, regional district managers and Forest Practices foresters on field visits may follow up on deviations from compliance, should they deem mitigation necessary.
Following the completion of sampling for the biennium, data are checked for accuracy and quality control, then submitted to a contracted statistician. The Compliance Monitoring Program manager and statistician work together to create a summary report of findings for the biennium.
A deeper look at the sample selection, data collection methodology, and statistical analysis methods used for CMP are presented later in this story map.
Field visits are the core of the CMP, and present great learning opportunities for new employees in Forest Regulation or regional offices to learn the rules in practice. They are also a chance to meet with landowners and to strengthen the bonds between DNR and forest managers and between division and regional staff. The CMP operates in early spring to early summer to collect these samples, rain or shine. The field work required for CMP data collection can be difficult, including crossing recent harvests, climbing steep terrain, and working through large and small streams in heavy blowdown.
Figure representing the process for sample selection, based on the 2020-2021 data as an example. Click to expand.
Sample Selection
The process to find sites for field review involves multiple steps, as shown in the figure at left. First, the Compliance Monitoring Program sends a query to Forest Regulation IT to gather the entire population of Forest Practices Applications (FPAs) that expired over the previous year.
Next, Compliance Monitoring staff and the Department of Ecology screen the applications for the 8 prescriptions to be sampled. Screened FPAs are added to a new sample population.
Total prescriptions by region are counted, and used to ensure that field reviews are proportional to the forest practices occurring in that region. In 2018-2019, 40% of FPAs that included a 'No Inner Zone Harvest' (NIZH) prescription - a protection on a fish stream in which the areas closest to the stream are not allowed to be harvested - were from Pacific Cascade region in southwestern Washington. Therefore, 40% of site visits to examine NIZH prescriptions were in Pacific Cascade Region.
Photos from field reviews with Department of Ecology and DNR representatives collecting data on site, 2022.
Data Collection
Field reviews may involve representatives from DNR such as the local district manager, region office staff, Forest Practices foresters and local foresters, interns and trainees, staff from the Department of Ecology and Department of Fish and Wildlife, and representatives from local Tribal Nations.
Field site visit in South Puget Sound region, 2022.
To collect data, riparian prescriptions around fish streams necessitate an individual in the stream drawing bankfull width (width of the surface of the water at the point where water begins to overflow into the active flood plain) and measuring the length of the stream with a string box.
The length of the no-cut buffer required by the Forest Practices Rules varies depending on the prescription. Inner buffers - those closest to the stream or wetland - and outer buffers - those on the outer edge of the required buffer around a stream or wetland - are marked using flagging tape and laser range finders. When a certain number of leave trees (trees leftover and not cut during the harvest to serve as protective barriers for fish streams, providing shade and habitat for other species) are required in the inner or outer buffers, the total number of trees are tallied by the field crew.
A culvert for a fish stream found during field review, 2022.
For field reviews, prescriptions are assessed for resource damage caused by the harvest, and any mitigation performed post-harvest to reduce this disruption. These prescriptions are also checked for correct typing - that is, the category of the riparian resource, such as a forested wetland, bog, or non-fish perennial stream. If a resource is typed incorrectly, it may not have been protected correctly.
Roads prescriptions are assessed for their susceptibility to produce runoff or sediment deposits in stream ecosystems, including culverts installed or maintained during harvest and new road building or abandonment.
Possible Ratings
Compliance Monitoring field visits can result in three possible ratings for each rule applicable to the prescription:
- Compliant - the activity is compliant with the individual Forest Practices rule.
- Deviation - the activity does not meet the requirements of the individual Forest Practices rule.
- Indeterminate - compliance cannot be determined for the individual Forest Practices rule; this rating can also be considered a 'no data' data point, telling a story about an issue that may need to be addressed through training, education, or clarification of the rule. Indeterminate ratings require a detailed description of the situation leading to an indeterminate call.
Statistical Analysis
Data collected from the Compliance Monitoring Program is recorded in a database, and used for in-depth statistical analyses to understand how current 2-year trends vary across the state and fit into the previous decade of compliance monitoring trends.
Some statistical analysis tools are very simple, such as taking the total rules assessed for a single prescription and dividing the number of rules with compliance ratings over the total, or the total rules with deviations over the total assessed. This gives us a ratio- or a rate- of compliance and deviations in these prescriptions across the state. For example, if 99 out of 100 rules are compliant, with 1 rule deviating from compliance, compliance rate would be 99% (and deviation rate would be 1%). These results are summarized in the report sent to the Forest Practices Board every two years.
Field sites can vary wildly in elevation, understory and brush, and canopy cover depending on the management activities, region, and local ecosystems. Pictures from field visits, 2022.
More complicated statistical analysis methods are used to understand long-term trends in compliance rates. A jackknife ratio estimator is one major tool used to understand these trends. The jackknife estimator is a type of boostrapping - a test that uses random sampling to measure the accuracy of the samples in understanding the population as a whole. In other words, the Compliance Monitoring Program collects data at only a subset of field sites across the state - around 200 site visits over two years - to represent the total population of between 3,000-4,000 actual field sites. The goal of statistical analysis methods is to explore whether the small subset of samples CMP is collecting can actually be representative of state-wide trends in a much larger population.
In statistics, the jackknife technique "is a rough and ready tool that can improvise a solution for a variety of problems." As long as the data collected by the Compliance Monitoring Program is randomly selected (the sites) and enough of the data is collected (based on sample size estimates), we can use our sample population to understand the greater compliance trends across the state and compare these to the previous decade of data collected and analyzed by the program.
Once all field data has been collected, recorded, and uploaded to the database, it is used to explore rates of compliance with the Forest Practices Rules across different prescriptions, small and large forest landowners, and state-wide.
The Compliance Monitoring Program examines compliance rates as the total number of rules that were followed accurately divided by the total number of rules assessed for all site visits across the state.
For example, in the 2020-2021 field data, the Compliance Monitoring Program visited and collected data from non-forested wetlands at 39 field sites. At each field visit, a possible 13 questions were asked, each corresponding to a Forest Practices rule applicable to non-forested wetland management. At some visits, only a small number of questions were applicable to the harvest, so the number of rules examined at each site visit varied.
CMP examined a total of 100 rules applicable to non-forested wetlands for the 2020-2021 analysis, finding that out of all the rules examined, 88 were found to be compliant with the Forest Practices Rules, and 12 had deviations from the rules.
There are often situations during field data collection when only some, but not all, of the rules will apply to a prescription. For example, there are rules dictating a required buffer in which harvest is not allowed around certain types of non-forested wetlands. Further wetland rules dictate that depending on their size and type, a certain number of trees must be left within the Wetland Management Zone (WMZ).
During field reviews, the Compliance Monitoring Program evaluates whether there was or was not harvest in this WMZ, and if not, all rules around how many trees are required to be left around the wetland are skipped. If harvest was performed in the WMZ, then rules surrounding how many trees per acre are left will be addressed.
Due to these situations, sometimes the total number of rules assessed per prescription will not be the same for different site visits. This is why the use of the total rules assessed across all site visits is very important to ensuring that our statistical analysis is representative of what was actually assessed in the field.
Preliminary 2020-2021 Results
Each biennium, the Compliance Monitoring Program puts out a lengthy and detailed report outlining the results of the previous two years of data collection and analysis. A short summary of the results from the most recent biennium (2020-2021) are presented below. To access the full report, visit the CMP website after August 10th, 2022.
A total of 189 field visits were performed during the two-year data collection period of 2020-2021. The unique field visits performed to assess each prescription are shown in the table at the left.
The number of field visits for each prescription varied from 13 to 39, based on sample selection (as described in a previous section of the story map). The total estimated population of each prescription varied from 68 to 2,790. Haul routes are not part of the standard prescription, but instead describe roads surveyed for sediment delivery during the spring sampling season.
The graphic at the left shows the number of rules assessed in total for each prescription (across the state). The orange represents the number of rules found to be compliant, and the blue represents the rules found with deviations.
DFC1 prescription field reviews found a total of 9 deviations, which were due to (1) lack of adequate shade documentation , (2) lack of correct number of outer zone leave trees, and (3) diameter requirements of inner zone leave trees not met.
Np prescription field reviews found 6 deviations due to harvest within the 50-foot no-cut buffer.
All deviations and descriptions can be found in the 2020-2021 CMP Biennium Report available after August 10th, 2022. Indeterminate findings are not displayed in the figure at left, but are described in detail in the report.
Haul routes are not displayed here as they are assessed per mile; for 2020-21, 76.2 miles out of 77.4 miles of haul routes were found to be compliant, resulting in a 98.4% compliance rate.
The highest number of deviations was found in non-forested wetlands (type A & B wetlands), with a majority of those deviations coming from underclassification (or mistyping) of wetlands, in some cases associated with fish water. In all, eight wetlands, 3 type B wetlands and 5 type A wetlands, were determined to be associated with fish waters.
Wetlands that are "inundated and associated" with fish water may at first glance seem like non-forested wetlands, but in reality are used by fish at some time during the year. This usage by fish means that inundated and associated wetlands need to be protected as though they are fish water, resulting in higher resource protection than a standard non-forested wetland.
WAC rule ( WAC 222-30-020(8) ) dictates that when a wetland management zone and a riparian management zone overlap, “the requirement which best protects public resources shall apply.”
It is the recommendation by the Compliance Monitoring Program that Forest Practices as a whole provide further training for landowners, foresters, region staff, and division staff on how to identify and protect inundated and associated wetlands across the state.
As part of the analysis of the most recent two years of data, the Compliance Monitoring Program also looks at how the past two years of results fit into the trends found over the most recent ten years of Compliance Monitoring data collection.
Between 2010 and 2021, compliance rates increased in Western Washington riparian management zone DFC1 and DFC2 prescriptions, and for statewide NIZH prescriptions, with estimated average increases in compliance rates from 0.6% to 0.8% per year.
No statistically significant trends (upward or downward) were observed for Ns streams, Np streams, non-forested or forested wetlands, and roads. An in-depth look at trend analysis is available in the 2020-2021 CMP Biennium Report .
Overall, compliance rates for a majority of prescriptions sampled during the 2020-21 biennium were above 90% statewide. The only exception being non-forested wetlands, which was still relatively high at 88% compliance. This means that in a majority of cases, Forest Practices rules are being followed correctly for all prescriptions, and resource protections are being applied adequately in Washington state.
CMP staff get to visit all parts of the state, passing through some of the most beautiful landscape Washington has to offer. Pictures from field visits, 2022.
Some samples assessed by the Compliance Monitoring Program are only reviewed once during the biennium, with sampling and data collection conducted every other year. These samples are sometimes referred to as periodic samples in the program. During the 2020-2021 data collection biennium, the periodic sample performed was for unstable slopes - a prescription which examines whether mitigation efforts were performed for potentially unstable landforms and assesses whether these efforts were carried out in accordance with the proposed efforts approved on the FPA.
Landowners are required to note unstable landforms such as inner gorges, convergent headwalls, bedrock hollows, toes of deep-seated landslides, and more on their FPAs. The Compliance Monitoring Program team conducting field visits consisted of CMP staff, landowners, Forest Practices Foresters and Forest Regulation Science Team staff (including a licensed engineering geologist).
For the 2020-21 biennium, a total of 25 field visits were conducted for unstable slope study. A total of 75 rules were evaluated, with 72 found compliant and 3 deviations, resulting in a compliance percentage of 96%.
Deviations were due to (1) a potentially unstable area not identified on the FPA, (2) a toe of a deep-seated landslide not identified on the FPA, and (3) an area where four boundary trees along an inner gorge had their roots cut, resulting in destabilization of the slope from loss of root strength.
CMP field reviews often result in beautiful views, interesting creatures, and sometimes a delicious treat. Pictures from field visits, 2022.
In many situations, calls cannot be made by the CMP team in the field. This may be due to a lack of information, safety issues accessing an area of the field site, or a lack of clarity around the Forest Practices rules for that prescription or rule interpretation. In these situations, CMP team members can make an 'indeterminate' call, meaning that no compliance or deviation rating could be made accurately at the time of review.
Sometimes these situations can be solved with input from other experts in the Forest Regulation Division or Forest Regulation Operations Team, while some situations may be used to advocate for more training or changes to the FP rules or WAC guidance. Regardless of the outcome, a description of the situation leading to an indeterminate call is always recorded and reported in the biennium report. To read about indeterminate calls made during the 2020-21 field season, please check out the 2020-2021 CMP Biennium Report , available online after August 10th, 2022.
Learn More
The Compliance Monitoring Program serves as a tool for understanding the rate of compliance of forest practices activities in our Washington forests with the Forest Practices rules and Washington Administrative Code. We explore trends and compliance rates with small and large forest landowners in every region of the state, working closely with Tribal Nations, DNR, Department of Fish and Wildlife, and Department of Ecology staff.
To learn more about our program, visit our webpage or send us an email. Thank you for taking the time to learn more about Compliance Monitoring of Forest Practices in the Washington Department of Natural Resources.
