33 



So we let these folks then take over and develop plans, provide 

 technical assistance, provide cost-sharing, as they typically have 

 done. As long as a person is in that process and is making progress 

 according to the conservation agency, he is not subject to regu- 

 latory authority. But if he refuses to start developing plans, or if 

 he starts to develop a plan and quits, or says basically he is not 

 going to change his operation to come into compliance, then that 

 conservation agency has the obligation to turn him over to the 

 State regulatory agency. Then he gets into that really tough gorilla 

 of administrative law processes. 



We call this planned intervention. We think that this process will 

 probably take 12 years before we should begin to start trying to 

 regulate water quality criteria. 



Mr. Johnson. Thank you. 



Dr. Nipp, you mentioned the need for multiagency cooperation in 

 evaluating watershed and nonpoint source programs. How does the 

 expansion of involvement in these issues balance with the need to 

 streamline compliance plans for producers on the ground? That is, 

 can we have multiagency participation while at the same time have 

 the kind of coordination and one stop shopping, if you will, that our 

 producers demand? 



Mr. NiPP. An extremely good question. Ideally, the kind of inter- 

 agency cooperation that we would be advocating would result in 

 the agencies comparing notes amongst themselves as to what the 

 requirements are that they would ask of producers, so that in the 

 end you could create one stop shopping. The model that was pro- 

 posed last year in H.R. 1440 certainly provides a vehicle for accom- 

 plishing that by giving SCS the lead in developing those farm man- 

 agement plans or working with farmers to accomplish that. The 

 question that will be put to SCS and the challenge that will be put 

 to that legislation is whether or not those plans adequately address 

 the environmental protection requirements of other pieces of legis- 

 lation such as the Coastal Zone Management Act of other EPA pro- 

 grams and of programs that are underway in Interior. 



And so when we argue for interagency cooperation, we would 

 argue that these different agencies, with their different require- 

 ments and different paperwork requirements, would reach agree- 

 ment before they go to the farmer and put this burden of multiple 

 compliance upon him or her. 



Mr. Johnson. Dr. Leitch, I think you have excellent testimony 

 about the definitional difficulties that we have in this area. They 

 do certainly exist. But apart from some who would say that wet- 

 lands, whatever they are, have an inherent value, there is substan- 

 tial evidence it would seem to point to the fact that certain kinds 

 of wetlands in any event have substantial pollution impacts, con- 

 tribute to environmental diversity, and are otherwise valuable to 

 society at large. Given the rate of loss of wetlands that this country 

 has seen over the last number of years, is it not important that we 

 work with a working definition, as best as we can arrive at, of wet- 

 lands for now rather than waiting for the perfect final definition of 

 wetlands? 



Mr. Leitch. Mr. Chairman, I wasn't suggesting that we push 

 some environmental pause button and wait until we had the per- 

 fect definition. Certainly, there are wetlands that are extremely 



