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additional trigger levels could also be developed, some of which could be based on 

 "ecosystem indicators". There needs to be interaction between the states, USDA and 

 EPA to identify and develop appropriate trigger levels. 



• Monitoring data would be critical to the program, including agreements on the number 

 of samples to be taken over what time period to provide definitive data to establish 

 contaminant levels. Additional characterization for watershed areas could include data 

 on contaminant level trends and potentials for pollution to occur such as any significant 

 changes in agrichemical use, increased size or number of confined animal feeding 

 operations in relation to land and soil capabilities and climate, or other pertinent data. 



• Committees or commissions should be established at the state and local levels of all 

 agencies, including representation from Land-Grant Universities involved in 

 agricultural pollution prevention programs to facilitate coordination. In addition, 

 technical committees could be established to assist with development of 

 recommendations regarding criteria to define contamination levels, monitoring 

 procedures, best management practices, trend analysis and related program guidance 

 and coordination needs. 



• Provisions should be made to periodically reassess the classification of watersheds to 

 provide for upgrading or downgrading as appropriate. 



• An expanded program of water quality monitoring and source assessment must be 

 implemented to properly define problems and permit accurate targeting of efforts. 



• Federal agencies should coordinate monitoring efforts and establish agreed upon 

 criteria for monitoring data needed to determine levels of contamination. Partnerships 

 between EPA, USDA, and USDI are crucial for maximizing cost effectiveness and 

 avoiding unnecessary duplication or incompatibility of data sets. Efforts coordinated at 

 the federal level will also help meet the needs in states where state agencies do not have 

 the resources to handle monitoring that is necessary. One lead agency in each state 

 could coordinate state monitoring efforts to ensure that the appropriate necessary data 



is being gathered. 



• Monitoring by volunteer groups may provide useful data and indications of water 

 quality; however, state and federal agencies should provide adequate assistance in the 

 design of these programs, as well as insure that there is adequate training and oversight 

 in the programs if the data is to be used for state and federal decisionmaking. Federal 

 agencies should work together to develop broad guidelines for volunteer monitoring. 

 The lead state agency for monitoring in each state would develop specific criteria and 

 training for volunteer monitoring under the federal guidelines and outline how 

 volunteer data would be incorporated with federal and other states' data. 



• State regulatory agencies and EPA, in consultation with interagency teams consisting of 

 members from both non-regulatory and regulatory agencies, should be responsible for 

 setting-up and conducting enforcement activities associated with level III watersheds. 



March 23, 1994 



