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However, these efforts should be closely coordinated with on-going USD A and state 

 Extension Service programs. 



• Congress and Executive Department agencies should strive to enhance state-level 

 programs rather than building duplicative and even competitive federal programs. 

 State Extension Services and Experiment Stations in most states are recognized and 

 accepted in the agricultural community as the primary technical agencies to provide 

 producers with guidelines, based on research findings, about agricultural production 

 and control of agriculmral pollution, particularly from nutrients and pesticides. Better 

 funding for those programs to allow expansion would be much more effective and 

 efficient than building an alternative bureaucracy. 



• Funding for programs dealing with level I and level 11 watersheds should be primarily 

 through USD A with a focus on building state-level instead of federal programs. 

 Funding through ES-USDA to State Extension Services could be used to build basic 

 educational programs for all watersheds. Identification of level n and level III 

 watersheds would provide a rationale and focus for urgeting of priority efforts of all 

 agencies. Significant funding for level III watershed efforts should be through both 

 EPA and USD A. 



• Funding for these programs should be distributed using a balanced approach. In each 

 state 50 percent of the funds should be directed to a base program with those funds 

 determined by the size or acreage of the state. The other 50 percent should be 

 distributed on the basis of need determined by the extent of water quality problems. 



Recommended Changes for Section 319 Program 



• Section 319 program limitations in some EPA Regions could be corrected to some 

 extent by setting of appropriate allowable expenses that may be deducted for 

 administrative purposes and by setting-up new mechanisms for transferring funds from 

 the management agencies to the action agencies directly involved in practice 

 implementation. In addition, eligibility requirements for projects funded under Sec. 

 319 should be reviewed. New approaches to stimulate appropriate practice evaluation 

 and implementation should be developed for Sec. 319 along with careful targeting to 

 level III priority areas. Sec. 319 funds could be allocated on a percentage basis based 

 on the relative contributions of those sources to the State NPS problem. 



• A complete re-evaluation is needed of Sec. 319 management and assessment programs 

 and especially identified problem watersheds or "nonattaining" stream segments. The 

 state-level coordinating committee could conduct such an overview and facilitate 

 needed changes. No watershed should be listed as a problem in the Sec. 319 list 

 without adequate monitoring data for characterization and source identification. In 

 addition, BMPs should not be listed as such without adequate supporting data. 



• EPA should have an outside critical review of program administration under Sec. 319 

 to identify factors that facilitate its success in some states, or which hamper it in others. 



March 23. 1994 



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