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Policy Group represented agencies that are directly involved in issuing and administering the proposed 

 watershed regulations, groups that are affected by the regulations, and organizations that may contribute 

 to facilitating them. 



I have attached a copy of the Task Force final report with the Committee, so you may have the 

 opportunity to study its membership and the program scheme as it emerged from these negotiations. The 

 goal of the group was to fmd an alternative to a mandatory set of rules and regulations which would still 

 achieve the desired level of v^ter quality protection. Over the course of a year the Whole Farm 

 Planning/Best Management Practices approach for the New York City Watershed concept was developed 

 and evolved. 



Fanning in the New York City water supply watersheds presents a complicated environmental 

 management problem. Farming methods and practices are a potential source of nonpoint source pollution 

 and present a risk of pathogen introduction, siltation, toxics, and nutrients introduction to the City's 

 reservoirs. Farm practice pollution control is critical for meeting the City's anti-degradation objectives, 

 as well as the avoidance criteria of the Federal Surface Water Treatment Rule and the State Filtration 

 Rule. On the other hand, forming is a preferred land use as compared with more intensive uses like 

 second homes, which pose even greater threats to the City's drinking water quality, with significant long- 

 term environmental benefits, and the City wants to take all appropriate steps to keep farming economically 

 viable and in control of the land. 



A locally developed and administered program of best management practices, tailored farm by farm, with 

 the voluntary cooperation of the farm operator, would contribute far more to achieving the avoidance 

 criteria, as well as enhancing the viability of the farm enterprise and the agricultural economy. 

 Discussions in the Ad Hoc Task Force convinced members of the Task Force representing the City and 

 the farm community that the regulatory proposal took a purely water quality perspective and set absolute 

 technological standards for all farm practices, to be applied uniformly in all farm situations (uniform set- 

 backs from streams, berming pastures, control of all pesticide use, etc.). 



The City, after consulting with appropriate regulatory bodies and after full review of federal and state 

 regulations, was satisfied that such a program would meet the avoidance criteria for effective watershed 

 regulation, and represents the best strategy for dealing with concerns of both the City and the farm 

 community. 



Whole Farm PiannUig/Best Management Practice Program Option 



Guiding Principles — In place of the agricultural regulations, farmers have the option of participating in 

 a voluntary Whole Farm Planning/Best Management Practice Program. These are the guiding principles 

 for the program: 



• The objective of the program is to protect the sources of the New York City water supply, while 

 keeping farms in operation. Agriculture should be continued and promoted as a preferred land 

 use in the New York City watersheds. Except for a general prohibition to safeguard against 

 individual farm operators who exhibit a willful and irresponsible intent to pollute in a manner that 

 threatens to significantly increase pollution levels and degrades the source waters of the City's 

 water supply, the program will be entirely voluntary. 



• The preferred approach to source protection for farms is the use of Best Management Practices 

 (BMPs) developed to meet water pollution control policies under the 1989 NYS Nonpoint Source 

 Water Pollution Control Act and section 319 of the Federal Clean Water Act amendments of 1987. 



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