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while providing for a farm management plan that sustains or enhances the efTiciency, productivity, and 

 economic profitability of the farm enterprise. 



Scientific uncertainty exists when relating agricultural practices to their effects on raw water compliance 

 with drinking water standards. Drinking water standards for raw water at its source covering some of 

 the agricultural contaminants of concern are not defined. Therefore, as a general rule, Whole Farm Plans 

 should call for the design, installation, management, and maintenance of any combination of BMPs 

 necessary to limit the release of nutrients, organic matter, domestic animal-borne pathogens, toxic 

 chemicals, and soil to any surfiace or ground water body, consistent with applicable state and federal laws 

 and regulations, as well as with the water quality goals established for the watershed. In those cases 

 where it can be shown that an activity on a specific farm leads to an actual violation of a legally adopted 

 water quality standard, the farm shall be required to alter the activity to the extent necessary to meet the 

 water quality standards. 



While it may be possible to achieve zero discharge of some contaminants during some periods (i.e., 

 avoiding winter land application of manure or relying wholly on biocontrols or cultural practices to control 

 some pests) universal attairunent of zero discharge for all agricultural contaminants at their source is not 

 practically achievable. 



BMP Implementation — The implementation of Whole Farm Plans may be viewed as a two-level process. 

 First, the "installation" of physical strucrares prescribed by the farm plan will need to be arranged. These 

 structures may include grass waterways, manure storage facilities, barnyard improvements, diversions, 

 etc. Engineering expertise is needed from the design through final certification of construction. 

 Engineering technical assistance needed includes: gathering of site-specific data on soil type, drainage 

 characteristics, and topography; preparing construction drawings, specifications, and contract documents; 

 reviewing design with the landowner; assisting the landowner in securing a contractor; surveying and 

 staking out the project site; inspecting ongoing installations/constructions; and certifying that projects meet 

 contract standards. 



The second level of implementing Whole Farm Plans requires the integration of a farm's physical, human, 

 and time resources so that prescribed changes can be incorporated into the operational routine of the farm. 

 This level of implementation involves an array of educational activities targeted at changing perceptions, 

 attitudes, practices, and beliefs of farm managers. 



Summary of New York Watershed Program — Additionally, in New York we have taken a similar 

 approach to our statewide non-point source program. In accordance with guidance provided by state 

 agencies, individual counties have formed County Water Quality Coordinating committees, which in turn 

 have developed County Water Quality Strategies. These strategies identify water quality problems and 

 outline programs to address these problems. The strategies focus on the use of education and technical 

 assistance to prevent and remediate water quality issues at the local level. Because these programs and 

 actions originate at the local level, the opportunity for success is greatly enhanced. When citizens have 

 ownership of solutions to problems, action occurs and progress follows. The farm community has 

 responded positively on this issue, as they have in the past, to programs which recognize their needs while 

 pursuing water quality objectives. 



While we are still in Phase I of the process and much has yet to be accomplished to prove that the process 

 ultimately works, I believe this farm-by-farm approach is tentatively accepted by the farm community in 

 the watershed as a much preferred alternative to a traditional top-down, standard-setting, enforcement, 

 penalty system of regulation. In fact, I am persuaded that the latter approach cannot be made to work 

 for farms, each of which is somewhat difference from the other. 



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