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Before moving on to NASDA's overall position on CWA reauthorization, I would like to summarize the 

 important principles embodied in this approach to non-point pollution prevention that has been adopted 

 as the alternative to a uniform regulatory system for the farm sector of New York City's watershed. 



• The system for pursuing the City's water quality objectives, as they are affected by the agricultural 

 segment of the watershed community, was arrived at by negotiation and consensus — not by fiat. 



• The program is locally delivered and administered by an existing — not a new — group of 

 institutions with whom farmers are familiar; who understand farming science, methods and 

 techniques, and farm business operations; and whom fanners trust. 



• The responsible regulatory institution — in this case. New York City's Department of 

 Environmental Protection — has created contractual relationships with these locally based delivery 

 entities to serve its public policy objectives, and has established a collaborative mechanism with 

 the farm community generally to assure continued communication, momentum, and support. 



• The cost of both the farm planning process and the installation of practices called for by each plan 

 to achieve the pollution prevention goals of the responsible agency is financed by the responsible 

 agency — or, in any case, not by the farmer. Once the firont-end costs are overcome, these 

 improvements will benefit the economic operation of the farm. 



• The program is voluntary, but there is sufficient unchallengeable legal authority in the background, 

 coupled with a time tlireshold for a high rate of sign-up, to spur participation. 



• Improved and sustainable (unsubsidized) farm profitability, combined with 100 percent cost- 

 sharing for planning and the installation of water-quality-related capital improvements and 

 practices, creates strong incentives for farm participation. 



Wetlands Regulations 



Let me now turn to another area you, Mr. Chairman, asked me to address — wetlands regulations impact 

 on agricultural production. NASDA strongly believes that many of our nation's wetlands are highly 

 valuable resources that must be conserved and enhanced. At the same time, any federal program to 

 protect wetlands must also preserve private property rights and allow for a balance between economical 

 agricultural production and wetland conservation. 



The debate over federal wetlands policy has proven to be one of the most contentious and difficult issues 

 feeing Congress. Clearly, the federal government has a role in stemming the rate of wetlands loss and 

 encouraging restoration of areas that have been degraded by pollution or careless development activity. 

 The policy development process is complicated by the reality that 75 percent of the nation's wetlands 

 resource in the lower 48 states is privately owned and that much of that resource is located near large 

 population centers. 



Conserving and restoring the nation's wetlands will require an enormous commitment of privately owned 

 land, money and expertise. It cannot be accomplished without the involvement of the private sector, 

 particularly the people who own wetlands, in conservation and restoration activities. 



The need for wetlands regulatory reform cannot be dismissed. The federal regulatory wetlands program 

 in effect today under section 404 of the Clean Water Act is not the product of a carefully considered and 

 fully debated legislative policy. Current federal wetlands law is the result of 20 years of bureaucratic 



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