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incorporation in a state's coastal nonpoint program. The agricultural commodity organizations and USDA 

 helped provide the financial resources to develop the document. 



NASDA hopes to also host and facilitate a workshop, working with EPA, NOAA and leading experts in 

 nonpoint source pollution, on the CZARA requirements (focusing on the process document) to inform and 

 train state department of agriculture officials and enable them to contribute to the development of the 

 state's coastal nonpoint program. 



PE>a)iNG Legislation 



A number of bills have been introduced in the 103rd Congress dealing with nonpoint source pollution and 

 wetlands. While certain bills have been referred to the House Agriculture Committee, many other 

 measures are the jurisdiction of other Committees. Rather than attempting to address each piece of 

 legislation in detail, NASDA will review the areas that seem to appear in many of the bills. 



Funding & Timeframes — Most CWA bills pending before Congress provide basically provides 10 to 

 12 years and limited federal funds to manage NPS. The federal government has dedicated over 20 years 

 and a tremendous level of federal funding to control point source pollution. Congress should not expect 

 agriculture and other nonpoint sources to achieve the more complex pollution prevention in a relatively 

 short period of time with few federal dollars. Congress has not funded section 319 at levels necessary 

 to implement programs fully, and with the current budget atmosphere, there is no reason to believe that 

 additional appropriations are forthcoming. Authorizing bills can provide increased spending levels, but 

 the appropriations process tends not to fiilly fund these programs. When that occurs, the states are left 

 holding the bag. Unfunded federal mandates have put an economic strain on states which they can no 

 longer absorb. And when both the federal and state governments fail to provide the funding necessary, 

 it's the producer who suffers. 



Watershed Planning & Site Specific Plan — Many bills establish the concept of watershed-wide planning, 

 an approach which allows for targeting of scarce resources to impaired areas. This concept is a positive 

 approach as long as it encompasses site-specific planning similar to that outlined in H.R. 1440. 



Some of the pending legislation provides the flexibility and site-specific planning opportunities that have 

 proven workable in a number of areas, including the New York program explained above. The final 

 CWA product must stress the need for site-specific plans to remain flexible and be based on sound 

 technical and financial assistance. A mandatory hammer approach does not work because the agencies 

 cannot enforce them properly, and mandatory programs create an atmosphere of animosity rather than one 

 of cooperation. As you see with the New York experience, technical and financial assistance in a 

 cooperative fashion is successful, whereas mandatory hammers are not. 



Monitoring and State Reports — It is vital that an improved system for monitoring nonpoint source 

 pollution is developed. While it is appropriate to use current information in the immediate term, we must 

 do a better job of monitoring pollution contribution and improvement. Current section 305(b) reports do 

 not provide EPA with information in a standard form which allows for accurate reporting. Current 

 reports, which compare apples to oranges, are incomplete and inaccurate. Since many of the pending bills 

 increases the monitoring responsibilities of the states, and uses that information to determine future 

 requirements, the system must be improved and standardized so that the information is accurate and 

 useable by the states and EPA. 



The citizens monitoring provisions outlined in some bills should be completely deleted. Statutory 

 language is not necessary for the public to make comments to states about water quality. In times of 



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