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 availabe to individuals who are implementing new and costly 

 management practices. 



H.R. 3948 would authorize higher funding levels for both 319 

 programs and State Revolving Funds, and we support these important 

 provisions. But we have many concerns with the bill as introduced, 

 which include the following: 



(1) The CWA "goal line" for water quality is moved to 

 potentially unachievable levels by requiring that all waters, 

 including groundwater, be "drinkable", as well as fishable and 

 swimmable. 



(2) Best management practices for agricultural nonpoint 

 sources appear to be mandated in all areas, whether waters are 

 impaired or not. We believe that scarce resources and efforts 

 should be directed to the minority of waters which have been found 

 to be impaired. 



(3) State nonpoint source programs are inflexible and 

 required to conform to EPA Guidance, which emphasizes control and 

 source reduction, rather than effective management. The EPA 

 Guidance would likely resemble Guidance to States recently put into 

 place under Coastal Zone Act Reauthorization Amendments. The 

 Guidance limits the flexibility of States and landowners to respond 

 with local solutions. Landowners will be able to respond more 

 effectively by cooperating with USDA's Soil Conservation Service, 

 state and regional agencies and research institutions to implement 

 management systems which are appropriate to their specific 

 location. These agencies should provide technical guidance for 



