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 site specific plans on agricultural lands - and not the EPA. In 

 addition, USDA and state programs which have already resulted in 

 the installation of best management practices, including 

 conservation compliance plans, must be credited before setting new 

 requirements for producers. 



(4) Agricultural producers are required to implement 

 additional BMP's every 5 years if water quality standards are not 

 achieved. Such a mandate would not allow adequate time for many 

 BMP's to yield measurable water quality benefits. In addition, 

 non-attainment is virtually assured if all waters must meet the 

 "drinkable" test, or if we misdiagnose the problem by failing to 

 consider natural background levels. This means that adoption of 

 additional practices and measures would be a never-ending round of 

 increasingly stringent requirements to come into compliance. 



(5) The bill should provide that deadlines for states and 

 agricultural producers be adjusted in the event of appropriations 

 shorfalls, to avoid the imposition of unfunded mandates. 



(6) Rigid antidegradation and other provisions will serve to 

 stifle economic development in rural America. 



(7) Expanded enforcement provisions of H.R. 3948 should not 

 apply to agricultural nonpoint sources. 



A more complete discussion of the CWWG's concerns with H.R. 

 3948 is contained in the attached letter to the chairman of the 

 Committee on Public Works and Transportation. Also attached to the 

 testimony is the Principles Statement of the CWWG with regard to 

 Clean Water Act amendments, which was developed last year. 



