144 



March 16. 1994 



The Honorable Norman Y Mineta, Chairman 

 Committee on Public Works and Transportation 

 U.S. House of Representatives--! 165 RHOB 

 Washington, DC 20515 



Dear Mr Chairman: 



The undersigned agricultural, agribusiness, and soil and water conservation organizations would 

 like to offer comments for the Committee's consideration as you prepare to deliberate H.R 3948, 

 "The Water Quality Act of 1994." 



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Our goal is to help craft policies which permit agricultural producers to seek intended water!, 

 quality benefits and remain profitable while doing so. Given limited resources in both agnculture 

 and government, environmental policies will be better served if government acts in parmership 

 with agricutlural producers instead of as a command-and-control regulator. 



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The attached review of H.R. 3948 briefly identifies concerns, questions and potentially beneficioi 

 features based upon these important considerations. In an effort to be responsive to indicatec 

 Committee deadlines, our comments at this point are necessarily preliminary. Major concern 

 identified to date include: 



(1) significant change in OVA goals. 



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(2) apparent, mandatory regulation of all agricultural producers, regardless of watt 

 quality levels; 



(3) emphasis on control and source reduction, rather than effective management, in EP/ 

 guidance for NPS pollutants without provisions for USDA input; 



(4) unclear, and potentially unworkable, time lines; 



(5) lack of scfeguurds against unfunded mandates; 



(6) failure to address wetlands reform and serious private property rights questions; and Hi 



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(7) possible threats to rural economic development. J| Pul 



We are continuing to work to gain a better understanding of H.R. 3948, in the hope that we mal Tlis 

 provide for the Committee's consideration more informed and complete recommende JIk 

 improvements in the near future to resolve these and other concerns. We stand ready to discus 

 the intended workings of the bill and elaborate upon our concerns. 



We would again urge that subcommittee markup be deferred until after the Easter recess so th 

 agriculture and other interested groups can provide constructive input on a more informed basi 

 We look forward to working with you in the coming weeks. 



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