161 



for the states to establish mandatory polluted runoff prevention 

 programs for waters that are impaired (or threatened) by polluted 

 runoff. This approach is ecologically and fiscally sound because it 

 targets the highest priority on restoring waters and watersheds that 

 need the most attention. Under all four proposals, the major 

 requirement of the state programs would be to steadily reduce 

 polluted runoff from existing sources over a reasonable time period 

 until water quality standards have been achieved. The sound, 

 fundamental concept is for EPA to require states to achieve 

 mandatory water quality results (i.e., meeting water quality 

 standards and designated uses), while allowing states and 

 landowners who have existing polluted runoff sources broad 

 flexibility on the means to achieve these results. 



The major difference between the proposals pertains to the number 

 and type of options that EPA would allow the states and landowners 

 to choose to achieve water quality goals. The Senate, 

 Mineta/Boehlert bill, and Administration proposal would allow the 

 states and landowners to choose to implement 1) management 

 measures developed by EPA (probably patterned closely after the 

 CZARA nonpoint guidance), 2) site level plans developed by the 

 landowner, or 3) a state-developed option that would have to be as 

 effective as the EPA management measures. 



Conversely, the Oberstar bill would require states and landowners to 

 use only site level plans developed by the landowner (with technical 

 assistance from USDA and the state). Although the site level plans 

 envisioned by the Oberstar bill would certainly be based on the EPA- 

 developed management measures, each plan could be tailored by the 

 landowner and the state to better fit the individual circumstances of 

 the site. 



We believe that the single, flexible site level plan option for existing 

 sources in the Oberstar bill is likely to be the most effective proposal 

 because it will ensure landowner involvement, allow site-specific 

 tailoring, yet will provide more understandable, more consistent 

 procedures for states and landowners to follow, as opposed to trying 

 to implement a patchwork of potentially diverse measures required 

 under the various options. 



Also, a major distinction between the proposals is that the 

 Mineta/Boehlert bill is the only proposal that requires the states to 

 implement mandatory, phased-in management measures for all' 



