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waters throughout the state, not just those that are impaired or 

 threatened. This is a certainly a useful provision which we support. 

 Unfortunately, other provisions (discussed below) of this bill ^' 



undercut this provision, substantially weakening its polluted runoff 

 provision. 



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2. Require polluted runoff programs to be watershed- 

 based. We support requiring states to use watersheds as 

 the basis for revised Section 319 programs. The Oberstar bill is the 

 only proposal that would make such a requirement. The other 

 proposals would give states flexibility to do less than full watershed 

 protection. 



None of the proposals define a watershed for the purpose of applying 

 the amended Section 319 program. All proposals give the states 

 flexibility to determine watershed definition. 



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3. Require Mandatory Runoff programs for new sources. 



An ounce of prevention is worth a pound of cure in terms of water 



quality as well as human health. Therefore, states should be 



required to ensure that all new sources of polluted runoff statewide 



should be required to implement either management measures or 



site level plans to prevent polluted runoff. This is a common sense rf 



requirement that will keep the nation's waters from further 



degradation. The Oberstar bill and Administration position contain Ok 



this requirement. The Senate bill does to a degree, but allows EPA 



and states broad discretion on the breadth of its application. 



Unfortunately, the Mineta/Boehlert bill has no such provision. 



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4. Give landowners credit towards their Section 319 

 requirements for achieving polluted runoff prevention 

 through participation in state and Farm Bill polluted runof 

 prevention programs. This element is critical to the successful 



meshing of a reformed Section 319, the Farm Bill programs, and 

 existing state programs. States should be required to determine the 

 pollutants and land areas that have been effectively covered by 

 management measures authorized or funded under the non-Section 

 319 programs. For example, where a landowner has farm fields 

 which are in compliance with Conservation Compliance Program, the 

 landowner should be given credit for preventing sediment runoff 

 from those lands, but would not necessarily be given credit for 

 controlling pesticide runoff from those lands. The Oberstar and 



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