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Mineta/Boehlert bills, and the Administration's position do give 

 credit where credit is due. The Senate bill provides too broad of a 

 Section 319 exemption for those landowners participating in the CCP. 



5. Ensure that the new program is enforceable, contains 

 reasonable deadlines and progress milestones and is tied to 

 achieving water quality standards and designated uses and 

 other relevant water quality goals. Section 319 must be 

 amended to mandate EPA to require states to have available, and 

 utilize when noncompliance occurs, sufficient authority and 

 mechanisms to enforce the provisions of the new Section 319 

 program. EPA must review and decide whether or not to approve 

 states' polluted runoff programs, and enforce Section 319 in states 



that fail to implement the program properly. The Oberstar bill and 

 the Administration's bill contain these provisions. The Senate and 

 Mineta/Boehlert bill contain useful enforcement provisions, but fall 

 short on providing sufficient EPA backup of state enforement and on 

 EPA oversight of state implemetation of the Section 319 program. 



Further, to ensure that sufficient progress is being made by states 

 and landowners towards achieving water quality goals, Section 319 

 must be amended to provide reasonable milestones and deadlines for 

 states and landowners to reach those goals. Following EPA approval 

 of revised state polluted runoff programs, we believe that an 8-10 

 year deadline for achieving water quality goals is warranted. The 

 Oberstar and Senate bills contain such provisions, as does the 

 Administration's position. However, the Mineta/Boehlert bill fails to 

 make a tie between deadlines and achieving water quality goals, 

 thereby weakening the utility of that bill's entire Section 319 

 amendment provision. 



6. Protect polluted runoff-impaired groundwaters. 



In some areas of the nation, groundwater pollution is a significant 

 cause of polluted surface waters. Therefore, where states determine 

 that groundwater is impaired by polluted runoff sources, then stales 

 should be required to target these groundwaters and develop 

 measures to protect them under the polluted runoff provisions of a 

 revised Section 319 program. The Mineta/Boehlert bill includes such 

 provisions. The Senate bill has a similar provision, but allows the 

 states complete discretion regarding whether or not to target such 

 impaired groundwaters. The Oberstar bill does not contain any such 

 provision. 



