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state resources are going to continue to be severely constrained in the future, states should 

 have the prerogative to target what resources are available towards state-determined 

 priorities. To ensure effective and productive programs, states need to be accountable but 

 retain flexibility to meet the unique circumstances and needs of their states if they are to 

 continue to meet the objectives of water quality. This is accountability with flexibility. 



The Senate, Mineta and Oberstar bills all direct the Environmental Protection Agency to 

 develop management measure guidance for new and existing sources of non-point source 

 pollution. NASF does not oppose this direction to EPA. In fact, state forestry personnel 

 participated in the development of Non-Point Source Management Measure Guidance for 

 silvicultural actives in coastal areas. However, we think it necessary and critical to rec- 

 ognize £ind appropriately limit the authorities that are granted to EPA for setting and di- 

 recting National policies and practices. 



Following are several final points and recommendations we would leave with the commit- 

 tee on non-point source pollution. We know what we need to do to prevent and reduce non- 

 point source pollution that results from forestry activities and we are doing it ~ despite 

 severely limited resources. If assistance for addressing non point source problems were to 

 increase five-fold it would still not come to forestry because we are not a major problem. 

 The approaches of S. 1114, H.R. 3948 and H.R. 2543 add artificial and unneeded defini- 

 tions and categories that will seriously hamper and restrict the ability to effectively and ef- 

 ficiently address non-point pollution at the state and local levels. These approaches will 

 also " inadvertently - stretch and reallocate limited resources to areas of lesser priority 

 that are still going to be addressed. With these comments, NASF offers the following rec- 

 ommendations that we hope the committee will consider actively pursuing in the best inter- 

 est of achieving water quality goals for the Nation. 



Recommendations for Non-Point Source Pollution legislation: 



• Continue to utilize existing categories of non-point source pwUution identified 

 by Congress in 1972. Federal legislation and federal administrative agencies 

 should not create or develop new labels; to do so would add confusion and com- 

 plexity. Remove references to 'new' and 'existing* non-point sources. 



• NASF supports provisions of HJl. 3948 that recognize comparable state and lo- 

 cal programs (Sec. 321, (c)). 



• NASF suppmrts provisions in HJl. 3948 that require the EPA Administrator to 

 consult with appropriate Federal and State departments and agencies, and pub- 

 lish for public comment, guidance that identifies best management practices and 

 measures to be undertaken. Where forestry is concerned this should include ap- 

 propriate state and professional forestry representatives. 



• Where similar non-point source programs and responsible administrative 

 agencies overlap - e.g., coastal zone non-point source management programs - 

 authority to implement and manage non point sources at the state level should be 

 assigned to a sinyle agency within the state. 



• "Qualified" programs that are recognized as satisfying the requirement for 

 implementation of site specific management plans (i.e., Conservation Reserve, 

 Integrated Farm Management, Agriculture Water Quality Protection programs) 

 should include appropriate forestry programs. 



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