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I. Agriculture and Pesticides in the NPS Pollution Debate 



For twenty years, controlling toxics and water pollution has been 

 primarily an end-of-pipe strategy, and clean water for human health 

 reasons was a key driver. Many tens of billions of dollars were 

 spent restricting releases to the environment. It was a successful 

 effort - much progress has been made in water quality in America. 



Now the focus has turned to nonpoint sources of pollution, and 

 rightly or wrongly, agriculture is squarely in the spotlight. 

 "Toxic" has been redefined to include a range of effects caused by 

 clean soil sediment, nutrients and pesticide traces on various 

 species of the food chain. "Impairment" has been redefined to 

 include real and potential adverse impacts on water quality, 

 aquatic species, habitat and other factors. And "navigable waters" 

 has been redefined to include "ground" and "groundwater", as well 

 as many other waters no boat could ever navigate. 



Both the House and Senate reauthorization bills have attempted to 

 legislate nonpoint source pollution coming from agriculture and 

 other sources. Those of us in agriculture have expressed 

 significant concerns about these bills, for both HR 3948 and S 1114 

 would severely impact on agricultural producers, both existing and 

 new crop and livestock producers. Production costs would increase, 

 affecting what crops and production locations are economical, and 

 production technology would be forced to change, influencing 

 availability, quality and cost of food. Indeed, this 

 reauthorization could well be as important to the future of 

 agriculture as the Farm Bill, affecting present and future 

 agricultural policy and competitiveness. 



Today, expectations for environmental protection reach far beyond 

 agriculture's traditional aggressive commitment to soil and water 

 conservation. Many now speak of restoration and protection of 

 water resources at levels approaching pristine conditions as though 

 this could be accomplished easily, quickly and without significant 

 social and economic sacrifice. It is not clear that the current 

 situation justifies such a dramatic approach. 



As CWA reauthorization has turned to NPS and agriculture, language 

 has been introduced that gives us pause, for it would move farmers 

 into a regulated system of farming-by-permit by the end of the 

 century. Enforcement measures, penalties and citizen suits are not 

 part of the traditional concerns of producers facing the 

 uncertainties of the typical growing season. And concepts such as 

 integrated watershed planning, biodiversity protection, ecosystem 

 criteria and national management measures are new concepts which 

 everyone is struggling to understand, including ag producers. 

 Surely there are effective solutions to managing NPS runoff which 

 producers can enthusiastically support, solutions which take a more 

 individualized, performance-based approach. We need to carefully 

 consider which of these concepts are right for agriculture and how 

 they overlap with existing programs already being followed by 

 producers . 



