States will need to devote sufficient resources to the TMDL development process in order to provide scientifically adequate input parameters and robust stakeholder involvement in the entire process. The TMDL program fail if environmental extremists are permitted to highjack the process to their agenda of Federal watershed zoning. The proposed regulations unlawfully allow EPA to designate nonpoint sources as point sources. They propose to regulate nonpoint sources, private forestry and livestock activities for such practices as harvesting, site-preparation, road construction, thinning, prescribed burning, pest and fire control, land application of organic nutrients, and nutrient utilization plans, by requiring landowners to obtain point source discharge permits for these land use activities. This proposed action is an unjustifiable expansion of the EPA's authority, constitutes significant federal intrusion into private activities, and overrides state arid private control of land-use decisions.
Agriculture is willing to be a part of reasonable and lawful water quality management programs.
The provisions set forth in S.B. 2417 represents a reasoned approach to developing a program that meets the concerns expressed above Accurate data upon which difficult rulemaking is based, additional resources for states address their rightful responsibilities, and a critical review of this complicated and confusing issue are all called for in the bill and are needed to assure landowners of fair and equitable regulatory action Additional time is needed to evaluate and, possibly rethink the TMDL concept It is more important to At the rules done right than to At them done quickly. Over the decades farm and ranch families have achieved extraordinary conservation gains through voluntary, incentive based programs to conserve fragile soils, wetlands, protect water quality and wildlife habitats. The nonpoint source issues outlined in EPA's TMDL proposal are best addressed through incentive-driven programs, implemented by those with the most interest in the environmental quality of America's land and water resources. That is, the people who own and work with those resources on a daily basis-America's fainters and ranchers. We applaud your efforts in developing S. B. 2411 as we do others in the Congress who have offered legislative remedies to the TMDL problem.