Overseeing the trades is more difficult. The team agreed that states should set up and administer their own programs, but the Bay Program should have some oversight to ensure consistency among states. Trades, the team agreed, needed to be governed through permits or a regulatory program. States would have to take on new responsibilities such as certifying the eligibility of participants. For point sources, which have discharge permits, that is straightforward.
Monitoring is in place to make sure reductions take place.
The effectiveness of streamside buffers, changes in cultivation practices, grass waterways or other activities varies from place to place depending on soil conditions, the slope of the land and other factors. The draft guidance document agrees that more monitoring will be needed, and the states will need to inspect nonpoint runoff control practices to make sure they are maintained. But the details of just how much additional work is needed are left up to the states. Don Robinson, district manager of the Lancaster County Conservation District in Pennsylvania, said that if the program becomes too prescriptive, farmers won't participate. That doesn't mean they are trying to deceive the public.