States are developing and implementing their own programs. For example, in my own state of Kansas, we are implementing voluntary incentive-based practices as part of the Governor's Water Quality Initiative, and we have monitoring data which shows these practices are improving the water quality in the area. EPA's TMDL rule fails to give states the flexibility that is needed to build on our progress. Instead, EPA's TMDL proposals substantially rewrite implementation of the Clean Water Act with prescriptive requirements, short deadlines, new and additional layers of planning, implementation, and oversight. This is counterproductive.
States are on the forefront of addressing nonpoint water quality issues.
We know what the problems are, we know what programs will help. States don't need EPA trying to dictate and prescribe solutions. In Kansas, we have written and are implementing 120 TMDLs in the Kansas Lower Republican Basin. We will have more done in the Upper and Lower Arkansas River Basins, as well as the Cimarron Basin by mid-2000. Lack of flexibility in the TMDL rule will slow our progress and our efforts to improve water quality in Kansas.