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<br /> <br />The large and growing number of sizeable confined <br />animal-feeding operations represents an <br />ever-increasing threat to surface water and <br />groundwater quality. Under the Clean Water Act, <br />most such feedlots are point sources in the technical <br />sense only, but they are generally treated as exempt <br />from regulation in the practical sense. Clean Water <br />Act authorities should be applied to require that all <br />confined animal feeding operations operate under <br />the National Pollutant Discharge Elimination <br />System (NPDES). <br /> <br /> <br />Water in the West: The Challenge for the Next Century <br /> <br />Integrating Land and Water Quality <br />Management <br /> <br />The federal government is a substantial land and <br />water manager in the West and, therefore, has <br />important obligations in this area. The mission and <br />authority of each federal water and land <br />management agency-including the Corps of <br />Engineers, Bureau of Reclamation (Reclamation), <br />Forest Service, Bureau of Indian Affairs, Bureau of <br />Land Management, U.S. Fish and Wildlife Service, <br />and National Park Service-should explicitly include <br />land management goals and strategies to improve <br />water quality, particularly from nonpoint sources. <br />Federal agencies should be held to the same water <br />quality protection practices as others. <br /> <br />Specific Sources of Water Quality <br />Impairment <br /> <br />Discharges from publicly owned wastewater <br />treatment works that are utilized beyond their <br />capacity are a potential cause of water quality <br />impairment in specific western water bodies. The <br />states and EP A should carefully monitor the water <br />quality impacts of growth in the West and assure <br />that growth does not outstrip current and future <br />waste treatment capacity . <br /> <br />Among the most serious unregulated forms of water <br />pollution is that generated by irrigated agriculture <br />through irrigation and drainage districts. Irrigation <br />retum flows can, in certain situations, contain toxic <br />constituents as well as salts, pesticides, and <br />fertilizers. Some of these discharges are particularly <br />well-suited to be designated as "point sources," as <br />they often enter waterways through discrete and <br />specific points-pipes and ditches- after being <br />collected in carefully engineered systems. These <br />point source discharges were exempted by the <br />Congress from Clean Water Act requirements; that <br />exemption should be reconsidered. <br /> <br />Groundwater-Surface Water Linkage <br /> <br />Because of the hydrologic link between surface and <br />groundwater, the discharge of pollutants into <br />groundwater from a wide range of sources should be <br />subject to a rigorous system of management under <br />the Clean Water Act, such as the NPDES or the <br />nonpoint source best management practices <br />programs, or through watershed management <br />approaches. <br /> <br />Water Use and Water Quality Linkage <br /> <br />The Commission joins with many other voices in <br />noting that water quality and water use systems are <br />not integrated or effectively coordinated at the <br />federal, state, or local level. The relationships <br />between water use (water allocation and water <br />rights) decisions and water quality management <br />should be recognized at all levels of government <br />decisionmaking, while acknowledging that the <br />Congress determined that "the authority of each <br />state to allocate quantities of water within its <br />jurisdiction shall not be superseded, abrogated, or <br />otherwise impaired by this [Clean Water] Act." <br />Federal agencies with water management <br />responsibilities should recognize that storage and <br />diversions for water use can have a locally <br />siguificant adverse effect on instream water quality <br />in western states. <br /> <br />xxii <br />