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BOARD00585
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Last modified
8/16/2009 2:52:08 PM
Creation date
10/4/2006 6:41:01 AM
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Board Meetings
Board Meeting Date
11/23/1998
Description
Federal "Clean Water Action Plan" and EPA's Advance Notice of Proposed Rule Making - Status Report
Board Meetings - Doc Type
Memo
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<br />to rural communities, EP A should strengthen the voluntary, incentive-based nature of <br />existing non-point source control programs such as those promoted under Section 319." <br /> <br />Again, there is substantial information available regarding how agricultural activities pollute our <br />nation's-and our state's-waterways, For starters, one need go no further than Colorado's <br />latest 305(b) report. Moreover, even the USDA has recognized the significant role that <br />agricultural runoff plays in polluting the nation's streams; it was for this reason that the agency <br />established the Environmental Quality Incentives Program, Therefore, TU recommends that <br />CWCB redraft this sentence as follows: <br /> <br />Without SlnJRg e'Aclenee that agriellltl;lralaetivities are eausing signifieant barriers to the <br />sl;leeessful implementation of the CW r. lliill In evaluating changes to the water quality <br />standards program that would impose new requirements on currently unregulated <br />agricultural activities, EPA should examine an evall;lation of the potential economic <br />impact to rural communities,~ In addition to, or in lieu of changes and additions to its <br />water quality standards program, EP A should also continue to explore ways to <br />strengthen the voluntary, incentive-based nature of existing non-point source control <br />programs such as those promoted under Section 319. <br /> <br />4. "EPA's interest in establishing new or broader organizations is causing concerns that EPA <br />seeks to influence the priorities or the balance of powers within or among existing <br />. . " <br />organizations. <br /> <br />There are varied regulatory and non-regulatory interests who have taken up the banner of <br />watershed councils, Solving Clean Water Act issues has been one of the many reasons that <br />federal, state and local interests have formed watershed councils in the last decade, The Board's <br />concern about proliferation of such councils is valid; however, the Board must recognize that <br />such councils have been and will remain a useful tool under the Clean Water Act, just as they are <br />for solving other problems, TU is surprised, given the Board's strong bias in favor oflocal and <br />state action, that the Board would object to EPA's proposal to make watershed councils a more <br />important forum for the resolution of Clean Water Act matters. TU recommends replacing this <br />sentence in its entirety as follows: <br /> <br />if. or to the extent EP A identifies the need to establish new watershed councils to enable <br />progress within the water quality standards program, EP A should ensure, consistent with the <br />principles of the Reinventing Govemmentlnitiative, that there is not a proliferation of local <br />organizations, requiring duplicative efforts by interested parties. <br /> <br />5, "EPA's ANPRM does not appear to recognize the Prior Appropriation Doctrine. ..." <br /> <br />TU believes that the language that the Board staff has suggested is unnecessarily hostile and <br />condescending here and recommends that the phrase "appear to recognize" be changed to <br />"mention," <br /> <br />6. "If flow criteria, for example, are developed without regard for the obvious dependence of <br />many existing communities on water storage and diversion facilities and the obvious effects <br /> <br />2 <br />
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