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<br />002970 <br /> <br />Experience has shown that successful implementation of the watershed approach. <br />involving numerous stakeholders to reach consensus on measures, has greater up-front <br />cost and time constraints when compared to the typical command and control regulatory <br />management model. However, we believe the cost is justified because the watershed <br />approach will yield an overall higher level of citizen commitment, therefore, resulting in <br />more effective TMDLs and water quality improvement, If the TMDL program is to be an <br />effective means of ensuring clean water. it needs to include local panicipation and buy-in, <br />A voluntary incentive-based program. in conjunction with any state specific approaches. <br />and strong commitments to improving water quality will ensure that the program is an <br />effective management method. <br /> <br />4. DATA ACQUISITION AND MANAGEMENT - State implementation of the <br />watershed approach for addressing TMDLs will require a significant increase in the data <br />gathering, analysis, modeling and time required to address the variety ofTMDL issues. A <br />high level of local stakeholder involvement and confidence in the overall data <br />management (including monitoring of the results of implementation) will be essential for <br />successful implementation. <br /> <br />EP A can playa significant role in supponing TMDL implementation by: I) increasing <br />funding suppon and technical assistance to the states for data acquisition, management <br />and modeling, and 2) serving as a TMDL 'library' for states to rapidly share innovations. <br /> <br />5. FEDERAL PROGRAM COORDINATION - Many of the states in the West have <br />significant ponions of their land managed by federal agencies (Nevada is 90% federal <br />land. Utah 70%, etc.), Successful TMDL implementation by the states will require the <br />development and implementation ofpannerships,with a number of federal agencies <br />(Bureau of Land Management, Forest Service, Bureau of RecJamation. National Park <br />Service. Defense Depanment, etc.). In addition. the relationship between activities under <br />federal land management programs such as the Endangered Species Act (listing and <br />recovery actions) and the Clean Water Act must be addressed through a facilitated <br />process with significant input from the states. <br /> <br />On private land, the Natural Resource Conservation Service (NRCS) can have a key role <br />in planning and implementation as a result of their unique relationships with local Soil <br />and Water Conservation Districts and the agricultural community. NRCS also <br />administers or provides assistance on a number of water quality related programs. Each <br />of these programs can provide substantial assistance to private landowners in performing <br />appropriate projects and measures on private land. <br /> <br />The federal agencies must become committed panners with the states, and coordinate, <br />and/or provide resources to assist states with data management and monitoring and <br />implementation ofTMDL plans including best management practices and other actions to <br />achieve an approvable TMDL. State TMDL priorities and program guidance must be <br />followed by the federal agencies. Funding to the federal agencies must also be provided <br />by the President and Congress so that the agencies will have the resources necessary to be <br />active panicipants with the states, <br />