May 21, 2002
Ms. Linda M. Combs
Chief Financial Officer
U.S. Environmental Protection Agency
1300 Pennsylvania Avenue, N.W. (MC2710A)
Washington, D.C. 20460
Dear Ms. Combs:
The National Association of State Departments of Agriculture (NASDA), representing the commissioners, secretaries, and directors of the state departments of agriculture in the fifty states and four territories, is pleased to provide our comments on the Environmental Protection Agency's (EPA) FY2004 budget priorities and planning.
NASDA appreciates this opportunity to discuss EPA's planning and budget process, and believe such consultation will strengthen our state-federal working relationship. With this letter, we also respectfully request the opportunity for early participation in the next budget cycle. This will enable us to survey our members to better determine budget priorities, and identify trends, issues, and concerns that may affect environmental protection and the state agriculture department activities.
As you know, states are partners in the federal system of environmental protection. The state agriculture departments have long been the lead state agencies for implementing federal pesticide laws. However, the scope and range of out activities are rapidly expanding. For instance, major initiatives on water quality and the Total Maximum Daily Loads (TMDLs) program, Concentrated Animal Feeding Operations (CAFO) regulations, and endangered species protection all have a significant impact on agriculture activities and individual farm and ranch operations. Implementing these new regulatory activities will place tremendous demands on state budgets and resources in the technical, financial, education, and enforcement delivery system.
Generally, our top budget priority is adequate federal support for both delegated state programs (i.e. pesticide cooperative agreements) and specific environmental programs designed to assist agriculture (i.e. nonpoint source management). We are particularly concerned that new demands and requirements on states are continuing to grow; yet, federal environmental funding has declined or remained flat for almost a decade. NASDA believes the federal government should pay its fair share or reduce its mandates on the states.
Following are some of the specific areas where we believe increased funding is critical to advance our goals for environmental protection:
- Section 319 Nonpoint Source Management Program. NASDA has long believed that the 319 program has been severely underfunded. Under the 319 program, states receive funds to support a wide variety of activities to address nonpoint source water quality issues, including technical assistance, education, training, technology transfer, demonstration projects, and monitoring.
- Concentrated Animal Feeding Operations (CAFOs). Funding to support technical assistance, training and education for implementation of the agency's upcoming new CAFO regulations. EPA has estimated the proposed CAFO regulations will result in compliance costs to be $850 - $940 million per year. Assistance is needed by producers and states to plan and implement the conservation measures that will be required.
- Water Quality Data, Research, and Monitoring. Current information and statistics on water quality are lacking in completeness and are dated. More state and federal funding is needed in these areas to get more accurate, science-based data. This evolving base of knowledge can be used to provide technical and educational assistance to producers. From this knowledge, we also know which management practices and investments should be supported with financial assistance in the form of cost-share payments, loans, and grants.
- Watershed Restoration. EPA's FY03 budget proposes $21 million for a new program to fund and support improvement of targeted watershed projects. We believe such targeted resources should be expanded or targeted for some agricultural initiatives or pilot projects. NASDA has proposed a new "Agricultural Stewardship Program" funded by block grants to states to compensate producers for implementing conservation practices that enhance environmental goals. As EPA develops and implements the new watershed initiative, we suggest that funds be allocated for an agricultural stewardship program.
- State Pesticide Cooperative Agreements. NASDA's affiliate organization, the Association of American Pesticide Control Officials (AAPCO) has conducted funding surveys and previously conveyed to EPA the need for improved funding of state pesticide programs. NASDA endorses these recommendations. In particular, we emphasize the need for increased funding for certification and training programs for pesticide applicators, as well as public education efforts. These programs are essential to the safe use of pesticides.
Again, we appreciate this opportunity to provide input on the agency's budget and look forward to providing more in-depth recommendations during the next budget cycle. Finally, you may be interested to know that NASDA recently adopted a resolution recommending that EPA hold periodic meetings with the directors of the state agriculture departments to discuss agricultural environmental goals, policies, regulations, and budget issues. We believe such a dialogue would help us form an effective, successful working partnership with EPA that will significantly enhance our shared commitment to an agricultural production system which can coexist in harmony with the environment.
Sincerely,
<signed>
Richard W. Kirchhoff
Executive Vice President & CEO