©1997 The National Association of State Departments of Agriculture
15th Street, N.W., Suite 1020, Washington, D.C. 20005, 202/296-9680
The following proposal presents a strategy for implementation of voluntary agricultural programs
-- such as voluntary agricultural Resource Management Plans (RMPs) -- as a means of addressing
impaired water segments under the Total Maximum Daily Load (TMDL) provisions of the Clean
Water Act (CWA). The policy explains the features and benefits of locally-led, voluntary, incentive-based programs to address nonpoint source concerns related to water quality.
The National Association of State Departments of Agriculture (NASDA)(1) strongly believes that
voluntary agricultural programs, like RMPs, provide an appropriate and effective option to
environmental mandates. States must have the flexibility to include voluntary approaches in their
water quality management plans to address the nonpoint source concerns in TMDL impaired areas.
Achieving Clean Water Through Voluntary Programs
The existence of programs at all levels of government to protect and enhance environmental quality
from potential degradation necessitates development of an effective coordination strategy to avoid
conflicts and duplication of efforts. Failure to recognize this need can lead to misuse of limited
resources, may result in conflicting programs, could increase the potential for environmental
problems, and will discourage the public's cooperation otherwise necessary to achieve success.
Policy relating to environmental quality must allow for the protection and enhancement of natural
resources; ensure a safe, adequate, and affordable food and fiber supply; and guarantee that these
objectives are achieved in a cost-effective, economical manner. The critical question which
policymakers are compelled to address is not what to achieve, but rather how to achieve it. As
stewards of the land and water, farmers and ranchers across this country strive to properly balance
environmental protection with their economic goals and objectives. It is the responsibility of
policymakers to recognize their insight when developing programs, education and training, and
financial assistance to accomplish water quality objectives.
There is a definite need to address potential agricultural nonpoint source pollution (NPS) which may
have adverse effects on natural resources and human health. The economic, environmental and
social importance of improving and protecting water sources is substantial. Communities place an
intrinsic value on having access to and utilizing clean water. It is a part of the quality of life of a
community and can directly affect growth and, consequently, the economic viability of an area. This
is particularly true if a body of water is used for recreational purposes, agricultural production or as
a source of drinking water. Quality water sources are one of the key components of a healthy, viable
environment. From streams and lakes that help sustain fish and wildlife, to streams that flow into
the nation's bays and estuaries, clean water is a critical requirement.
Agricultural operations, along with urban, construction, septic and natural sources, require a
comprehensive and coordinated management strategy, much of which is already in place (i.e., section
319 of the CWA), but in many cases inadequately funded. In order to reduce complex and diverse
NPS pollution, a commitment of time and resources is necessary, similar to the 20-year commitment
the country has made to reducing point source pollution. However, management of NPS pollution
will require a different approach than that of point source pollution because, unlike point source
pollution, NPS pollution is primarily a weather-related phenomenon that can be managed, but not
feasibly eliminated. NPS pollution is typically caused by the inadvertent discharge of pollutants
from nature or from a wide variety of society's most essential activities. While the added difficulty
in managing nonpoint sources creates a challenge, it is necessary to address its potential impacts
through programs which are voluntary and flexible in nature.
The CWA does not stand alone in protecting the nation's waters from NPS pollution. Other ongoing
programs at the federal, state and local levels must be adequately funded, and coordinated with, not
superseded by, the CWA. In particular, this includes the soil conservation and water quality
provisions of the 1985, 1990 and 1996 Farm Bills, the state groundwater and surface water
protection programs of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), and the
source water protection provisions of the Safe Drinking Water Act (SDWA). Furthermore, the CWA
must not directly or indirectly create a federal water quality law or program which supersedes,
abrogates or impairs state water allocation systems and water rights. Instead it should complement
and support these programs.
The central focus for NPS management solutions must be economically-feasible, voluntary, based
on sound science and supported by education, site-specific technical assistance and accurate
interpretation of available data. NPS pollution management programs should emphasize the
protection of water resources and state-designated water uses, including state-designated agricultural
uses, recognizing the importance and needs of individual agricultural producers and other
landowners affected by the CWA. This approach can emphasize the use of locally developed and
applied, economically feasible, site-specific RMPs which are designed by private landowners, and
which sustain rather than infringe on private property rights. (See Appendix A for description of
Resource Management Plans.)
Total Maximum Daily Loads (TMDLs)
Substantially improving and maintaining the quality of the nation's waters has been a priority of
federal, state and local governments since the early 1970s. While states, municipalities and water
suppliers are primarily responsible for protecting water quality, the federal government also plays
a significant role in water quality issues with the CWA and the SDWA being the cornerstones of
these efforts.
The original focus of the CWA was to restore and maintain the quality of the nation's waters by
achieving zero discharge of pollutants resulting in water quality that is "fishable and swimmable."
A 20-year commitment of time and resources has been spent trying to attain these goals, with the
vast majority of federal resources focused on the reduction of point source pollution into waterways.
Despite these efforts, there are still waters that do not meet state water quality standards. In some
cases, that may be due to inaccurate use standards developed by the state, thus suggesting the need
to reassess those particular standards. Maximum flexibility should be afforded the states to define
or redefine their uses. How a state uses its water should be the prerogative of each state so long as
fishable and swimmable uses are designated where attainable.
The TMDL Program -- As established by section 303(d) of the CWA, the TMDL program is
designed to identify sources of pollution, specify the amount of pollutant that may be reduced to
meet state water quality standards, and allocate pollution control responsibilities among pollution
sources in a watershed where water quality goals are yet to be achieved. Under the program, states
must develop lists of impaired waters that do not meet state water quality standards, even after point
sources of pollution have installed the minimum required levels of pollution control technology.
States must establish priority rankings for waters on the lists based on the severity of pollution and
uses to be made of the waterbodies, and develop TMDLs for waters on the lists.
A TMDL is a written, quantitative assessment of water quality problems and potential pollutant
sources. It potentially identifies water quality concerns, specifies needed reductions with a margin
of safety, has as its goal attainment of water quality standards, and sets the stage for action to restore
a waterbody. A TMDL calculates the maximum allowable pollutant loadings for a waterbody to
address water quality use standards. It equals the sum of the allowable wasteload allocations (for
point source contributions) plus the sum of the allowable load allocations (for nonpoint sources),
reserving capacity (margin of safety) for future growth.
The U.S. Environmental Protection Agency (EPA) has published regulations to implement section
303(d) of the CWA. Those regulations create a program which requires TMDLs for those waters
which technology-based controls or other required pollution controls are not stringent enough to
achieve water quality standards. The regulations require that states submit lists of waterbodies
needing TMDLs every two years, and require that states target those waters for which TMDLs will
be developed over the following two years. This is reflected in EPA's five-step TMDL approach:
1) identify waters requiring TMDLs; 2) prioritize ranking and targeting; 3) develop TMDLs; 4)
implement control actions; and 5) assess control actions.
The existing EPA guidance on the TMDL program encourages states to develop TMDLs for more
difficult problems, e.g., waters impacted by multiple point and nonpoint sources of pollution. It
further describes a phased approach to TMDL development when uncertainty is high, e.g., when
nonpoint sources are involved. The current phased approach requires reasonable assurance that
nonpoint source controls will achieve load reduction, additional data collection, and schedules for
installation and evaluation of controls.
EPA Policy on Nonpoint Source Contributions -- EPA's policy on the rate of TMDL development
and TMDL implementation has recently been released. The policy calls for states to develop
TMDLs on all listed waterbodies within an eight to 13-year timeframe. This new policy
memorandum for Establishing and Implementing Total Maximum Daily Loads also concentrates
heavily on TMDL activities in nonpoint source only segments. The new policy states:
For all section 303(d)-listed waters impaired solely or primarily by nonpoint sources, each
EPA region should work in partnership with each state to achieve TMDL load allocations
for nonpoint sources. All available federal, state, and local programs and authorities should
be used, including non-regulatory, regulatory, or incentive-based programs authorized by
federal, state, or local law.
For all section 303(d)-listed waters impaired solely or primarily by nonpoint sources, each
state should describe its plan for implementing load allocations for nonpoint sources. The
state implementation plan may describe how load allocations will be achieved by nonpoint
sources for individual waters, for several waters within a watershed, or for all affected
waters in the state. Through the Environmental Performance Partnership Agreement or
other similar process, each EPA region and state should agree upon the best strategy for
mutual support.
States may submit implementation plans to EPA as revision to state water quality
management plans, coupled with a proposed TMDL, or as part of an equivalent watershed
or geographic planning process. At a minimum, each state implementation plan should
include:
The policy memorandum further says that where a state does not develop a plan for achieving TMDL
load allocations for nonpoint sources, regional EPA officials are to engage the state, no later than
the beginning of fiscal 1999, in a constructive and focused discussion of needed actions by state and
federal environmental managers. If necessary, the memorandum directs the regions to take
additional steps to require a state to update its state water quality management plan; focus substantial
grant dollars toward those states that are providing reasonable assurance that nonpoint source load
allocations established by TMDLs will be achieved; initiate source-by-source reviews of the National
Pollutant Discharge Elimination System (NPDES) permits (including minors) in the watershed and
in upstream watersheds where the NPDES permit regulates the same pollutant covered by the TMDL
and further reductions at the point source will speed progress toward achieving water quality
standards; and deny or revoke a state's enhanced benefits standard under the new section 319
nonpoint source guidance and revert to a more intense, project-by-project oversight process on
annual section 319 grants.
For the most part, TMDLs are developed by state water quality agencies. In some states, a local
sponsor of the water quality improvement project could complete the TMDL (often expressed as
goals and/or objectives to meet the designated beneficial use) and submit for review and approval
to the state water quality agency. The water quality agency completes an internal review to assure
the TMDL will meet the water quality criteria and/or designated beneficial use and then allow for
public comment for the proposed TMDL. After completing the public participation process of the
review, the state water quality agency then submits the TMDL to EPA for final approval. EPA has
30 days to approve the TMDL and if not approved within 30 days, EPA is then required to establish
a TMDL for the impaired waterbody.
A general concern associated with the establishment of a TMDL for nonpoint sources of pollution
is related to the identification of sources and the lack of applicability of "daily" loadings. Since there
often are limited scientific data and/or scientific methods of monitoring that can indicate whether
an impairment can be associated with a nonpoint source, and nonpoint sources are not daily in their
nature, TMDLs will tend to be subjective. Some states are approaching this problem by developing
a "surrogate" TMDL. A "surrogate" TMDL utilizes measurements of second order phenomena,
often biological, to estimate pollutant loads. For example, a surrogate TMDL may be based on the
density of macroinvertebrates in a stream, the number of native tree species and their population
densities along a stream bank, the fish species diversity and reproductive status of the populations,
etc. While certain biological surrogates may provide a good indicator of the waterbody's overall
health, it is difficult to relate surrogate data to nonpoint source inputs or to project goals for
reduction in specific pollutants.
Legitimate scientific debate surrounds this "surrogate" approach. The decision on which second
order phenomena to measure and the design of the sampling schemes employed must be done
carefully in order to ensure the highest achievable confidence in the results which allow the TMDL
to withstand critical scrutiny. The establishment of a "surrogate" TMDL, based on insufficient
scientific data indicating a presence and cause of an impairment, or, in some cases, on economy of
data collection, can only be viewed as subjective and provide the potential for anyone to claim that
the TMDL is not being met.
The process of establishing TMDLs can only be realistically achieved with more intensive scientific
evaluation and monitoring of point sources at the local level. It is questionable how agencies will
establish reliable nonpoint source reduction goals under the TMDL process.
Obviously, simply establishing TMDLs does not, by itself, result in improved water quality. It is
imperative that the process of establishing TMDLs does not, in itself, create an ineffective approach,
or add another layer of control to the use of public and private lands, or reduce or remove multiple
uses of public and private lands. Nor should the TMDL process destroy or render less effective
current highly successful voluntary NPS programs.
TMDL Listing and Delisting Criteria
Section 303(d) of the CWA requires states to identify and prioritize "those waters within its
boundaries for which the effluent limitations required ... are not stringent enough to implement any
water quality standard applicable to such waters." The section further requires a state to "establish
a priority ranking for such waters, taking into account the severity of the pollution and the uses to
be made of such waters." It is important to maintain the quality of the nation's waters, and states
should work closely with the EPA to achieve the goals of the CWA. However, it must be understood
that a fundamental flaw with EPA's current TMDL approach is the notion that point and nonpoint
sources can be comprehensively combined and assessed with sufficient precision, frequency, and
economic efficiency.
Listing of Impaired Waterbodies -- EPA has improperly interpreted existing law under section
303(d)(1)(A) of the CWA to cover impaired water, regardless of the types of sources present,
including nonpoint source waters. A strong argument can, and has been made, that nonpoint source
waters are not covered under section 303(d)(1) but instead, are covered by section 303(d)(3). Section
303(d) of the CWA is limited to listing waters and the establishment of TMDLs to water where point
sources are present. Listings of waterbodies not attaining the state water quality standards for which
such waterbodies are classified can be accomplished by identifying them either under section
303(d)(1) or section 303(d)(3) of the CWA. Congress provided both sections for identifying
waterbodies affected by pollutants, and states should be given the flexibility to use both sections as
they see fit when identifying impaired segments.
Nonpoint source contributors listed on either list must be treated similarly, and the listing must not
affect funding allocations or participation under other voluntary programs. Whatever process is used
to identify nonpoint contributors, the use of voluntary best management practices (BMPs) and RMPs
under section 319 of the CWA must be the means of addressing all water quality concerns generated
from nonpoint sources. The same holds true for states who choose to create a single list of impaired
waterbodies under section 303(d).
Until Congress clarifies its intent that section 303(d) governs waters impaired only by point sources,
and not waters impacted by nonpoint sources, it is essential that EPA recognizes that voluntary
approaches, like RMPs, under section 319 will meet the needed and/or required water quality
standards. The language of section 303 of the CWA is silent on any mandatory regulatory control
of nonpoint sources of pollutants. The intent of the CWA is clear -- nonpoint sources of pollution
are not subject to mandatory regulations under the CWA, but are to be addressed through voluntary,
outcome-based programs. Congress should clarify that nonpoint sources are not subject to section
303(d) when it reauthorizes the CWA. If EPA continues to move forward in mandating the
establishment of TMDLs for nonpoint sources in hundreds of waterbodies affecting states throughout
the nation, there exists the potential to negatively impact the nature of nonpoint source pollution
prevention programs, possibly changing programs from voluntary to mandatory. The negative effect
of this regulatory transition to the citizens of this nation, natural resource industries, and the United
States competitive food and fiber production is staggering in political and economic terms. As the
goal of maintaining and improving the quality of the nation's water resources is sustained, it is
imperative that local, voluntary, incentive-based approaches are recognized and used for problem
resolution. Legislation has provided a clear and concise distinction between point and nonpoint
source management, and it is imperative that the TMDL program not require states to operate in any
different manner.
Identification of "Threatened" Waterbodies -- Lists created under section 303(d) should identify
only those waterbodies where degradation of water quality currently exists. Although some parties
consider it an appropriate use of section 303(d) to target waterbodies where impairment of water
quality could occur, this concept should be rejected because of its ambiguity and because of the
additional scientific uncertainties such an approach would add to the TMDL process.
Natural or Atmospheric Causes of Impairment -- There are waterbodies where natural conditions
render the water unsuitable for some uses. These waterbodies are impaired by naturally-occurring
constituents, such as sediment, total dissolved solids, and other elements. Degradation of these
waterbodies occurs regardless of human activities. Where natural conditions are deemed to cause
waters to fail to meet water quality standards, these waterbodies should not be listed under section
303(d), though this should not be taken as a license to allow additional human degradation.
Similarly, when waterbodies fail to meet water quality standards due to atmospheric deposition of
contaminants, the cause or causes of such widely-dispersed depositions should be addressed under
other appropriate federal or state statutes. These waterbodies should not appear on lists generated
by the states under section 303(d).
Impractical Application of TMDLs -- When waterbodies are identified as impaired and where
preparation of TMDLs will not result in significant or plausible improvement in the quality of such
waters, existing resources should not be devoted to addressing the problem. The preparation of
TMDLs should be conducted where and when reliable scientific evidence and economically efficient
management indicate the public can expect meaningful results to occur.
Waterbodies "Expected to Meet" Water Quality Standards --As states undergo revision or review
of section 303(d) lists, waterbodies identified as those "expected to meet" water quality standards
within the period for which such lists are created should not be listed. Resources dedicated to
improving water quality should be spent identifying and developing TMDLs for waterbodies where
water quality problems are unaddressed or unachieved.
Delisting of Impaired Waterbodies -- State and federal efforts under the CWA should be results-oriented. Consequently, when water quality improvement is achieved, those efforts should result in
the delisting of improved waterbodies. EPA and the states should remove any impediment to the
delisting of waters where water quality improvement occurs to record success, and to facilitate
directing scarce resources to where water quality problems remain. EPA's guidance and regulations
should also provide for a systematic approach to delisting waterbodies when listing occurs as a result
of erroneous data, BMPs have demonstrated the desired results, water quality standards are being
met, or where sound science demonstrates that listing of the waterbody is inappropriate.
Delisting should be permitted by EPA and the states at any point within the effective period for
which the section 303(d) list covers when any of the criteria enumerated above are met. States are
urged to adopt a process to periodically review 303(d) lists for appropriate listings. Also, the states
should provide for a process whereby, upon petition, specified waterbodies can be requested for
delisting by any party with an interest in doing so.
Economic Benefits and Other Incentives for Agricultural Producers
Financial Incentives -- EPA has indicated that there is a significant level of funding available for
TMDL programs in fiscal 1998 and beyond. States and local entities should be encouraged to apply
these funds where TMDL listings indicate agriculture is a potential source of concern. These funds
should be applied toward voluntary measures, like agricultural resource management planning and
implementation programs, to satisfy the objectives of water quality improvement. These funds
should be made available to soil and water conservation districts, other local entities, and agricultural
producers within an impaired segment to plan and implement improved management practices, in
some cases under an RMP, designed to protect and enhance water quality consistent with TMDL
goals.
Some have suggested that Farm Bill funding should be made available for practices in a TMDL
impaired area. While states and the U.S. Department of Agriculture (USDA) agencies should work
together to integrate their programs and water quality benefits where possible to enhance
effectiveness of voluntary programs, Farm Bill conservation program funding cannot be diverted
from the purpose of those programs, and cannot be seen as the sole source of funds available to assist
in the development and implementation of BMPs to meet water quality standards.
In addition to TMDL funds, local implementing organizations and agricultural producers may have
access to funding provided by related local, state and federal programs and private sources. For
example, the federal nonpoint source pollution control program provides grant funding, under
section 319(h) of the CWA, for farm or watershed-scale demonstrations of BMPs to control nonpoint
source pollution. Additionally, under the 1996 SDWA amendments, Congress provided the
opportunity to set aside a significant portion of the drinking water state revolving fund (DWSRF)
for source water protection programs. Congress authorized states to set aside up to 10 percent of the
DWSRF to assist them in developing and implementing source water protection programs, in which
the law specifically recognizes RMPs. In addition to the 10 percent set aside, Congress provided that
an additional 15 percent could be set aside for local assistance. Up to 10 percent of that 15 percent
can be used as loans for community water systems to implement voluntary, incentive-based source
water protection measures. Regional (e.g., water supply or management districts) or local (soil and
water conservation districts, county and municipal governments) public agencies also provide
funding for resource and pollution source management.
States should develop strategies which combine funding under CWA, SDWA and Farm Bill
programs with state and local sources, as well as private sources such as private utilities, local
conservation organizations and cooperating landowners. Private sources should be considered as
providing in-kind or non-federal matching funds required under certain CWA programs, to maximize
funding available. EPA and the states should provide maximum availability of funds to local
agencies and agricultural producers to develop and implement voluntary practices.
Compliance with Laws and Regulations -- Aside from the desire to foster good stewardship, an
important aspect of any voluntary program is the benefit derived by a participating agricultural
producer in terms of reduced burden associated with regulation and liability. Where an agricultural
producer participates in a voluntary program with demonstrated water quality benefits, the producer
should receive a measure of credit. Voluntary programs do or should offer some form of
presumption of compliance with the objectives of regulatory programs (e.g., water quality
standards),(2) appropriate relief from water-related permitting requirements, and/or reduced liability
associated with off-farm environmental degradation (e.g., from undefined sources). The so-called
"safe harbor" concept incorporates relief from regulation and enforcement for landowners where
acceptable management practices are put in place voluntarily. In many states, agricultural producers
may be able to accrue these additional benefits. The TMDL program should encourage states to
adopt these incentive measures.
Technical Assistance -- Agricultural producers who participate in voluntary programs should also
be eligible to receive quality technical assistance through local, state and federal program staff who
provide the needed expertise to assist in planning, designing, installing and monitoring BMPs.
Whether a plan is designed around one practice, a simple structure, or a very complex operation,
producers should have access to expertise and experience through voluntary programs not otherwise
available.
Public Perception -- Although agricultural producers are already good stewards within their
watersheds, participation in voluntary programs will promote a more positive public perception by
showing how agricultural producers are working to protect the water resources against
contamination, and how producers are sharing the responsibilities with other watershed sources in
responding to the TMDL process. Participation in voluntary programs will help the public
understand the benefits of agricultural land use in protecting water resources. An improved public
image could also reduce the potential for citizen suits against agricultural producers.
Public lands (or federal lands) administered by the Bureau of Land Management (BLM) and the U.S.
Forest Service (USFS) in the 11 western states comprise 42 percent of total acres. Nevada ranks
highest of all states, with 77 percent of its lands held by these two federal land management agencies,
while Washington is lowest with 22 percent of its territory controlled by the BLM and USFS. These
lands are typically range and forest lands, and are designated to be used for such purposes as grazing,
timber production, mining, and recreation.
Approximately 85 percent of these public lands are utilized by grazing domestic livestock under
some 29,000 individual grazing permits. These permits authorize approximately 21.6 million animal
unit months (AUMs) of grazing. Many individual public land ranchers largely depend on these
federal lands for seasonal grazing and, in situations where yearlong grazing is allowed, federal lands
may provide substantially all available AUMs. Estimates indicate that over half of the commercial
cattle herd in the 11 western states is on ranching operations which hold BLM or USFS federal land
grazing permits.
Ranching operations on federal lands, like other agricultural practices, may contribute to water
pollution loads as nonpoint sources. That is to say, some water degradation resulting from grazing
may occur. If any such degradation does occur from grazing, it is universally recognized as arising
from nonpoint sources. The language of section 303 of the CWA is silent on any mandatory
regulatory control of nonpoint sources of pollutants. The intent of the CWA is clear -- nonpoint
sources of pollution are not subject to mandatory regulations under the CWA, but are to be addressed
through voluntary, outcome-based programs. This applies to all lands, regardless of ownership
status.
Federal land management agencies, in cooperation with the states, should only address water quality
issues under their own enabling legislation, and as an integral part of all resources under their
management authority. The requirement of establishing TMDLs under the CWA does not grant
additional implementation authority to the federal land management agencies. When addressing
water quality issues, the BLM and USFS should ensure full and fair disclosure of all resource
conditions in question as well as providing opportunities for all interested and effected groups and
industries to comment on the planning and decisionmaking process.
Given the nature of nonpoint sources, outcome-based attainment is the only practical approach
available whether on public or private lands. The best and most efficient way to deal with any
loading resulting from nonpoint sources is through a voluntary approach which is site-specific,
recognizing the efficiency of outcome-based, flexible practices in order to mitigate any detrimental
effects. Specification of practices recommended to achieve desired outcomes should only be done
in a manner which allows the maximum flexibility practical in order to optimize effectiveness and
efficiency. This could best be achieved by utilizing an approach such as RMPs on federal lands,
which are tailored to the specific grazing permit operation. Federal management programs should
be encouraged to adopt this approach.
The key to successful implementation of this proposed response to TMDL issues is its highly
participatory and interactive approach. The approach is based on the foundation that voluntary
participation by agricultural producers is the preferred manner of addressing water quality
standards. The concept features detailed outreach, communication, technical information sharing,
planning, and education components. In addition, close coordination is maintained among the core
group of producers, the traditional conservation partnership, the private sector, and regulatory
agencies to maximize benefits derived by all stakeholders from a voluntary approach.
Once such an approach is put in place, partners must perform routine program evaluations to
document continued resource protection benefits, as well as economic and related benefits to
participating agricultural producers. Additional research may be necessary to confirm the
effectiveness of BMPs implemented by producers. Through coordinated program evaluation, where
planning and implementation efforts are closely monitored and assessed, states and other participants
can demonstrate the greater benefits of voluntary programs such as RMPs. This especially occurs
when evaluations are supported by coordinated water resource data collection efforts to measure
success through tracking water quality and other critical resource parameters.
By providing greater watershed participation and support, and through successful implementation
and evaluation, programs like agricultural resource management planning, will result in the
development of a local voluntary, incentive-based partnership to protect water quality. This
partnership will meet the needs of the TMDL provisions of the CWA. If state and local agencies are
provided the appropriate guidance and support, they can implement a locally-led water quality
protection and resource management planning approach that precludes the need for any regulatory
approach or mandatory enforcement under the CWA.
Under this approach, agriculture, the general public, and local governments all reap the benefits of
a better protected resource because everyone participates in making it happen. Since it is voluntary,
such an approach includes a careful and workable balance of the economic and business needs of
agricultural producers along with the public's values associated with water quality. This balance
allows all parties to realize the benefits associated with the necessary changes in behavior, financial
perspectives, and enhances participation and local commitment to success.
Where voluntary agricultural programs are successful, the public realizes the value of maintaining agriculture as a preferred land use. Through its locally-led and highly interactive nature, this approach demonstrates to local governments and the public that it is in their best interest to retain agriculture in the community, while protecting water quality. Because this approach is built on shared responsibilities, it results in a more effective and lasting partnership between agriculture and the general public who, likewise, share the water resource.
Background
Resource Management Plans (RMPs) provide farmers and ranchers with a voluntary opportunity to
enhance their resource protection and help address TMDL nonpoint source reduction goals in a
manner tailored to their operation. The purpose of the RMP process is to provide technical,
educational, and financial incentives to encourage the enhancement of environmental stewardship.
The process is designed as an integrated approach that is voluntary and site-specific in application.
To be successful, these voluntary plans must be farmer and rancher owned, controlled, developed
and implemented.
Components of RMPs should include, but are not limited to, as determined by the producer: crop
residue management; soil erosion management; nutrient management; integrated pest management;
animal waste management; cover crop management; water quality and utilization management;
grazing and range management; wetlands management; and species management. The planning
process provides increased outreach to farmers and ranchers by offering information, technical
assistance, and financial opportunities to farmers and ranchers for implementation of the plans.
Current RMP Implementation
RMPs have a proven track record. The New York City Watershed project is one example of a
successful voluntary approach to drinking water source water protection. This successful effort is
based upon the voluntary adoption of BMPs -- in a whole farm approach -- to control nonpoint
source pollution by the more than 400 dairy farmers in the New York City Watershed area. Other
examples include the Skaneateles Lake Watershed Agricultural Program in New York, and RMP
programs in Idaho, Florida, Oregon, Pennsylvania, Texas, and a number of other states.
Oregon 1010 Program -- Federal and state initiatives, ranging from the Clean Water Act (CWA)
and the Safe Drinking Water Act (SDWA), to Wellhead Protection, and other laws, are the driving
forces to new approaches to water quality protection in Oregon. These efforts culminated in the
passage of Senate Bill 1010 in 1993, designating the Oregon Department of Agriculture (ODA) as
the lead agency for education and enforcement efforts relating to agricultural nonpoint source
pollution affecting water quality.
Under Senate Bill 1010, local farmers and ranchers are asked to deal with identified problems such
as soil erosion, nutrient loss from fields, or degraded stream bank areas. The bill provides flexibility
so that landowners in each watershed are able to develop their own approaches to local problems.
Individual farmers and ranchers can develop and implement resource management plans specific to
their operation as long as the results of the plan are meeting the watershed goals and objectives for
water quality. Technical assistance is available from their local soil and water conservation district
or other sources.
Producers are encouraged to choose their own ways of meeting established water quality goals.
Once a farmer or rancher develops and implements a site-specific plan approved by ODA, then
his/her plan establishes compliance and ODA assumes any potential environmental liability.
Texas Agricultural/Silvicultural Nonpoint Source Management Program -- In 1993, the Texas
Legislature passed Senate Bill 503 which created a program to provide agricultural and silvicultural
producers an opportunity to comply with state water quality laws through traditional voluntary
incentive-based programs. The Texas Agricultural/Silvicultural Nonpoint Source Management
Program provides agricultural and silvicultural producers the opportunity to develop and implement
site-specific water quality management plans in cooperation with local soil and water conservation
districts. Certified water quality management plans ensure farming or ranching operations are
carried out in a manner consistent with state water quality goals. The plans are certified by the Texas
State Soil and Water Conservation Board. Approximately $2.5 million of $3.7 million is available
each year for cost-sharing for implementation. The remaining funds are used for technical assistance
for plan development and administration.
To remain in compliance with state water quality rules and regulations as well as to receive program
benefits, a producer must implement the certified plan as specified and agreed to in its
implementation schedule.
Common Threads of Different Approaches
While the specifics of successful RMP programs vary as local conditions warrant, there are common
threads to these successful approaches. Each program has recognized the importance of the
voluntary nature of resource management planning, specifically the producer's lead role as
decisionmaker in the planning and implementation of the RMPs. The programs have also
incorporated the importance of landowner control, local input and stakeholder coordination,
recognizing that local communities have the most knowledge of their needs and concerns.
Resource assessment and planning are also central in these programs. Each program gives producers
a chance to assess their resources first through a simple self-assessment questionnaire, and then
through a more in-depth review of their operation and practices. Based on that assessment,
producers work with conservation districts, state and federal agencies, and other service providers
to develop and implement alternatives which will enhance the protection of their natural resources.
Using Resources Management Plans to Address TMDLs
To address nonpoint source pollution reduction goals in TMDL impaired segments, EPA should
recognize, and states may choose to adopt, programs that are guided by RMPs that incorporate the
following concepts:
Stakeholder Coordination
Stakeholder involvement in any program to address nonpoint source pollution is important. All
interested parties must be included in the program development phase of the project. Local, state
and federal agencies should share their expertise in program requirements and administration, while
farmers and ranchers bring their knowledge of production agriculture and their operations to the
table, and local citizens play a significant role by outlining the concerns of the community.
In order for the RMP concept to be utilized and useful, it is important that the planning process, and
the plans, be user-friendly. Holding local meetings with producers is a good way to understand the
needs of farmers and ranchers. For example, in Idaho under the "One-Plan"(3) approach, focus group
sessions were held by local soil conservation districts in several locations throughout the state.
These focus groups included farmers and ranchers representing diverse agricultural groups. The
focus groups were conducted by an independent, trained facilitator knowledgeable about resource
management planning efforts.
The purpose of the focus groups was to introduce the concept of the Idaho "One Plan"to farmers and
ranchers throughout the state and listen to their reactions and record their impressions. The focus
groups gave opinions on various features of the "One Plan" that might be important or useful to
them. The input received from these focus groups was utilized to develop a useable and acceptable
Idaho "One Plan" product.
Once the product was under development and contained some planning prototype materials, a series
of presentations and demonstrations were made at various commodity groups and agribusiness
meetings. This increased the knowledge level of the product throughout the state and developed a
high level of interest and enthusiasm by potential customers. Refining the product continues with
input and feedback from users through a product testing team comprised of 11 farmers and ranchers
and three agency field representatives.
In order to truly have a single RMP process for a state, all state and federal agencies involved in
natural resource management need to be included as stakeholders from the beginning of the planning
concept. A multi-agency team should be responsible for the development of a state process. In
Idaho, the first step was to develop a formalized working relationship among state and federal
agencies and other private and non-profit organizations. The state agencies took the lead on
development of a Memorandum of Understanding (MOU) in order to provide a coordinated,
customer-oriented approach to resource management planning. This MOU affirms commitments
by the signatories to cooperate in the development and implementation of the Idaho "One Plan."
Resource Management Planning and Implementation
The RMP process used to address TMDL nonpoint source concerns should be a voluntary program
that provides for locally developed and implemented "one-stop" planning. The "team approach" to
assessing the needs of the watershed and the site-specific operation will lead to the successful
implementation of the program.
Producers and the "team" should use a logical, step-by-step approach designed to help them develop
the RMPs. It should guide them through their natural resource management decisions while
remaining flexible. In addition to the traditional sources of technical conservation assistance,
private-sector service providers can play a vital role in the development of RMPs and should be
encouraged to participate in the process at the producer's request. The process should be similar to
the clustering of the nine-step planning assistance process used by NRCS. The actions are cyclical,
not always sequential, and are rarely achieved in the short term. Recognizing that the producers
control the scope and extent of planning, their process may differ slightly from the NRCS nine-step
process while achieving similar results.
Below are planning steps which could be used to develop RMPs to assist in meeting water quality
objectives identified through the TMDL program. Service providers may describe their planning
assistance through other steps. The steps below are for example only.
Determine Objectives -- The producer voluntarily begins the planning process by looking
at his/her needs and objectives including financial needs, production capabilities, and long-term goals.
Inventory and Assess Resources -- The producer voluntarily assess and inventories the
resources available to meet his/her objectives. Resources include not only natural resources
such as soil and water, but financial, technical, equipment/facilities, labor, and similar
resources. The inventorying process can include a "tiered" approach where a producer
determines the areas of the operation that need a more in-depth assessment.
Assess Current Situation -- Producer evaluates how well objectives are being met. The
producer may wish to seek outside input here if he/she lacks the necessary data to make
water quality determinations.
Identify Resource Priorities -- Based on resource inventory and assessment and an analysis
of the current situation, the producer identifies areas where alternative practices could
enhance natural resource management.
Develop Alternatives -- The producer develops options, or chooses alternatives developed
by a service provider, to resolve the resource problems identified and may seek technical
assistance from qualified service providers.
Make Decisions --The producer selects the best management practices that meet his/her
objectives.
Document Decisions in Plan -- The producer combines site-specific, scientifically-based
resource-enhancing practices with his/her own innovations and ideas. The plan is a logical,
step-by-step process with a rational timeframe for implementation. The decisions in the plan
may be provided to agencies administering incentive programs in order to ensure eligibility
for services and benefits, and to document good environmental stewardship which can help
producers comply with environmental laws and regulations.
Implement Plan -- The producer carries out the schedule to implement the plan. Detailed
practices and designs or other resource-specific components of the plan that support
implementation of the plan may be reviewed by the producer annually or more often if
needed.
Evaluate and Modify Plan -- The producer evaluates the plan for corrections and adjustments, using the appropriate planning steps. The producer may change or revise the plans at any time. If the plan provides compliance with other laws, contractual agreements, or if financial assistance is provided, a producer may request reviews or approvals from administering agencies at any time. In those cases, approval should be provided indirectly by regulating agencies through agreements with local partners, such as soil and water conservation districts, where approval may provide additional benefits.
Outreach and Education
One important aspect of resource management planning and implementation is the educational
opportunity experienced by the producer. The RMP process offers unique opportunities for technical
outreach and enhanced recognition of environmental stewardship. For example, in New York, a full-time Agricultural Environment Management (AEM)(4) Outreach Coordinator employed by Cornell
Cooperative Extension Service works with local and state partners to coordinate education and
outreach activities such as training sessions/conferences, and other assistance for AEM program
participants in implementing RMPs. A producer's voluntary participation in the resource
management planning and implementation process should benefit him/her through access to outreach
and education efforts otherwise unavailable.
Likewise, to implement a solution to water quality problems identified through the TMDL process,
in particular with respect to non-regulatory approaches for nonpoint sources, outreach and education
will be an important tool. Because the TMDL process itself is a complex and technical issue, a
primary goal of outreach and education should be to provide a simplified but accurate message as
to the purpose and use of TMDLs and how TMDLs fit into separate programs for control and
management of pollution sources. This message must be delivered to agricultural producers, other
potential nonpoint source polluters within a watershed, and the general public alike. This will help
to alleviate much concern and confusion about the TMDL process, its applicability to nonpoint
sources, how pollution reductions will be achieved, fairness in dealing with permitted and
unpermitted activities, and the role of regulatory versus non-regulatory approaches. A clear and
truthful message will also promote the highest level of investment and participation by the
agricultural community in a well-coordinated response to the TMDL issue.
As states, or the EPA, prepare TMDLs for impacted waterbodies, outreach and education must occur
simultaneously if producers and the public are to properly understand and participate in the process.
As the TMDL process includes an assessment of present water quality and an allocation of reduced
loadings under a proposed improved condition, participants must understand both technical and
fairness aspects of these decisions. Secondly, once TMDLs have been established, states will need
the participation of an educated producer community in developing and implementing solutions (e.g.,
a system of BMPs or RMPs). Agricultural producers will need reliable information, delivered as part
of an outreach and education program, about the effectiveness of different practices to control
pollution.
States can use traditional sources for outreach and education, such as the Cooperative Extension
Service, soil and water conservation districts, state and regional agencies, federal partners,
agricultural associations, consultants/advisors, and local governments. Some states employ a
stakeholder process for resource management planning and implementation, which can be adapted
to deal with TMDL solutions through ongoing outreach and education. In many cases, states will
need to expand their sources for outreach and education to include a better coordinated effort using
resources of agricultural, conservation and water quality agencies.
In preparing an outreach and education program, careful consideration should be given to the
following components:
Agricultural producers will need to understand that, although the TMDL process does not
prescribe an implementation strategy for nonpoint sources, their ability to adopt and apply
improved management practices and resource management plans will play a crucial role in
any implementation strategy to achieve pollution reduction, and that their on-farm
management will be the key to success of the preferred non-regulatory or voluntary approach.
Goals should also recognize the need to distribute information about the effectiveness of
management practices to control pollution, and should incorporate accurate information on
opportunities for incentives and benefits (e.g., presumption of compliance, cost-share, tax
relief, precluding a regulatory program) to be derived by producers through Resource
Management Planning.
Background
In 1993, two Idaho environmental groups filed suit in Federal Court against the U.S. Environmental
Protection Agency (EPA) for violations of section 303(d) of the Clean Water Act (CWA). The
groups alleged that EPA improperly approved Idaho's 1992 section 303(d) list because the it did not
identify all waters violating state water quality standards. (Idaho Sportsmen's Coalition v. Browner,
Case No. C93-943WD (W.D. Wash.) The plaintiffs also alleged that Idaho had failed to develop a
sufficient number of Total Maximum Daily Loads (TMDLs) for Idaho's listed waters.
In April 1994, the Court issued an Order granting partial summary judgment to plaintiffs on their
challenge to the list. (Idaho Sportsmen's Coalition v. Browner. I d. (W.D. Wash. April 14, 1994.)
The Court found that EPA's approval of Idaho's 1992 section 303(d) list was arbitrary and
capricious, because EPA "failed to offer a rational explanation for its approval of a list containing
only thirty-six bodies of water" when there was "evidence showing that hundreds of waters were
impaired or threatened." The Court ordered EPA to publish a new list. In October 1994, EPA
published a section 303(d) list for Idaho that included 962 waterbodies.
In May 1995, the Court ruled that EPA must establish a "complete and reasonable schedule" with
the state of Idaho for TMDL development, as required by 40 CFR section 130.7(d)(1). The Court's
May 1995 Order described a reasonable schedule encompassing all listed waters as follows:
"[S]uch a schedule may provide more specific deadlines for the establishment of a few
TMDLs for well-studied water quality limited segments in the short-term, and set only
general planning goals for long-term development of TMDLs for water quality limited
segments about which little is known...."
In May 1996, the Idaho Department of Health and Welfare, Division of Environmental Quality
(DEQ) and EPA proposed a TMDL development schedule to the Court. This proposal included a
short-term schedule which provided specific dates to complete TMDLs for 41 water quality-limited
waters on the 1994 section 303(d) list. It included a four-year period. The proposal also included
a long-term plan which consisted of additional evaluations of water quality for listed waters and a
basin management approach to TMDL development for each of the six administrative basins in
Idaho. EPA indicated that all required TMDLs would be completed within a 25-year timeframe.
On September 26, 1996, the Court found that the proposed schedule for TMDL development in
Idaho "violates the CWA because of two flaws. The first is its extreme slowness.... The second flaw
is that the proposed schedule makes no provision for TMDL development for the full list of Idaho
WQLSs." The remedy ordered by the Court remanded the matter back to EPA with direction to:
"[E]stablish with Idaho ... a complete and duly adopted reasonable schedule for the
development of TMDLs for all water bodies designated as WQLSs in Idaho. The present
record ... suggests that a completion time of approximately five years would be reasonable."
Overview
The TMDL development schedule was prepared collaboratively by the Idaho DEQ and EPA Region
10. This schedule is built on several principles which include:
Basin management in Idaho used to approach TMDL development in each of the state's
six administrative basins with involvement by the appropriate Basin Advisory Group (BAG)
and by the appropriate DEQ Regional Office(s).
Development of priority TMDLs targeted over the short-term (three years) because the
severity of pollution of these waters is well documented, the sensitivity of beneficial uses to
further pollution, and the state resources have been allocated to these efforts.
Subbasin TMDL approach used to develop remaining required TMDLs over the longer-term (eight years) which considers all waters and parameters identified on Idaho's section
303(d) list.
Of particular note, for the long-term component, is the use of a "subbasin" TMDL approach to
address all waters on Idaho's 1994 section 303(d) list. There are 84 subbasins entirely or partially
within the state of Idaho. All required TMDLs within each subbasin will be developed concurrently.
All subbasins listed segments and parameters will be addressed within the eight-year time frame
identified in the schedule.
The eight-year time frame differs from the schedule proposed in May 1996 where EPA indicated that
all required TMDLs would be completed within 25 years. There are two important reasons for this
difference. The primary reason is that EPA Region 10, in its review of the May 1996 schedule,
believed that implementation should be a major consideration in the time required for TMDL
development. Thus, time to develop implementation plans was included in the TMDL development
schedule proposed in May 1996. It is still Idaho DEQ and EPA Region 10's desire to see
implementation addressed in the water quality management process. However, implementation is
not included within the timeframe of this TMDL development schedule in order to address
expediency concerns identified by the Court. A second important reason for the shortened schedule
is the use of the "subbasin" TMDL approach. "Subbasin" TMDLs will be developed in a relatively
short time using existing data and simple analytical methods.
As described, this multi-year schedule sets short-term deadlines for TMDL development on targeted
waters and identifies a long-range plan to address all water quality-limited waters still requiring
TMDLs. This is the schedule that the state intends to follow for establishing TMDLs in Idaho. The
length of the schedule reflects the substantial resource commitment that the state is making to this
effort. In the absence of this substantial commitment of resources by Idaho, this schedule would not
be reasonable to meet and a longer schedule would be needed to establish required TMDLs for
waters on Idaho's 1994 section 303(d) list. Furthermore, the proposed TMDL development schedule
is based on factors, described within this document, as they are known at the present time. DEQ and
EPA expect that as the TMDL development process moves forward in Idaho, some of the
considerations related to these factors could be subject to change. As a result, it may be necessary
to adjust the schedule accordingly in terms of order of TMDL development while still maintaining
the overall pace. Thus, needed changes will be conducted through appropriate schedule
modifications and all subbasins will still be addressed within the eight-year time frame.
Basin Management in Idaho -- Idaho has a comprehensive framework in place for DEQ to monitor state waters and implement pollution control strategies, including development of TMDLs. In 1995, the Idaho legislature passed Senate Bill 1284 to comprehensively address water quality throughout the State. (Idaho Code §39-3601 et seq.) The statute requires that water quality problems be addressed at the local level for each watershed. To address this requirement, the statute establishes citizen advisory groups which advise DEQ on monitoring, pollution controls, priorities, and TMDL development. DEQ appointed members to each of six Basin Advisory Groups (BAGs). These six administrative basins, identified in Idaho's water quality standards (IDAPA 16, Title 01, Chapter 02), include:
In addition to the BAGs, a significant component of basin management in Idaho is involvement of DEQ Regional Offices. These offices not only provide staff support to the BAGs, but also work directly with local groups and agencies. For TMDL development efforts in Idaho, DEQ Regional Office staff have the lead responsibility. Because of their key role, the TMDL schedule is organized by year, then by DEQ Region within each year. DEQ Regional Offices include:
In preparing the TMDL development schedule, the workload within each DEQ Region is a major
consideration and is discussed in several of the following sections.
Development of Priority TMDLs -- In the May 1996 schedule, high priority waters were targeted
for complex TMDL development over a four-year period. The schedule proposed in May 1996 for
these waters remains essentially intact. Each of these waterbodies has been well studied and DEQ
resources are already directed to develop TMDLs on these waters. The waterbodies are considered
high priority because of the documented severity of pollution. Because of the numerous sources of
pollution and other factors affecting these high priority waters, development of TMDLs on these
waterbodies has been technically complex and resource intensive. Upon approval by EPA, each of
these TMDLs will be included in Idaho's Water Quality Management Plan.
Subbasin TMDL Approach -- Remaining waters will be addressed through development of
"subbasin" TMDLs. Viewing water quality management needs and pollution control efforts from
a subbasin perspective is intended to increase efficiency in TMDL development. These "subbasin"
TMDLs will be developed in a relatively short time frame using existing data and simple analytical
methods. This process will employ an approach built on preparing a subbasin assessment, followed
by TMDL development.
The following sections outline, in greater detail, the role of each step in this proposed schedule. This
proposed schedule includes a process to:
The purpose of the subbasin assessment (SBA) is to describe water quality in a particular subbasin.
Specifically, the subbasin assessment is intended to:
The approach taken in preparing the subbasin assessment is to summarize existing information,
including Beneficial Use Reconnaissance Program (BURP) data, related to water quality within the
drainage area. Based on results of the subbasin assessment, waters on Idaho's 1994 section 303(d)
list may be identified which are shown not to require TMDLs because water quality standards are
met. DEQ will inform EPA that they are modifying (resubmitting) the section 303(d) list to remove
those waters. If EPA approves removal of those water because they meet water quality standards,
then TMDLs will not be required for those waters.
For those waters that still require TMDLs, the subbasin assessment provides technical information
which serves as a foundation for TMDL development.
Schedule
The TMDL schedule addresses specific concerns identified in September 1996 by the United States
District Court for the Western District of Washington. The schedule will be conducted over a
reasonable time frame, specifically eight years. The schedule will also lead to completion of all
required TMDLs with appropriate consideration given to all waters and parameters identified on the
1994 section 303(d) list for Idaho.
Idaho's section 303(d) list contains 962 water bodies -- 83 percent are smaller wadable streams, 13
percent larger rivers and four percent are lakes or reservoirs. The pollutants listed for these 962
water bodies are as follows: sediment 91 percent, nutrients 29 percent, flow alteration 22 percent,
temperature 19 percent, habitat modification 15 percent, bacteria or pathogens 15 percent, dissolved
oxygen 12 percent, metals five percent, and other (ammonia, pesticides, organics, oil and grease,
etc.) 12 percent.
As described, this multi-year schedule sets short-term deadlines for TMDL development on targeted waters and identifies a long-range plan to address all water quality-limited waters still requiring TMDLs. The proposed TMDL development schedule is based on factors, described within this appendix, as they are known at the present time. The TMDL schedule commences in 1997 with completion of all TMDLs by the year 2005. The TMDL process consists of a 22-month TMDL development phase followed by 18-month implementation phase. TMDL development will use the phased approach primarily on sediment, nutrients and temperature in Phase 1. Development of TMDLs will occur on large scale watersheds. Idaho's 51 Soil Conservation Districts have identified as TMDL priorities, 400 segments from Idaho's list of water quality limited (section 303(d)) water bodies.
1 NASDA is the national nonprofit association of public officials representing the Commissioners, Secretaries, and Directors of agriculture from the 50 states and four territories.
2 Under the Florida Water Quality Assurance Act, passed in 1983, the state water quality agency is responsible for the remediation of groundwater problems including nitrates in water supplies. The state can recover remediation costs if they can determine who caused the water quality problems. However, it is very difficult to identify the source of nitrate problems to recover remediation costs. The Florida legislature, through the Florida Department of Agriculture and Consumer Services (FDACS), brought together stakeholders to develop proposed solutions to address the nitrate problem in groundwater. The stakeholders included the state water quality agency, agricultural organizations, agribusiness representatives, Farm Bureau, large landowners, and producers. A new law -- which became effective in August, 1995, administered through rules promulgated by FDACS pursuant to the Florida Commercial Fertilizer Law --
includes a 50 cent fee on each ton of fertilizer with nitrogen sold. The rule defines BMPs for nitrate
reductions. Under the Commercial Fertilizer Law -- Chapter 576 of the Florida statutes -- producers who
implement the BMPs are given a "waiver of liability" to protect them from future liability for remediation
done by the state, and are provided with a "presumption of compliance" with the state groundwater standard
for nitrates. The fees collected are used for research to help solve the nitrate problem. If the research shows
that a BMP is not effective, then producers may have to change to a more effective BMP to stay in
compliance and receive the remediation liability protection. The FDACS must report to the Florida
legislature on progress made in solving the nitrate problem. Unless the legislature determines that additional
resources are needed, the fee will expire in the year 2003 unless reauthorized, and the "waiver of liability"
protection will expire in the year 2008.
Michigan implements a similar program where producers are protected from civil liability under the Michigan Right to Farm Act if they implement General Accepted Agricultural Management Practices (GAAMPs), and from remediation liability under the environmental code of they participate under the Groundwater Stewardship Program and follow pesticide label requirements.
3 The Idaho "One Plan" enables farmers and ranchers to be more informed and productive, and provides a "one-stop" location for current information. It improves agency efficiency in developing and implementing conservation benefits throughout Idaho. The "One Plan" concept promotes resource stewardship, consolidates resource management efforts, reduces agency confusion and conflict, standardizes technical specifications, and helps the farmer or rancher understand and comply with prevailing environmental laws and regulations. The system is designed to be customer oriented with improved agency efficiency in providing conservation benefits.
4 The New York Agricultural Environmental Management (AEM) Program addresses farm-based environmental issues in a flexible, cost-effective way in all areas of the state. It incorporates all of the concepts of the RMP program advocated in this report, with special emphasis on "tiered" planning as implemented in the Skaneatles Watershed Program. Tiered planning allows the statewide program to focus resources on priority problems in sensitive watersheds. However, it also encourages participation by producers throughout the state as a means of documenting good environmental stewardship and enjoying the many incentives associated with participation. The program provides a framework for cooperation among local, state and federal agencies responsible for protecting the state's environmental resources. It facilitates local initiatives and partnerships to address local needs. The program also provides technical, educational and financial incentives for farmers to participate, and promotes public understanding and support for agricultural/environmental initiatives.
©1997 The National Association of State Departments of Agriculture
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