EPA rulings on Non-point

D. Staples dstaples at livingston.net
Tue Dec 28 17:10:06 EST 1999

This is a reprint of a comment on the About.com forestry board, posted
by a SC state forester.  Interesting commentary.

I thought I would jump into this discussion..

   I work for a state forestry agency, and run our forestry BMP program.
I was
   given the task of reviewing the proposed EPA changes and commenting
   them (and I wouldn't wish reading all of that on anyone!).

   I hear that this will pass, that it is just a matter of time. As a
matter of
   clarification, my understanding is that the TMDL and the loss of the
   nonpoint source classification are linked. In other words, each state
   quality agency is supposed to determine the historic use of each
water body.
   Then, they figure out through monitoring, etc. which water bodies are
   meeting their historic use.

   If a stream is not meeting its historic use (such as swimming,
fishing, etc), then
   they come up with a TMDL for that stream. Under these proposed regs,
   activities occurring adjacent to a stream that is not meeting it's
TMDL or where
   a TMDL has not been established could require a permit.

   In SC where I live, the water quality agency (DHEC) figures show that
   activities only contribute 4% of the total nonpoint source pollution.
In the
   proposed regs, they key in on forestry and barely mention the other
   like urban runoff and agriculture, which are the highest polluters
here. And the
   language in the proposed regs mentions that this authority would be
   rarely, and at the discretion of the state coordinator. This broad
   scares me!

   My contention in the response was that our NPS prevention program
   got recognition from EPA and NOAA for being innovative and successful
   trying not to brag too much!), so why go and make it regulatory? I
mean, if it
   ain't broke, don't fix it!

The door to my web page:  http://www.livingston.net/dstaples/
For forestry commentary see bionet.agroforestry and alt.forestry news
groups, as well as http://www.delphi.com/ab-forestry/ for a continuing
conversation on forestry.

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