EPA rulings on Non-point
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.
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
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
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.
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
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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