x>EPA
              United States
              Environmental Protection
              Agency
              Water Planning Division
              Washington, DC 20460
                           September 1979
              Water
Agriculture Nonpoint
Source Strategy
                  ^ ^r



 •

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AGRICULTURAL NONPOINT SOURCE STRATEGY
       WATER PLANNING DIVISION
 U-SŤ ENVIRONMENTAL PROTECTION AGENCY
           OCTOBER 10, 1979

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON. D.C.  20460

                                    OCT1979
                                                     Office of Water and
                                                       Waste Management
                 AGRICULTURAL NONPOINT SOURCE STRATEGY
The national agricultural nonpoint source strategy has been developed to
provide direction to EPA, State and local governments and the agricultural
community in the implementation of the agricultural  portion of the water
quality management program.

The initial water quality plans have provided evidence that agricultural
activities are a source of significant pollution in  many parts of the
country.  The resources required to abate or prevent continuing agricul-
tural  nonpoint source problems will be substantial.   Both public and
private investment must be utilized in the most cost effective manner.

The strategy focuses initial  efforts on those areas  which State and local
agencies have identified as having the most critical water quality problems.
It places the highest priority on use of EPA funds to assist in accelerating
the establishment of best management practices (BMPs) in those areas.  In
addition the strategy recognizes that there is a lack of data on cause  and
effect relationships between  establishment of BMPs and stream quality.   EPA
resources will be made available to provide more information in that area.

Agricultural nonpoint source  problems vary from region to region.   Institu-
tional and legislative mechanisms available also may differ from State-to-
State.  Regions will be expected to adopt a strategy which will meet the
various regional, State and local needs.
                                           Merira M.  Hurd,  Director
                                           Water Planning  Division

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                     Agriculture Nonpoint Source Strategy


INFORMATION

An aggressive nonpoint source  (NFS) pollution control program is required if
the legislatively mandated water quality goals are to be met.  Since agricul-
tural activities have been identified as major contributors to nonpoint source
pollution, EPA has given a high priority to the development and implementation
of agricultural nonpoint source control programs.

Agricultural nonpoint source pollutant problems are pervasive.  (Many States-'
have identified their agricultural NFS related water quality problems and
developed implementation programs.)  Reasonable solutions to many of the agri-
cultural problems are known and many of the institutional mechanisms are in
place.  However, there is general agreement that while implementation programs
move ahead, there is the need  to develop a more comprehensive evaluation of
the impact of agricultural nonpoint source pollutants on water quality; the
degree of control required to  meet water quality goals; and, the effectiveness
'of Best Management Practices (BMPs) in reducing pollutant loadings and meeting
water quality goals.  Since water quality management resources in EPA are limited,
it is not feasible to fund each State to look at every agricultural  nonpoint
source water quality problem.  A strategy has been developed to focus resources
on solving the most significant problems in those areas where water quality has
or will be most adversely affected.  Information and data from these projects
will be widely disseminated to other States with similar problems.

NPS projects of the Office of  Research and Development (ORD) are an integral
part of the NPS program.  The  NPS strategy recognizes the supportive role of
the ORD projects in implementation of the strategy.

The agricultural strategy builds on the framework developed in the Water
Planning Division's Water Quality Management Strategy.  It is consistent
with the Work Load Analysis (WLA) developed for the Zero-Based Budget process
for both the FY 80 and 81 budgets.  The increasing emphasis on program imple-
mentation described in the strategy is consistent with the FY 80 and 81 bud-
get decisions.  The attention  to implementation will  require that additional
Agency resources are devoted to this area.  However,  since the need for personnel
in the planning phase will decrease, no additional  resources will  be required
in the water quality management program.

PURPOSE

The agricultural NPS Strategy  is the framework for:  1) defining national
agriculture NPS policy; 2) developing Regional agriculture NPS strategies
and State programs for continuing agricultural NPS planning and implemention
activities; 3) funding FY-1980 agriculture NPS program elements; 4) determining
the need for new Federal  legislative  initiatives or changes needed in existing
legislation and 5) recommending required legislative action.
  here applicable, State definition also includes areawide agencies.

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OBJECTIVE 1

Complete the development of State agricultural NPS plans:

     •    Identify and prioritize areas with critical agricultural NPS water
          quality problems.

     •    Select BMPs appropriate for the pollutant problems.

     •    Designate management agencies with adequate authorities and
          capabilities.

     •    Develop operational programs.

National Policy Direction

Continued Section 208 funding for the development of agriculture NPS programs
will be limited to States that have identified agricultural activities as
significantly contributing to the State's water quality problems.  Planning
funds may be made available in those States where EPA has determined that the
agriculture plan elements in the initial plan were inadequate.  Normally,
agricultural portions of 208 plans determined by EPA to be adequate will  not
receive further funding. Where warranted, further funding must be commensurate
with an established need for additional water quality problem identification
and solutions and for further designations or changes in area priorities.  In
addition the responsible planning and designated management agencies must clearly
demonstrate an interest in implementing the NPS control program before further
funding is provided.  Agricultural NPS elements are considered adequate if
agricultural NPS problems are identified, critical areas and sources prioritized,
BMPs identified in sufficient detail to select implementation projects, manage-
ment agencies have been designated and the required operational program is
underway.  No funds shall be provided in those States where agricultural
activities do not presently contribute or will not contribute to water quality
problems.

Problem identification has not been completed in a number of States.  Sediment
was identified as a pollutant in many of the initial plans, but other potential
pollutants (i.e. pesticides, nutrients, etc.) may not have been addressed. In
States where preliminary data indicates a strong probability that pollutants
other than sediment contribute to water quality problems funding priority
shall be given to address those pollutants.

Continuing planning process (CPP) funding may also be required to complete
other program elements, such as the development of State funding for the
operational programs of designated management agencies, for administrative or
legislative actions required to accelerate implementation, and for CPP regulatory
program development.  CPP activities which address regulatory programs shall
be given priority.

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Funding of agricultural NPS work elements that involve cause/effect analyses
and the evaluation of the effectiveness of BMP systems will generally be
limited to projects selected under the comprehensive monitoring and evaluation
program objective.

Discussion

Identification and Prioritization of Critical Areas or Sources

Most States identified agricultural NPS pollutants as a significant water
quality problem in their initial 208 plans.  A variety of planning techniques
were used to identify those problems, ranging from sophisticated land use
models to field examination.  In many States the information developed was
sufficient to identify the critical problem areas.  Since implementation will
focus on those priority problem areas and available resources will limit the
number of areas which can be addressed, the use of funds for further problem
identification studies will have a very low priority.  States have designated
priority areas as a result of RCWP requirements (many States used FY 79 funds),
therefore, no FY 80 funds will be utilized for this purpose.  Since implementa-
tion resources are only sufficient to initiate control programs in a few of the
highest priority problem areas, the development of priority listings for every
area in the State is not necessary at this time.

BMPs

BMP identification was required in initial plan development.  While these plans
addressed BMPs, in many cases the BMPs were limited to standard soil and water
conservation practices.  As the impact of many of these practices on water
quality is not clearly understood, evaluation of BMP effectiveness is still
required and will be funded in selected priority problem areas where accelerated
BMP implementation is underway.

The largest gap in selection, testing and evaluation of BMPs regards pollutants
other than sediment.  The CPP can be utilized to obtain this information.  Exam-
ples include the use of Cooperative Extension Service personnel in addressing
pesticide, nutrient, animal wastes, etc; the funding of planning activities in
such critical problem areas; and the funding of programs to transfer techniques
to other applicable areas.

The initial planning process resulted in the development of numerous BMP Hand-
books and substantial amounts of informational material such as brochures, slide
shows, movies, etc.  FY 80 funds will not be used to produce similar material
which would duplicate what has been produced previously.  Funding material of
this type will be limited to innovative approaches for which Handbooks, and
other informational or educational material have not been developed.

Management Agencies

There will be few cases that justify funding of activities  related  to management
agencies.  Designation of management agencies was completed in the  initial
plans.  Where required, detailed management agency agreements  have  been funded
with FY 78/79 funds.  Where management agencies accepted their designation

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it was in full recognition of their obligations and they should be prepared to
fulfil their responsibilities.  This does not mean that management agencies
can not be utilized to carry out specific planning functions.  Planning
activities related to management agencies, such as, obtaining additional  admin-
istrative or legislative authority (i.e. regulatory legislation) are eligible
for funding and have a high priority.

Develop Operational Programs

Most initial plans will require additional effort for the development of effec-
tive operational programs.  With few exceptions most States have relied heavily
on ongoing programs.  Issues concerning additional non-Federal resource require-
ments were generally not given much attention.  The CPP should address the
questions of providing technical assistance and cost sharing through non-Federal
sources, and developing additional administrative and legislative authorities
required to meet the program decisions agreed to in the initial plan.  Some
examples include State and local budget support for management staffs, including
enforcement; State and local cost sharing programs; administrative regulations
requiring BMPs on State leased land; etc.
Program Tasks

Headquarters

1.   As requested, assist Regional Offices in the
     development of Regional agricultural  strategy.

2.   Define and provide examples of acceptable agri-
     culture NPS elements to Regional  Offices & States.

3.   Develop additional cooperative agreements as re-
     quired.  Define functions and areas where Regions
     and States may use USDA (ASCS, SCS, SEA, FS), USDI,
     and TVA to complete agriculture NPS programs.

4.   Provide Regions and States with information on the
     mechanisms States have developed to fund the opera-
     tional elements of the agriculture NPS programs and
     on regulatory agricultural NPS programs.

Regions

5.   Develop Regional  agricultural NPS strategy.

6.   Identify those States with acceptable agricultural
     NPS plans and those States with inadequate elements.
     Define requirements and work elements necessary to
     make the plans acceptable.  This analysis is needed
     as input into the Regional strategy.
Scheduled Action
Assist three Regions
prior to 1-80

Quarterly; Starting
1-80

Develop two coopera-
tive agreements in
FY 80
Quarterly, starting
1-80
Complete 1-80

Complete 12-79

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7.   Use the cooperative agreements to assist States        Each Region develop
     in utilizing the expertise of USDA (ASCS, SCS,         minimum of 1 program
     SEA, FS) and other agencies (DOI, TVA) to com-
     plete their State agriculture NPS programs.
8.   Negotiate State/EPA Agreements and develop 208         Complete for FY 81
     work plans to correct the inadequacies of State
     agricultural NFS plans.
Funding Decisions
9.   Fully approved Agricultural NPS elements are generally not eligible for
     funding.  Where conditions change, the continuing planning program may
     be required to address plan additions or revisions.
10.  Funding will be available only to those States with:
     (a)  Significant agricultural NPS problems.
     (b)  Agricultural NPS elements which were found to be inadequate in
          the initial 208 plan.
11.  Funding will not be provided for further problem identification activity
     in designated RCWP projects.
12.  BMP Handbooks for soil and water conservation practices will not be
     funded.  Pesticide and nutrient BMP activity may be funded.
13.  208 funds can not be used to cost share BMP implementation.
14.  Those States addressing regulatory programs for agricultural NPS controls
     shall be given funding priority.
Federal Legislative Initiatives,
15.  Reauthorization of 208 planning grants beyond FY 80.

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OBJECTIVE 2

Develop a comprehensive monitoring and evaluation (M&E) program to:

     •   Determine the cause and effect relationship between agricultural
         activities, NFS pollutants and their impact on stream quality.

     •   Evaluate the effectiveness of BMPs on stream quality;

     •   Determine the degree of control necessary to meet water quality
         qoals.

National Policy Direction

Initial plans have defined the agricultural NPS problem on a broad scale.
However, only limited information is available regarding the effect of
agricultural activities at the field, farm and small watershed level.  There
is a need to analyze the effect of NPS pollutants on stream quality from various
farming activities and to evaluate the cost effectiveness of BMPs applied to
correct or prevent those problems.  A comprehensive M&E program, including
technical guidance, is being developed in coordination with the Office of
Research and Development.  The M&E Guidance document will be jointly released
by ORD and OWWM and will provide guidance for;

     •   General M&E which will normally consist of a few stations to determine
         BMP effectiveness in selected projects.  An example is the requirement
         for a general M&E program in all approved Rural Clean Water Program
         (RCWP) projects.  General M&E is also being conducted in a number of
         Model Implementation (MIP) and ACP Special  Projects.

     •   Intensive M&E which will be utilized to determine detailed cause and
         effect relationships in a very limited number of areas (projects in
         the major type of agricultural activity areas such as dairy farming,
         corn belt and wheat belt cropping systems, irrigated agriculture, etc).
         Intensive M&E will be restricted to nationally approved projects.

M&E guidance being developed must be utilized for all intensive M&E projects.
Additionally all monitoring and evaluation funded, beginning with FY 80, will
be conducted in accordance with the Administrator's June 14, 1979, memorandum:
Quality Assurance Requirements for all EPA Extramural Projects Involving
Environmental Measurements^

Discussion

There is a Tack of information regarding the causes and effects of NPS
pollution and cost effectiveness of control programs.  This has been stated
in the initial plans, in GAO reports, and in the recent Congressional Oversight
Hearing on NPS pollution.

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This information is required vto establish appropriate BMPs, determine the costs
and benefits of a NFS control program, convince landowners and the public that
the required investment is appropriate and, where required, provide justifi-
cation for enforcement actions.  The information will be obtained through
both general and intensive M&E in project areas where BMPs are being applied
on an accelerated basis.  These projects will normally be restricted to RCWP,
MIPs, Special Water Quality Projects, projects where State funded cost sharing
is available and research projects.  A number of field evaluation (M&E) projects
will be funded with ORD funds in FY 80.

Approximately ten projects (including those selected under RCWP), representative
of different types of farming operations, climatic and soil conditions,
combinations of BMPs, and receiving water use will be selected for intensive
study of cause/effect relationships.  The intensive M&E projects are costly
and will normally have a time span of not less than five years.  Information
from these projects will be used in other areas with similar problems and
conditions.

Priority for both intensive and general M&E projects will be given to the
accelerated implementation projects (MIPs, Special Water Quality Projects,
RCWP projects) to make use of the administrative and management structure,
the baseline data, the commitment of USDA agencies and the institutional
structure already developed.

Intensive M&E projects approved under the RCWP will receive funds from that
program.  Other intensive M&E projects will be funded mainly with 208 funds
although 106, 314 and research funds may also be used.  Those RCWP projects
which are not selected for intensive M&E will require a general M&E program.
Assurances that such a program will be conducted must be forthcoming before
final project approval is given.  Funds for general M&E may be provided from
a number of sources; 208, 106, other Federal programs, State and local funds,
etc.

Program Tasks                                               Scheduled Action

Headquarters

1.   Develop draft monitoring and evaluation guidelines           3-80
     with ORD assistance (September 1, 1979).  Finalize
     detailed monitoring and evaluation guidance.

2.   Based upon an analysis of State 208 plans and the          10-79
     advice of Regional Offices and States, develop a
     matrix of water quality conditions, types of farm
     operations, pollutants and BMP systems to be covered
     by the intensive monitoring and evaluation studies.

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                                     8
3.
4.


5.


6.


7.

8.
     Develop a monitoring and evaluation strategy that
     classifies pollutants, water quality conditions and
     combinations of BMPs for different agricultural enter-
     prises to determine the required mix of monitoring and
     evaluation proposals.  The M&E project proposals will
     cover a variety of conditions, pollutants and BMP
     systems and will be prioritized with the assistance
     of Regional Offices and States.  The classification
     of pollutants, conditions and BMP systems will  be
     used as a check to cover as many matrix elements as
     possible within existing resources.  The strategy
     will integrate the mix of conditions to be studied
     in order to:  1) determine the cause/effect rela-
     tionship of selected NPS pollutants on water quality;
     2) to estimate the effectiveness of BMP systems
     on preventing pollutants from reaching the stream
     for different types of farming operations; and,
     3) the amount of control required to meet water
     quality goals.

     In cooperation with USDA, select the RCWP M&E
     projects.

     In cooperation with the Regional Offices and States,
     select projects for intensive M&E with 208 funding.

     Assist in development of work plans for RCWP and 208
     funded intensive M&E projects.

     Coordinate with O.RD on its M&E Projects.
 11-79
     Establish system to provide Regions with informa-
     tion obtained from the M&E projects.
Regions

9.
     Recommend appropriate RCWP and 208 funded projects
     for intensive M&E.
10.  Assist appropriate States to develop M&E plans
     for RCWP projects and 208 funded M&E projects,
     both general  and intensive.

11.  Negotiate FY  1980 208 grant agreements to fund
     general  and intensive monitoring and evaluation
     project activities.
 11-79


 11-79


 Complete 2-80


 Ongoing

 6-80




 10-79


 Complete 3-80



Complete 3-80

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Funding Decisions
12.  Intensive M&E projects funded by 208 or RCWP must be consistent with
     the national M&E project priorities.
13.  208 funds for other than intensive M&E projects will be limited to
     trend analysis on RCWP projects and special projects where M&E is
     already underway.  Other funding sources will also be utilized.
14.  All M&E projects must follow EPA's Quality Assurance Requirements.
Federal Legislative Initiatives
15.  None

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OBJECTIVE 3

Expedite the Implementation of Agriculture NFS Control Programs:

     t  Utilize the resources and authorities of EPA, USDA and other agencies
        (USDI, TVA) to accelerate the implementation of approved/certified
        State agriculture NPS programs.

     •  Seek additional resources to fund the implementation of agriculture
        NPS programs (Federal, State, local).

     t  Encourage States to use their existing water pollution legislative
        authorities as necessary, to secure the application of BMPs by
        farmers who will not participate in voluntary programs.

National Policy Direction

Implementation is the highest priority of the agricultural NPS strategy.
Aggressive national and Regional leadership is required to assist States  to
make use of their own authorities and the authorities and resources of Federal
agencies to expedite the implementation of agriculture NPS control  programs.
Regional Project Officers will work with States and other agencies to develop
at least one accelerated implementation project for a priority agricultural
water quality problem area in each State, in addition to ongoing MIP, ACP
special projects and RCWP projects.

Discussion

Environmental and agricultural programs provide incentives which can be used
to assist to meet the national goals of fishable/swimmable waters while
maintaining an adequate food and fiber base.

Regions must work with local. State, and other Federal planning and management
agencies who have the authority, delivery systems and resources to implement
NPS controls.  The means for implementing priority projects include:

     •  RCWP projects.

     •  Additional ACP projects.

     •  Agreements with other Federal and State agencies to transfer or add
        resources to work in priority areas.  This includes' Soil Conservation
        Service, Cooperative Extension Service, T.V.A., Bureau of Land
        Management, Bureau of Reclamation, Forest Service, State agricultural
        and forestry agencies, etc.

     •  Provision of State and local cost sharing programs.

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     •   Provision to re-direct funds by those agencies whose program objectives
         are enhanced by NFS control programs, (ie) Highway Department,
         Irrigation Districts, Fish and Game Agencies, etc.

     •   Local and State regulatory programs.

The Administrator reiterated his support of non-regulatory agricultural
control programs on July 18, 1979, before the Subcommittee on Oversight and
Review, House Committee on Public Works and Transportation.  However, a
number of States have developed backup authority to ensure that non-participating
farmers do not gain an economic advantage over cooperating farmers by their
failure to implement BMPs.

Iowa, South Dakota and Pennsylvania have adopted regulatory controls for
agricultural erosion and sediment problems.  Other States such as Washington
rely on a voluntary program but refer non-participating farmers (those who
have had a valid complaint filed against them and refuse to correct their
problems) to the Department of Ecology for action.  Without violating the
concept of a voluntary program, there are a number of mechanisms that can be
used to monitor program compliance.

Various management tools are available to accelerate NPS control programs.
For example, where pesticide use is substantial, in addition to an on-farm
integrated pest management program, container disposal may require attention.
Consideration may be given to establishing a system of disposal fees included
in the price of the pesticide to support a program for proper disposal of
containers in these situations.

Regional project officers are the key to assisting States in implementing their
agriculture NPS program.  The umbrella USDA/EPA agreement and agreements
between EPA and individual USDA agencies should be used by project officers
to develop projects with USDA on shifting its resources to meet State priorities.
Agencies in the U.S. Department of the Interior and the Tennessee Valley
Authority can also assist States with their agriculture NPS control programs.

Other examples for NPS implementation include Bureau of Land Management leases
requiring performance standards to protect water quality and Title V Regional
Economic Development Commission funds used to establish BMP demonstration
projects.

A few States  (Wisconsin, Minnesota, Iowa, etc.) have developed cost share
programs to subsidize the costs of BMPs.  Regions should assist States in
these types of legislative initiatives by providing information on State
cost share programs and encouraging their adoption.

Regions should identify and evaluate conflicting, inflexible and ineffective
programs.  Problems with State and local laws, ordinances and programs should
be included in any evaluation process.  A major example is the prior appropriation
rights water law common in the western States.

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A key element in the strategy is the training assistance given to designated
management agencies in the utilization of management tools in their States to
accelerate NFS implementation.  As part of this assistance, a number of manage-
ment agency workshops will be conducted in FY 30 and FY 81.
Program Tasks

Headquarters

1.   Provide information to Regional Offices and
     States on innovative management and legislative/
     administrative initiatives to secure the implemen-
     tation of NFS controls.

2.   Work with national agricultural organizations to
     enlist their support for implementation program.

3.   Develop material which will be used in management
     agency workshops.  With Regions, schedule work-
     shops as required.  National Association of
     Conservation Districts (NACD) will provide
     consulting services and have a major responsi-
     bility for the scheduling and conduct of
     workshops.

Regions

4.   Develop better communication among State water
     quality agencies, designated management agencies,
     and ASCS, SEA, SCS, BIA, TVA, BLM, etc.  Methods of
     accomplishment include work shops, establishing
     advisory groups, etc.

5.   Assist States, ACP development committees and
     other agencies to focus technical assistance
     (SCS, SEA, FS) and funds (ACP, Small Farm
     Demonstration projects, State cost-share
     programs Title V Regional Development Commission
     funds, etc) in at least one priority area per
     State to expedite the implementation of agri-
     culture NFS control practices.

6.   Assist States to develop leases and contracts
     which include stipulations to protect water
     quality on public lands with the Bureau of
     Land Management, Forest Service and Tennessee
     Valley Authority, as appropriate.  Select at
     least one priority area per State and develop
     agreement.

7.   Encourage States to use their existing legislative/
     administrative authorities to secure compliance
     from non-cooperating operators. Develop program
     in at least one State per Region.
                                                            Scheduled Action
                                                            Quarterly beginning
                                                            1-80
                                                            Continuing
                                                            6  workshops;  2  per
                                                            quarter in  2nd,  3rd,  &
                                                            4th  quarters.
                                                            Throughout year
                                                            Identify  project  1-80
                                                            Initiate  4-80
                                                            Initiate  5-80
                                                            By  6-80

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8.   Assist in initiating, scheduling and conduct of        Initial  selection  12-79
     management agency workshops.  Locations will be        Final  selections 1-80
     limited to those Regions which request workshops.      Workshops start 3-80
                                                            Workshops completed  8/80
Funding Decisions
9.   Approve RCWP project applications.
Federal Legislative Initiatives
10.  Extend RCWP  (208j) authorization.

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OBJECTIVE 4

Develop a Management Information System for evaluating the effectiveness of
the Agriculture NFS control program.

National Policy Direction

The WQM program will be evaluated on its success in implementing 208 planning
decisions which will lead to meeting the Nation's water quality goals.   A
management information system which will provide data for evaluating the NPS
program is to be developed.  Agriculture will  be a key element in the system
developed.

Discussion

Hundreds of management agencies have been designated to implement agricultural
NPS programs.  These agencies were generally in operation and were given the
additional responsibility for water quality management.  The success of the
agricultural NPS program depends to a great degree on their concerted efforts.
EPA has not normally worked with management agencies on a continuing basis.
Presently, there is no system by which the implementation program (water quality
outputs) of these agencies can be determined.   EPA does not have any system
by which this information can be collected and analyzed (ie) there is no way
by which we can determine if a program's goals are being met or if we can
judge whether a program is successful.

An approach is required which recognizes EPA's resource limitations and
utilizes the delivery systems of other agencies (local, State and Federal)
to provide required data.

Program Tasks                                               Scheduled Action

Headquarters

1.   Form a management information system task force of     Initiate 11-79
     Headquarters, Regional, ORD, USDA and State            Complete 6-80
     representatives to:

     a.  Establish the scope of the system;
     b.  identify the data elements to be included in
         the system;
     c.  evaluate information collection and transfer
         mechanisms and recommend a system that will
         provide the user community with timely and
         accurate information on the implementation
         of agriculture nonpoint source control programs.

2.   With the Regions, develop criteria to be used to       Initiate 1-80
     document the success of State agriculture NPS          Complete 6-80
     control programs.

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                                      15
Regions
3.   Develop with States, the criteria to be used to        Initiate 3-80
     evaluate the States' and the designated management     Complete 9-80
     agencies' success in implementing agricultural
     nonpoint source control programs.
Funding Decisions
4.   None
Federal Legislative Initiatives
5.   None

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OBJECTIVE 5

Policy issue analysis required to provide basis for Agency's long range
agricultural strategy.

National Policy Direction

To date, agricultural NPS policy and programs have focused on utilizing
presently available legislative authority, resources and institutions.  It
is believed that significant short term progress in NPS implementation can
be achieved in this manner.  However, the strategy should also consider long
range needs in the above areas.  It is also necessary to evaluate a number of
broader agricultural policy issues to determine their long range effect on the
Nation's water quality goals.

Discussion

There are a number of policy and program issues which must be reviewed in
order to determine what actions are required to assure that the agricultural
NPS strategy is revised as required, addresses changing needs and remains
consistent with other program policies in the Administration.

No major policy or program shifts are expected within the next two years.
However, there are a number of policy issues which require analysis at this
time.

For the past few years agricultural production has been curtailed as a matter
of national policy (ex., set aside programs).  It now appears that this policy
is changing and production constraints will be lifted.  The effect will be
to bring more land into crop production.  This land is often marginal and
may require more management to prevent NPS pollution from occurring.  A
coordinated policy will be required to assure that agricultural and environmental
goals are mutually recognized and that programs consistent with those goals
are adopted.

Another issue which has surfaced in recent years is the need to adapt agricul-
tural incentive programs to meet environmental goals.  There is some discussion
in Congress and within the Administration regarding the need for better
coordination of various economic incentive programs with national environmental
goals.  For example; legislation has been introduced to require that fanners
who utilize Federal assistance programs for crop insurance also be required to
adopt a soil and water resource plan.  Support for this concept is growing.
It is important for EPA to analyze the effects of this and other legislative
efforts to develop policy positions and structure its long range strategy to
accommodate changes in national agricultural policy.

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                                        17
Most States, have adopted a non-regulatory approach for their agricultural
nonpoint source control program.  However, a number of States have adopted
various regulatory mechanisms to support the non-regulatory approach.
Evaluation of the various approaches will be undertaken to determine the
effectiveness of each.  It is expected that a period of three to five
years will be required to make a determination of program effectiveness,
A few States have adopted the general permit concept for various NPS activities,
including some related to agriculture.  These initial efforts should be
evaluated to determine their effectiveness and utility in other areas and
for other situations.  Another issue which requires attention is the utilization
of section 313 to assist designated management agencies in their efforts in
working with other Federal agencies to accelerate NPS implementation on public
lands.

While there are a large number of issues which might be studied it is important
to recognize resource limitations in this area.  Only one or two major issues
will be evaluated within a fiscal year.

Program Tasks                                               Scheduled Action

Headquarters

1.   Work closely with USDA, national agricultural and      Continuing
     environmental organizations and others on national
     agricultural policy issues.

2.   Evaluate policy issues relevant to WQM program,        Continuing
     utilize ORD to  assist in analyses and decisions
     on long range issues.

3.   Develop work groups as required to study and           Select issue 1-80
     provide recommendations on  policy changes.             Convene work groups 3-80
                                                            Complete study 7-80

4.   Revise agricultural NPS strategy as  required.          9-80

Regions

5.   Participate in  Headquarters' work groups.              Continuing

Funding Decisions

6.   Provide contract assistance.

Federal Legislative  Initiatives

7.   Provide Agency  recommendations on Administration  oolicy  and  congressional
     legislation.

                                                      ftU.S. GOVERNMENT PRINTING OFFICE: 1980-311-13E/67

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