From: Marie Bowers
Sent: Mon Mar 21 15:37:37 2011
To: ToxicsRuleMaking
Subject: Ag Water Quality Management Act
Importance: Normal
To Whom it May Concern:
The Oregon Department of Environmental Quality (DEQ) wants to improve a system that is not broke and will disrupt the current way of efficient and effective pollution management of the state's greatest natural resource: water.
Eighteen years ago the natural resource community, the environmentalists, the DEQ and the Oregon Department of Agriculture (ODA) came to a consensus on how agricultural non-point pollution sources were regulated and managed. The Water Quality Management Act (AgWQMA) mandated that a landowner prevent and control water pollution from agricultural activities. The ODA, the decided regulatory agency of the act, with the help of 45 Soil and Water Conservation Districts developed plans and rules for 39 identified watersheds. Each watershed has a committee made up of local stockholders that oversaw rules and plans.
The watershed management structure outlined by the ODA works. It gives the locals control to adjust and apply best management practices for the area and for the watershed to prevent non-point source pollution. Oregon is a diverse state in terrain, weather and agriculture so what works for one area does not for another. That's why the ODA's AgWQMA structure works great because the management and plans are based local by the people who know the area the best.
No problems have arisen from the current system. However, the DEQ wants to amend the AgWQMA. They want to specify the definition of Best Management Practices for the state and have local watersheds conform to the state's definition. How is it a best management if it's not controlled at a specific local level? Also, they want to change how Total Maximum Daily Loads (TMDLs) are calculated. TMDLs are based of human fish consumption to measure water pollution. Currently, the TMDL is based on a consumption 6 grams of fish per day certain interest groups want to raise it to 175 grams per day. That's 2 servings of fish per day 365 days per year! Ridiculous! Who eats that much fish?
I acknowledge that the AgWQMA and the DEQ's proposed rules have a lot of layers. However, why change the AgWQMA? Oregon has some of the cleanest waters in the nation. Obviously something is going right. The ODA, farmers, ranchers and foresters have proven that they can successfully manage the environment and non-point pollution sources. There is no need for additional regulation.
Sincerely,
Marie Bowers
Oregon Women for Agriculture
1st Vice President, Legislative Chair
541-914-0613
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