Vaughns’ Farm and Orchard
1014 Old Stage Road
Central Point, OR 97502
February 14, 2011
Andrea Matzke
Oregon Department of Environmental Quality
Water Quality Division
811 SW 6th Avenue
Portland, OR 97204
Dear Andrea:
I am a Farmer/Orchardist and have been farming for 18 years in the Jacksonville/Medford area. I am very concerned about the proposed new Best Management Practices (BMPs) for nonpoint sources of pollution by agriculture and how increased regulation will affect production agriculture and small farms in Oregon and my land.
I have been involved, as a member of the Local Advisory Committee (LAC), in revision of the Inland Rogue Agricultural Water Quality Management Area Plan since 2008. The plan lays out Best Management Practices and Educational Outreach program for the area landowners. The emphasis is on coordination and education along with the rules for enforcement. The expert skills of the local NRCS (Natural Resources Conservation Service) and Soil and Water Conservation district engineers and resource technicians are used in development of Land Management Plans for landowners.
I believe that this effort has significantly improved water quality in Oregon as it relates to pollution from non-point agricultural sources through Educational Outreach (the many educational programs conducted by Jackson Soil and Water Conservation District) and by helping landowners manage their land and institute Best Management Practices. They have developed many management plans with individual landowners and numerous watershed projects (www.jswcd.org ).
I believe that rules implemented by Agricultural Water Quality Management Area Plans should be based on best available soil, crop and livestock science that demonstrates impacts on water quality and is reasonable as well as practicable to modern production agriculture.
I support regulation and enforcement of farming practices coming directly from ODA and no other agency. While Oregon statute requires compliance with water quality standards adopted by the EQC (Environmental Quality Commission), these laws do not provide direct enforcement authority over agriculture landowners to either the EQC or DEQ.
If the DEQ, or other agencies, move forward with the proposed rulemaking language, I believe agriculture landowners and land managers, including myself, could be subject to unreasonable and economically inefficient rules that will regulate farms and ranches out of business in Oregon.
I oppose DEQ’s execution of “Implementation Ready” TMDLs (Total Maximum Daily Limits). This infringes upon Oregon Revised Statute 568.912(1) that gives ODA sole authority to regulate farming practices and adopt rules that constitute the only enforceable aspects of a water quality management plan. I believe this attempt by DEQ to directly regulate farming practices is in direct conflict with Oregon law.
Sincerely,
Signed J. Edward Vaughn
J. Edward Vaughn