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States encouraged to curb polluted runoff

Posted on behalf of Jodi Theut <cleanwaternt@igc.org>

Coastal Waters Need Your Help

The program requiring coastal states to have enforceable measures in
place to curb polluted runoff is being revised. Several changes being
proposed by NOAA and EPA will take the teeth out of program if allowed
to go forward as written.

Your sign-on to the draft letter below is needed to help pressure NOAA
and EPA to hold the line and ensure coastal state programs are
enforceable, targeted to prevention and timely.   If you have already
signed on thank you!  If you haven't, please do.

Coastal states are in the final phases of completing their plans and
will begin implementing them next year.  This is not the time to weaken
the program.

Please reply to Coast Alliance:  coast@igc.org   Attention - Nevette
Be sure to include your name, organization, address so we can send you a
final copy.

More in depth, specific comments are being drafted to accompany this
letter.  If you are interested in reviewing them, please let us know. 

Our apologies if you've received duplicate postings in our effort to get
the word out as widely as possible. 

Clean Water!

Here's the letter:
April 15, 1998
Mr. Joseph Uravitch
Chief, Coastal Programs division (N/ORM3)
Office of Ocean and Coastal Resource Management
1305 East-West Highway
Silver Spring, Maryland 20910
Dear Mr. Uravitch:
We appreciate the opportunity to comment on the Proposed Administrative
Changes to the Coastal Nonpoint Pollution Control Program Guidance. In
our communities, we are experiencing severe water quality degradation as
a result of nonpoint pollution; therefore, it is extremely important
that the administrative changes to the Guidance ensure that the Program
meets the intent of the law. 

Unless changed, we fear that the proposed revisions could severely
challenge the effectiveness of the only comprehensive, enforceable tool
we have nationwide to prevent polluted runoff.  To this end we have the
following suggestions:

Enforceable Measures -The Coastal Nonpoint Pollution Prevention Program
strikes a compromise in allowing voluntary measures to be tried, but
then requiring enforceable measures to be implemented if voluntary ones
fail. This is the cornerstone of the program. Program effectiveness will
be jeopardized if clear triggers are not required to determine when
enforceable measures must be implemented. The current proposal does not
identify such triggers. To determine whether voluntary measures are
working, states must establish effective and comprehensive plans to
monitor water quality.

Priority for Pristine Waters and New Sources of Pollution - Nonpoint
pollution prevention plans should not be confined to waterways that are
already severely degraded.  States should establish priorities for
addressing polluted runoff into pristine waters and for new sources of
pollution. This investment will benefit they ecosystem and will surely
save time and money in the future.

Program Timing and Enforcement Authority - The 15 year time-frame
referenced in the Guidance is excessive, and should be shorter. Given
the seriousness, urgency and widespread nature of the polluted runoff
problem, seven to eight years is more reasonable. Ten years should be
the absolute maximum and only in the context of approved extensions. The
Guidance should be amended to reflect this. In addition, enforcement
authority needs to be backed up by the Attorney General or the chief
attorney representing the agency that has jurisdiction over the program.

More specific suggestions on language changes to address these concerns
will follow under separate cover. In order to keep this program from
becoming a paper tiger, it is critical that the above three
recommendations be reflected in the final Guidance.

Thank you very much for your attention to our concerns,


Jacqueline Savitz
Coast Alliance
Washington, DC
Neil Armingeon
Lake Pontchartrain Basin Foundation
Metarie, Louisiana
Sarah Chasis
Natural Resource Defense Council
New York, New York

David Conrad
National Wildlife Federation
Washington, DC
Tim Eichenberg
Center for Marine Conservation
Washington, DC

Brett Hulsey
Sierra Club Great Lakes Program
Madison, Wisconsin
Jessica Landman
Natural Resources Defense Council
Washington, D.C.
Vivian Newman
Sierra Club, Maryland
Marriotsville, Maryland
Cindy Zipf
Clean Ocean Action
Highlands, New Jersey
Linda Sheehan
Center for Marine Conservation
San Francisco, California
Ann Notthoff
Natural Resources Defense Council
San Francisco, California
Ted Morton
American Oceans Campaign
Washington, DC

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