STATEMENT OF SENATOR BOB GRAHAM
SENATE SUBCOMMITTEE ON FISHERIES, WILDLIFE, AND WATER
HEARING ON EPA'S PROPOSED REGULATIONS ON "TOTAL MAXIMUM DAILY LOADS" MARCH 23, 2000

Mr. Chairman, thank you for the opportunity to speak to you regarding the EPA's proposed Total Maximum Daily Loads (TMDL) regulations.

I am also pleased to extend a welcome to Mr. Jeff Pardue, of Florida ,who is the Director of the Environmental Services Department for Florida Power Corporation. Mr. Pardue will be presenting testimony to the Subcommittee on behalf of Florida Power Corporation, the Edison Electric Institute and the Clean Water Industry Coalition.

Mr. Chairman, if I look back over the past several decades it is incredible how far we have come in achieving real progress on environmental protection with respect to air, water, solid and hazardous waste matters.

I am concerned, however, with the proposed TMDL regulations. In a letter to the EPA Administrator dated January 19, 2000, Florida Secretary of Environmental Protection David Struhs identified several issues of concern with the proposed TMDL regulations.

Mr. Struhs expressed the view that the responsibility for development of non-point source controls rested with the states and that the proposed regulations represented a significant, unwarranted expansion of the regulatory approach to control such sources.

He also noted that EPA should reconsider its proposed regulatory approach, if only for practical reasons in view of the large number of non-point sources that would need to be regulated.

For these reasons, and others discussed in the letter to the EPA Administrator, Mr. Struhs suggests that EPA adopt a voluntary, technology based approach to non-point source control.

Finally, Mr. Struhs notes that the State of Florida adopted its own TMDL related legislation which prescribes a comprehensive voluntary strategy for the non-point source component of waterbody TMDL's.

The Florida TMDL legislation establishes incentives for non-point source sources implementing best management practices.

I urge the EPA to review the State of Florida comments on the proposed TMDL regulation.

Thank you Mr. Chairman. I look forward to working with the Subcommittee on this important issue.