On behalf of Plum Creek, I am here to express strong opposition to the Environmental Protection Agency's proposed revision to the Water Quality Planning and Management Regulations.
First, we believe the proposal exceeds EPA's legal authority. EPA's attempt to bring nonpoint sources under the Total Maximum Daily Load program directly contradicts the Clean Water Act, as it does nothing to improve water quality. Congress never intended for forestry to be regulated as a point source, and policy changes such as this proposal should be made only by Congress.
Second, we believe the proposal will result in a tremendous increase in bureaucracy and red tape without a commensurate increase in water quality. Significant resources would be drained from not only large landowners like Plum Creek, but thousands of small landowners growing and harvesting trees on their property -- jeopardizing the health and vitality of the timber industry.
Lastly, Plum Creek and the entire forest products industry have made tremendous strides in the improvement of water quality through the use of Best Management Practices or BMPs for forestry. These BMPs have proven to be highly effective in controlling pollution from forestry activities.
The current EPA proposal is unwarranted and should be withdrawn.