AF&PA; is the national trade association of the pulp, paper and forest products industry. We represent approximately 84 percent of paper production, 50 percent of wood production and 90 percent of industrial forestland in the United States. Nationwide, there are more than 9 million non-industrial private landowners who own 59 percent or approximately 288 million acres of the total productive private timberland. Most of these landowners have holdings of less than 100 acres. In comparison, forest products companies own 15 percent of the nation's timberland and rely heavily on the fiber supply provided by these small landowners.
My name is John Godbee and I am Environmental Manager of Forest Resources for International Paper. International Paper is a major manufacturer of printing papers, packaging and wood products. We are the largest private forest landowner in the country with over 7.5 million acres. We also have 191 operations in 46 states located throughout the U.S.
While, as stated, AF&PA; also represents the manufacturers of the country's paper supply, I will confine my remarks to our forestry activities.
Upon release of the February 1998 Clean Water Action Plan, the forest products industry's initial action was to: 1 ) evaluate the federal government's proposals in light of what actually is going on in the private sector; 2) determine if there was consistency with industrial and non-industrial private landowner programs; and 3) examine if the Plan recognized private sector initiatives that are making progress in meeting the goals of the Clean Water Act. After careful review, we believe the Plan is heavily weighted toward federal prescriptiveness, rather than recognizing and promoting successful state and private sector initiatives that are making a significant difference in water quality protection.
Back in 1994, members of AF&PA; committed themselves to the Sustainable Forestry Initiative (SFI)SM. The SFI program is a comprehensive system of principles, guidelines and performance measures that integrates the perpetual growing and harvesting of trees with the protection of wildlife, plants, soil, air and water quality. All AF&PA; member companies are required to comply with the SFISM or their membership will be terminated, as has occurred for some. Among the water quality commitments that AF&PA; members make in subscribing to the SFI is the agreement to:
Meet or exceed all established Best Management Practices (BMPs);
Meet or exceed all applicable state water quality laws, regulations and the requirements of the Clean Water Act for forestland; Establish and implement riparian protection measures for all perennial streams and lakes and involve a panel of experts at the state level to help identify goals and objectives for riparian protection; Individually, or through cooperative efforts, provide funding for water quality research.
In 1997, AF&PA; member companies began reporting on the number of acres and miles of streams that are enrolled in wildlife and fisheries agreements with conservation groups and public agencies that specify on-the-ground management practices. Almost 11 million acres, representing 20 percent of the total acres in the SFI program, and 4,286 miles of stream have been enrolled in these agreements.
As you can tell from these commitments, this effort represents the industry's own Clean Water Action Plan and it has the full backing and support from an Independent Expert Review Panel that monitors our progress. The Panel consists of members from the conservation, environmental and academic communities, federal and state representatives and includes the Chief of the U.S. Forest Service and an EPA official.
Far from being a program based in Washington D.C., the SFI program has established State Implementation Committees in 32 states that receive more than $3.1 million from AF&PA; members and allies to foster their responsibilities to promote SFI principles.
While industrial forestland constitutes approximately 15 percent of the nation's forested acreage base, AF&PA; members are also committed to expanding and promoting sustainable forestry into the broader forestry community. For example, in 1997:
Over 9,600 loggers and foresters completed comprehensive training programs that include forestry education with over 20,000 loggers trained since 1995; More than 86,000 landowners across the country received information on the SFI program; 99 percent of the estimated 9,700 member company employees who exercised SFI duties were fully trained in sustainable forestry practices.
As the federal agencies involved in water quality and forest management issues work with state agencies in implementing programs to protect water quality from the impacts of land-based activities, we would hope that they work with the private sector in identifying areas that will compliment our commitments.
As an example, we believe that implementation of forestry best management practices (BMPs) through state-sponsored and directed programs are the key mechanisms to protecting water quality in streams and lakes. Eighteen states have recently reported that overall compliance with BMPs across all ownerships - industry, private landowners and public- averaged 85 percent. Although these results are encouraging, we can do better through promotion of BMP training and monitoring effectiveness. Therefore, AF&PA; and our regional and state forest associations strongly support funding for states to conduct BMP effectiveness audits of forestry practices. Numerous studies show that when BMPs are implemented, water quality is maintained. The more recent studies conducted in Florida, South Carolina and Idaho illustrate that when BMPs are implemented, the biological, physical and chemical integrity of the nation's waters are protected. We can provide copies of these studies and others that document our claims. As we move forward, we would encourage federal and state officials to establish a dialogue with the SFI state implementation committees and support ongoing efforts in the forestry community to reach out to forest landowners, loggers, consultants and practicing foresters on promoting BMP implementation to protect water quality.
At this point, I'd like to shift your attention briefly to two issues that many in the forestry and other nonpoint source communities believe have the possibility of imposing onerous and incompatible requirements on land management practices. First, the EPA is in the process of issuing proposed rules to revise the total maximum daily load (TMDL) program under Section 303(d) of the Clean Water Act. The TMDL program is designed to assure attainment of water quality standards by requiring the establishment of loading targets and allocations for waters that are not in attainment with those standards. The Clean Water Act and its implementing regulations require states to identify these impaired waterbodies and for EPA to approve the state lists and state- developed TMDLs for each pollutant. While we await issuance of the proposed rules, we remain very concerned with the lack of sufficient data used to list the 21,000 waterbodies identified by states and approved by EPA as impaired and the methods used to determine which activities have caused impairments. Even after these waters have been designated as impaired, which we believe requires a scientific water quality monitoring and sampling program conducted over time and seasons, the determination of actual daily loads to waterbodies and their allocations to individual activities in a stream segment is extremely complex and expensive. We do not believe this is a practical solution and should only be undertaken as a last resort where absolutely necessary and where significant resources are available.
Second, under the Clean Water Action Plan (CWAP) announced in March 1998, the Environmental Protection Agency (EPA) is beginning the process of re-examining the regulatory, legal and statutory exemptions and definitions for defining runoff from forest roads as a nonpoint source activity. While the industry supports the Agency's review on the effectiveness of forest road construction best management practices, their scientific underpinnings and how they are developed and implemented to attain and maintain water quality, we do not believe the Agency has the statutory authority to revise the regulations which recognize forest roads as nonpoint sources. Under the Federal Water Pollution Control Act and its amendments in 1977 and 1987, Congress cleary recognized forest roads as a nonpoint source category. In fact, several recent federal cases specifically recognize the different approaches taken by Congress to regulate point sources on the one hand and to address nonpoint sources on the other. Where roads were at issue, these courts upheld their definition as a nonpoint source.
I have one final remark, Mr. Chairman, regarding EPA's request for additional authority and money to run a new nonpoint source pollution control program under the Clean Water Act. All states with an active forestry presence have state and EPA-approved BMP forestry programs tailored to the conditions and forest types of the state. A federal agency prescribing forestry BMP programs to tell us what practices we can and cannot do would not be helpful. Likewise, we are not seeking federal financial assistance to implement BMPs. We do this as standard business and operating practice. What we do need is forestry BMP effectiveness funding for states to document their well-designed and scientifically-based programs and additional BMP research support for continuous improvement.
In conclusion, as EPA proceeds in implementing any of the key actions related to forest management in the Clean Water Action Plan, we hope that the agency recognizes the significant commitment of resources and efforts the private sector has launched in promoting water quality protection.
Again, I thank you for the opportunity to present these remarks, and I'd be glad to respond to any questions.