That' s why we use Best Management Practices - guidelines for how to conduct forestry in the most environmentally-friendly manner possible. And these BMPs have to be worked out on a local level. The solutions that work for a watershed in western Oregon will not work for one in eastern Oregon, and certainly not for one in Kansas. Local people need to be involved, which happens best through state-run incentive-based programs rather than the kind of top-down Federal mandates implied in these proposed rules
In Oregon, many of the streams which would be subject to EPA's new TMDL rules contain endangered fish, and landowners are already struggling with the legal requirements of the Endangered Species Act, so doesn't it make sense that these requirements be coordinated?
I'd like to suggest a more workable framework for managing non-point pollution, one which will be more scientifically and legally defensible, and will provide environmental benefits for endangered species and water quality while minimizing the burden on landowners. My approach would involve: developing a one-stop shopping approach for landowners, so that they can fulfil their Clean Water Act and Endangered Species Act obligations at the same time. I'd like to see the agencies coordinate so that a landowner can use the same land management plan to qualify for a Habitat Conservation Plan and a TMDL plan; increased funding for the use of Best Management Practices to control non-point pollution; and allowing flexibility in TMDL plans, so that as scientists study how Best Management Practices are actually working in a particular place the plan can be rewritten.