In comments to the U.S. Environmental Protection Agency (EPA), National Association of Conservation Districts (NACD) President Gene Schmidt stressed that the federal role in water resources management should be one of cooperation. The comments are in response to EPA's most recent draft guidance to states and territories on awarding 319 grants under the Clean Water Act (CWA) for implementing Nonpoint Source (NPS) management programs. Conservation Districts use the 319 NPS Program to increase the utilization of agricultural best management practices (BMPs) such as buffer strips, conservation tillage, and nutrient management, as well as to implement low impact development and storm-water management practices to protect urban water quality. 

When it comes to EPA's treatment of Total Maximum Daily Loads ("TMDLs") and the 319 NPS program, efforts addressing impairments should be locally-led. "The best way to promote and implement conservation is through locally-led efforts," said Schmidt. "Many states are already successfully leveraging non-federal money, along with Farm Bill conservation program funding and 319 grant funding, to achieve significant water resource goals."

NACD supports the EPA's proposal to remove procedural requirements in deference to locally-led conservation efforts and to encourage local-level innovation. The association also endorses EPA's increased focus on coordination with the U.S. Department of Agriculture (USDA), as well as the agency's efforts through the National Water Quality Initiative ("NWQI") to target highest priority areas and to nurture community-based actions on watershed scales. 

Because Section 319 BMPs address the same general issues for large and small watersheds, focusing less on watershed management plans at the federal EPA level, and more on the state and locally-driven planning and implementation level will be more productive. State agencies and conservation districts should be involved in the development of NPS state plans, serving as the "boots on the ground" in terms of planning and project implementation. 

NACD firmly believes in allocating as many resources as possible to putting conservation practices (BMPs) on the ground while recognizing that our ability to measure and describe success will be critical to achieve greater funding levels in the future. 

Conservation districts are experienced in working with NPS programs, and use 319 funding as part of the effort to put conservation practices on the ground. Nationwide, there are many examples of conservation districts making significant contributions toward setting priorities and implementing actions to achieve water quality goals. To view the full comments, click here.