The Virginia Grain Producers Association (VGPA) has joined 29 agricultural and forestry organizations in submitting comments to the Environmental Protection Agency (EPA) regarding water quality regulations it is proposing for the Chesapeake Bay.
VGPA also submitted comments separately specifying concerns of grain producers. Both comments outline the agriculture and forestry community’s concerns with the Agency’s draft Total Maximum Daily Load (TMDL) requirements for the Bay, while calling attention to the significant contributions of agriculture to water quality improvement in the Chesapeake Bay.
“Farmers work every day to make their operations more efficient, not because of regulations or a new law, but because it is the only way we can continue farming. As we noted in our comments, ‘Mandates do not achieve water quality but, willing participants do.’ The agriculture community supports water quality protection and has already made significant progress in improving our region’s waters.” said VGPA President Eugene Longest.
“In fact, Virginia agriculture has already met 52 percent of our nitrogen goals and 50 percent of phosphorus and sediment goals all through voluntary measures and incentive based programs.”
“VGPA has asked repeatedly for reality-based, sound science to go before any new regulations, yet EPA continues forward with the TMDL standards with admittedly inaccurate information.”
VGPA comments state that EPA’s models do not account for many of the voluntary agricultural and forestry practices that are currently being employed in the Chesapeake Bay watershed, and as a result, the draft TMDL fails to acknowledge the success that has been achieved in the Bay by the efforts of the agricultural community and others.
Cites lack of transparency
In addition to highlighting EPA’s oversight of the agriculture community’s environmental stewardship efforts within the Bay, the comments criticize the Agency’s lack of transparency regarding the draft TMDL and the models used to develop the requirements.
“Farmers continue implementing best management practices (BMP) but with no assurance from EPA these practices will actually achieve the desired water quality goals. In fact, EPA has provided no assurance that the Draft TMDL standards are even achievable with today’s population and economy. We have not seen any economic analysis of what this clean-up effort will cost taxpayers or how it will affect the food, feed and fuel supply provided by Virginia’s farmers,” said Longest.
“The Agency has made it difficult for any farmer to understand what impact the TMDL will have, because EPA’s own information is constantly changing; providing a moving target. This has prevented a meaningful dialogue about the costs, benefits, and challenges for policy makers, the public and agriculture.”
Both VGPA and industry comments address EPA’s needed authority to implement such measures on Virginia taxpayers, citizens, land and waters. Comments state that EPA is clearly stepping outside the authority granted to them by Congress in the Clean Water Act.
“This is the most complicated, largest TMDL ever attempted. Establishing this type of precedent especially, with admittedly flawed data, is not the intent of the Clean Water Act,” said Molly P. Pugh, VGPA Executive Director. “In our comments, VGPA states, ‘EPA must not attempt to mandate “one size fits all” regulations and expect water quality goals to be met. On behalf of our members, VGPA requests that EPA produce proof of BMP impact to the Bay, provide a full economic analysis of the TMDL standards, provide the legislation that outlines EPA authority over the states and most importantly, provide for public review the full and complete data used to create the TMDL standards.’ Agriculture and forestry are Virginia’s top economic sector. Without creating a feasible balance between economic growth and environmental goals, Virginia’s economy will be devastated. That is an unacceptable trade-off for any goal,” said Pugh.