Chesapeake Bay Issues
On November 8, 2010, 30 farm organizations released a unified collection of comments on the Draft Chesapeake Bay TMDL Docket ID No. EPA-R03-OW-2010-0736. The full 60-page response, which can be viewed here, consists of the following five points and conclusion.
- The undersigned support water quality protection and are taking action at the ground level to prevent pollutants from reaching waterways.
- EPA has failed to provide meaningful public review of the Draft TMDL.
- The Draft TMDL is arbitrary and capricious.
- The Draft TMDL is contrary to law.
- The Draft TMDL, if implemented, would result in substantial and widespread economic and social impact.
We conclude that it is not possible for EPA to establish a legally and technically defensible TMDL for the entire 64,000 square mile Chesapeake Bay watershed. This task is beyond the tools provided by the Clean Water Act-CWA. However, establishing separate TMDLs for the 92 impaired tributaries to the Chesapeake Bay is not beyond the authorities and capabilities of the individual watershed jurisdictions. The undersigned urge EPA to withdraw its Draft TMDL, address the flaws in its modeling, and work with the watershed jurisdictions to develop TMDLs for the Chesapeake Bay Watershed that are attainable without causing widespread and significant economic and social impacts on the people who live and work in the Chesapeake Bay Watershed, as well as the people who rely on the food, fiber and fuel that is produced there.
Submitted by:
Agricultural Retailers Association
American Farm Bureau Federation
American Meat Institute
CropLife America
Delaware Maryland Agribusiness Association
Empire State Forest Products Association
Maryland Grain Producers Association
Mosaic
National Alliance of Forest Owners
National Cattlemen’s Beef Association
National Corn Growers Association
National Cotton Council
National Council of Farmer Cooperatives
National Farmers Union
National Milk Producers Federation
National Pork Producers Council
National Sorghum Producers
National Turkey Federation
Responsible Industry for a Sound Environment
South Dakota Agri-Business Association
The Fertilizer Institute
United Egg Producers
USA Rice Federation
U.S. Cattlemen’s Association
U.S. Poultry & Egg Association
Virginia Agribusiness Council
Virginia Farm Bureau
Virginia Forestry Association
Virginia Grain Producers Association
Virginia Poultry Federation
On June 30, 2010, the Senate Committee on Environment and Public Works passed, by voice vote, S.1816 (Cardin-MD): the Chesapeake Clean Water and Ecosystem Restoration Act of 2010. Legislation information is available here by selecting Bill Number near the top of the middle column, entering "S.1816" (with or without quotes) in the box below Bill Number, then clicking on the SEARCH box.
Virginia's Total Maximum Daily Load (TMDL) Plan for the Chesapeake Bay is due to be submitted to EPA the week of August 30.
Position statements and action requests of the Virginia Agribusiness Council and the Virginia Farm Bureau about Chesapeake Bay issues are linked below.