A December Chesapeake Bay Journal article discusses public comments and stakeholder reactions to the Chesapeake Bay Total Maximum Daily Load (TMDL).  The in-depth article cites several concerns that were raised by MACo in its comments to both the United States Environmental Protection Agency (EPA) and the Maryland Department of the Environment, including concerns over costs to local governments, reliability of the Chesapeake Bay Model, and how a nutrient trading program would actually work.

After a quarter century of voluntary measures, most people who commented on the EPA’s draft cleanup plan said they were ready for a tougher approach.

Of the 7,980 submitted comments, about 90 percent supported EPA plans that would cast a broader regulatory net over pollution sources and force states to establish stronger pollution control programs. …

Critics beg to differ. While many say cleaning up the Bay is a noble cause, they fault the EPA for failing to consider the costs of its plan, and dispute its legal authority to implement it. Many said the agency’s goal of completing the cleanup by 2025 was too rushed, especially for expensive actions such as stormwater control.

Strong opposition came from local governments, wastewater management agencies, agricultural organizations and builders, all of whom could face increased regulations and costs. The extent of their concern was highlighted by the large number of national organizations that filed comments, fearing the Bay TMDL will serve as a precedent for plans elsewhere. …

The EPA was widely faulted for making no effort to calculate the cost of implementing the TMDL. Past estimates suggest the cost could be in the range of $15 billion to $30 billion, but several of those who commented said that the final tally could be substantially higher.  …

Much of the criticism of the draft TMDL was focused on the computer models used to estimate the amount of nutrient reductions needed to clean up the Bay, determine where those nutrients originated, and set pollution limits for each state and tributary. Many questioned the accuracy of model estimates, and faulted the EPA for not making available enough information about the models. They said the agency allowed inadequate time to review what information it did present.