The Watershed Implementation Plan Subcommittee and the Land Use and Growth Policy Subcommittee of the State Water Quality Advisory Committee (SWQAC) jointly submitted a letter on January 24 to Secretary of the Environment Robert Summers commenting on the State’s proposed Accounting for Growth (AFG) Policy.  The letter has also been preliminarily endorsed by SWQAC.

The State is required to create an AFG Policy under the federal Chesapeake Bay Total Maximum Daily Load and the State’s Sustainable Growth and Agricultural Preservation of 2012.  The AFG Policy will outline how nitrogen and other water pollution from new growth must be offset.

As previously reported on Conduit Street, MACo has submitted several sets of comments on the AFG Policy and although not a member of SWQAC, MACo Legal and Policy Analyst Les Knapp did offer input on the SWQAC letter.  The letter contains 16 comments regarding the AFG Policy, many of which mirror MACo’s previously submitted concerns, including support for a 1-year delay in the implementation of any portion of the AFG Policy to allow for further development of a nutrient offset trading program; opposition to mandating county government assumption of operation and maintenance of offset best management practices; support for the use of area-specific loading rates with respect to on-site wastewater systems; and support for the use of regional loading rates with respect to stormwater loading.

The letter also diverges from several of MACo’s positions.  For example, the letter supports limiting nutrient offset trading to the same 8-digit or 6-digit watershed, rather than at the county or statewide level.  Some of the letter’s other comments discuss concerns on fee-in-lieu implementation, the Chesapeake Bay Model and calculation of loading, and pubic outreach efforts.