Clean Chesapeake Coalition Asks for Hearing, Withdrawal of Phosphorus Management Tool Regulations

The Clean Chesapeake Coalition, a coalition of 10 Maryland county governments, sent letters on December 16 to both the Maryland Department of Agriculture (MDA) and the Joint Committee on Administrative, Executive & Legislative Review (AELR) regarding the recently proposed Phosphorus Management Tool (PMT) regulations.

The PMT regulations would limit how much poultry and animal manure and sewage sludge can be applied on farmlands in order to control phosphorus runoff into the Chesapeake Bay and local waterways.  Re-introduced at the very end of Governor O’Malley’s Administration, they have been strongly opposed by the agricultural community, especially poultry farmers.

In its 12-page letter to MDA, the Coalition requests that the PMT regulations be withdrawn, arguing that the regulations will have a significant cost to farmers and local economies without reducing an equivalent value in phosphorus pollution.  Instead, the Coalition believes that phosphorus reduction efforts should be focused on larger pollution sources, such as the Susquehanna River and the Conowingo Dam.

In sum, the implementation costs to farmers, the costs to taxpayers, the adverse impacts on local and regional economies, and the overall added strain from more piled on Chesapeake Bay Total Maximum Daily Load (“TMDL”) driven regulations far outweigh the purported reduction in overall phosphorus loading to Maryland waters and other speculative environmental benefits that may result from the PMT regulations.  …

In accord with the Coalition’s objective, the State’s public policy and limited taxpayer funding must be directed towards reducing major sources of phosphorus loading to the Bay (number one being the Susquehanna River), before the State proposes more regulations on less significant sources of phosphorus loading such as farms. This approach will maximize the benefits achieved from the limited public funding and other resources available to improve the water quality of the Bay. This will also safeguard against efforts and expenditures by Maryland farmers that will be marginalized or rendered meaningless as a result of the pollution loading from major sources that are not being appropriately addressed.

Coalition Letter to MDA

In its letter to AELR, the Maryland General Assembly Committee tasked with reviewing the regulations, the Coalition asks AELR to hold a public hearing on the regulations, something that AELR’s co-chair Senator Paul Pinsky has stated there are no plans for.

Pursuant to our written comments to MDA, the Coalition opposes the proposed regulations and requests the Joint Committee on Administrative, Executive, and Legislative Review of the General Assembly (the “Committee”) to schedule a public hearing and consider a hold on the proposed regulations. Our comment submittal to MDA requests that the proposed regulations be withdrawn. Our local economies rely heavily on agriculture. Placing additional economic and operational burdens on farms and related agricultural businesses, which the proposed regulations will do, will negatively impact our already stressed economies.

Coalition Letter to AELR