Phosphorus Management Tool (PMT)

Phosphorus Levels on Maryland Farmland Lower Than Expected, Still a Significant Risk to Bay Water Quality

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The Maryland Department of Agriculture (MDA) released a report earlier this month on soil phosphorus levels on state farmland from the second half of 2015. The MDA found that 18% of Maryland’s farmland has soils oversaturated with phosphorus. While this percentage is not as high as was expected,** this is still a significant amount of state land contributing to phosphorus pollution in local waters- this is one out of every five acres of farmland statewide; and two out of three acres on the Eastern Shore, according to the Bay Journal (Wheeler, 2016).

Phosphorus pollution from agricultural fields is a major issue in Maryland, given the high number of poultry farms and poultry manure that is applied as fertilizer to nearby fields. When over-applied to farmland, fertilizer high in phosphorous (which poultry manure is), runs off into local waterways, and pollutes the Chesapeake Bay watershed.

Last year’s update to the Phosphorus Management Tool (PMT), and the 2016 Poultry Litter Management Act, which has yet to be voted on in the state General Assembly, are Maryland’s regulatory attempts to solve this pollution issue. These regulations would transport phosphorus-laden fertilizer to farmland elsewhere in the state where phosphorus levels are low. The MDA report stated that 82% of farm fields have lower phosphorus levels, excluding these fields from the PMT regulation- meaning these farms will be allowed to continue to apply fertilizer as usual.

The 18% of fields found to have oversaturated soils (high in phosphorus) will be subject to PMT regulations. This targets farmland on the Eastern Shore- two thirds of farmland on the Eastern Shore will be subject to PMT restrictions- and the Lower Eastern Shore in particular, where 11% of farmland is subject to restrictions on phosphorus fertilizers altogether (Maryland Department of Agriculture, 2016).


**Keep in mind that the report gets its data from samples taken on state farmlands, and data is incomplete. The document does not account for 30% of state soils due to a lack of reporting. Half of missing data comes from the Eastern Shore- the portion of Maryland where poultry production is highest, and soil phosphorus levels are of the biggest concern.





Phosphorus in the Chesapeake: Part VI

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Part VI of the paper includes our final chapter on Maryland’s Phosphorus Management Tool (PMT), as well as the references and appendix for the entire paper.

Phosphorus in the Chesapeake Part V: Maryland Phosphrous Regulations

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Chapter V provides an overview of phosphorus regulations in Maryland.

Phosphorus in the Chesapeake: Part IV

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Part IV of Phosphorus in the Chesapeake includes a regulatory history of cleanup efforts in the Chesapeake Bay.

Phosphorus in the Chesapeake: Part III

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You can find the third part of our Phosphorus in the Chesapeake paper below. This section deals with nutrient pollution in the Chesapeake Bay- its sources and impact on the watershed. For a full version of the paper, please email, and I will provide you with a copy. Thanks for reading!

Coming Soon: Paper on Phosphorus Pollution in Chesapeake Bay

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Over the past several weeks, my colleague and I, Neil Saunders, have written several posts on phosphorus regulations in Maryland. In addition to these posts, we have been working on a paper on phosphorus in the Chesapeake Bay, which looks at the nutrient, how it’s used in agriculture, and how phosphorus acts as a pollutant in underwater ecosystems. I have been researching phosphorus pollution from agricultural activity in Maryland, with a focus on the use of chicken manure as a fertilizer. Neil has been researching the pollution issue from the legislative end, looking at the history of regulations affecting water quality in the Chesapeake Bay watershed, and the history of phosphorus regulations in Maryland. He has described Maryland’s proposed regulations, the Phosphorus Management Tool (PMT), and described how the PMT fits in with broader efforts to curb pollution in the Chesapeake Bay.


We will be publishing our paper to this site in segments, likely a chapter at a time, over the next few weeks. Our hope is to increase understanding of the issue of phosphorus pollution in the Chesapeake Bay, and the impact agricultural activities can have on our local watershed. Phosphorus pollution to the Bay can be reduced considerably with the right legislation in place.

Manure-to-Energy Plant on the Eastern Shore: A Solution to Phosphours Pollution in the Bay?

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The following is a piece from Neil Saunders:

On Monday, March 23rd, the Baltimore Sun published an article about a proposed plan to build a manure-to-energy plant on the Eastern Shore. The plan, teamed by New Hampshire-based AgEnergy USA and local poultry giant Perdue, includes a new $200 million plant to extract energy from chicken manure, which is used heavily as fertilizer on farmland on the Eastern Shore. The proposed plant is believed to provide an economic solution to some of the concerns surrounding the recently announced revised Phosphorus Management Tool (PMT) regulations.

The revised PMT regulations will require farmers to restrict the amount of animal manure that is used as fertilizer based on the levels of phosphorus found in their soils. Excessive phosphorus application can lead to greater amounts of the nutrient reaching nearby surface waters and ultimately the Chesapeake Bay. Too much phosphorus in the Bay causes water pollution and leads to algae blooms and dead zones.

The PMT regulations are part of Maryland’s broader effort to comply with the Environmental Protection Agency’s Chesapeake Bay Total Maximum Daily Load (Bay TMDL), a regulatory framework to coordinate Bay clean-up efforts across the entire watershed area. Unique to Maryland is the heavily concentrated poultry industry on the Eastern Shore. The PMT regulations have been designed to directly address the excessive levels of phosphorus that are reaching the Bay because of the poultry industry’s reliance on phosphorus-rich fertilizers, such as chicken manure.

Although most of the criticism surrounding the PMT regulations centers on the added costs imposed on farmers who would be required to purchase more expensive inorganic fertilizers, which include less phosphorus, another concern is what to do with the excess chicken manure. One solution, which is part of the framework of the PMT regulations, is to transport excess chicken manure from farmlands that are too rich in phosphorus to those farmlands that can use it. The problem with this is that there may not always be a viably marketable method to transport the chicken manure to where it is truly needed. Alternatively, a plant that can take that excess chicken manure and create alternative clean energy from it would not only make good use of the excess manure, but also remove the phosphorus in it from potentially reaching and polluting the Bay.

Implementation of the PMT regulations also plays an important role in completing this project. Recent advances in manure-to-energy technologies create an economic and environmentally friendly method to creating alternative clean energy. In order to invest in such technologies, however, there needs to be greater certainty at the administrative/legislative level to justify project funding. As James Potter, president of AgEnergy USA, says of his proposal in the Sun, “the timing is perfect.”
The proposal is still in the early stages, so there is still some skepticism as to whether the plan will come to fruition. Indeed, past projects similar to the present one have fallen through before. But given the progress made with the recent announcement of the revised PMT regulations and increased attention to the Bay clean-ups efforts around the state, there is reason to believe that this project will play an important role in restoring the Bay.

To access the Baltimore Sun article, visit:

Governor Hogan Moves Ahead with Phosphorus Regulations in Maryland

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After taking down former Governor Martin O’Malley’s proposed phosphorus management regulations this past January, current Maryland Governor Larry Hogan has moved ahead with revised regulations. While the most recent regulations will lead to less phosphorus runoff to the Chesapeake Bay, Hogan’s revisions push back implementation of phosphorus management on Maryland farms, and delay the much-needed cleanup of the Bay.

Hogan’s regulations will put into place the Phosphorus Management Tool (PMT), replacing the current Phosphorus Site Index for many of Maryland’s agricultural fields. The regulation will divide Maryland farmland into three tiers, based on the phosphorus fertility index value (P FIV) (phosphorus levels found in the soil). The highest tier (Tier C) will include farmlands with a P FIV of 450 or greater. These farms with the highest levels of phosphorus in the soil will be the first to begin implementation of the PMT. This means that farmers will have to measure and monitor soil phosphorus levels and apply amounts of manure fertilizer dependent on preexisting phosphorus levels. Farms with a P FIV of 400 or greater will likely have to stop using chicken manure (heavy in phosphorus) all together until the P FIV significantly decreases.
The second tier (Tier B) includes farms with an average P FIV of 300 and greater, but less than 450. The third tier (Tier A) includes farms with an average P FIV of 150 and greater, but less than 300.

The biggest difference between O’Malley’s proposed PMT, and the PMT regulations that Hogan has revised and reissued is timing. Hogan allows the farmers a little more leeway with implementation of the PMT. Farms with a P FIV of 400 or greater, while they must transition to the PMT sooner, are allowed the longest time to reach full implementation. These farms will face the greatest cuts, but will have the greatest amount of time to comply. In addition, the regulation will not begin to take effect until later than O’Malley’s original proposed PMT. Now, the PMT will not be fully implemented until 2022, across all three tiers.

It is good news that Hogan’s office has decided to implement the PMT, and was able to reach a compromise between Hogan’s own proposed regulations, and lawmakers who endorsed O’Malley’s former proposed regulations. However, full implementation of the PMT is still a long way off. Transition from the current Phosphorus Site Index for farms with the highest levels of phosphorus in their soils (tier C) does not begin until 2018; tiers B and A do not begin transition until 2019 and 2020, respectively. While Maryland is not the only state contributing to phosphorus pollution in the Chesapeake Bay watershed, their chicken feeding operations, and the tons of chicken manure used as fertilizer on state croplands means that Maryland contributes a significant amount to phosphorus loads in the Chesapeake Bay. (10% of the phosphorus in the Bay is estimated to come from the Eastern Shore alone, where many of these chicken farming operations take place). I would argue that for the Bay, every little bit helps, and it’s never too soon to begin implementing regulations that will improve water quality in the estuary. Bay health is overall still pretty poor – the Chesapeake scored a D+ on the Chesapeake Bay Foundation’s most current report card- while populations of blue crabs, underwater grasses, and oysters are still at extremely low levels. Changes need to be made now to improve conditions in the Bay in the years to come.

To read the revised regulations for yourself, please visit the Maryland Department of Agriculture. The Baltimore Sun and The Washington Post have also published stories in recent days, if you would like to read more about this issue.