TMDL
A Review of the EPA’s Assessment of Virginia’s Bay Cleanup Progress
By Neil Saunders
According to the EPA’s recent interim assessment of pollution in the Chesapeake Bay, Virginia is on track to meet its TMDL targets for both nitrogen and phosphorus, but is off track to meet its targets for sediment. Three out of four sectors- agriculture; wastewater treatment plants and onsite systems; and offsets and trading- are under the lower “ongoing oversight” designation, with the remaining sector- urban/suburban storm water- under the intermediate “enhanced oversight.” According to the EPA’s “Next Steps,” urban/suburban storm water may be upgraded to “ongoing oversight” in 2016 provided Virginia completes certain MS4 (define) permitting requirements.
What do these results mean going forward? At this stage in the overall TMDL process, it is an encouraging sign that Virginia, which contributes significant nutrient levels to the Bay, is on track to meets its 2017 targets for nitrogen and phosphorus. It is also encouraging that Virginia appears close to receiving an upgrade in oversight level for the urban/storm water sector, which would place all of the state’s programs under the lower “ongoing oversight” level. Until all practices are in place (which isn’t expected until 2025), this is generally what we hope to see in all of the Bay States’ interim assessments.
Despite the largely positive results, however, there are still areas where Virginia can improve. Sediment levels remain an issue for the state, and will require additional measures to achieve the necessary reductions targets by 2017. This will likely prove challenging, given the fact that the EPA’s current projections of sediment levels over the past decade are higher than were initially anticipated, meaning more sediment has been entering the Bay than previously thought. Another concern is that, although the EPA’s model projections place the state’s agriculture practices on track to meet the 2017 targets within that sector, the fact that Virginia maintains a voluntary approach to nutrient management makes it difficult to accurately measure. The EPA expects that Virginia will work with the Chesapeake Bay Program Office to “project the necessary pace of voluntary agriculture program implementation to stay on track with nutrient and sediment reduction goals and set milestones accordingly.”
The interim “results” are based largely on models that project future nutrient and sediment levels, and incorporate many activities, or practices, that have not yet been implemented. Unless the states actually follow through on their commitments, many of the positive projections will be unrealized. Therefore, it is crucial that the states continue to take any and all additional measures that are necessary to restore the Chesapeake Bay. There is still a long way to go and a lot more that needs to be done.
The interim assessments were released to for the six Bay States’ 2014-2015 milestones. These assessments, which form part of the EPA’s overall accountability framework under the 2010 Chesapeake Bay Total Maximum Daily Load (TMDL) for the entire Chesapeake Bay watershed, play an integral role in evaluating the progress of the Bay States towards meeting their respective pollution reduction targets, and are used to identify areas of concern that require additional measures to meet those targets.
The EPA and Bay States are currently in Phase II of a three-phase, fifteen year process of the TMDL, which means that they are continuing to work towards implementing practices by 2017 that will meet sixty percent of the total pollution reductions needed to clean the waters of the Chesapeake Bay. The third and final phase is to be completed by 2025, and requires 100 percent of the pollution reductions measures to be in place.
A Review of the EPA’s Assessment of Maryland’s Bay Cleanup Progress
By Neil Saunders
According to the EPA’s recent interim assessment of pollution in the Chesapeake Bay, Maryland is presently on track to meet the 2017 TMDL reduction targets for two out of the three major pollutants in the Bay: phosphorus and sediment. Maryland is not on track to meet the target reductions for the third major pollutant, nitrogen. New information obtained by the EPA shows that Maryland is actually contributing more nitrogen to the Bay than previously thought. Therefore Maryland must plan to implement even more effective practices to ensure that it will meet its 2017 targets for nitrogen.
So what do these results mean for the Chesapeake Bay going forward? For one, Maryland is the only state currently under the lower “ongoing oversight” for each sector category that the EPA assesses: agriculture; urban/suburban stormwater; wastewater treatment plants and onsite testing; and offsets and trading. While this is far from encouraging overall, it does demonstrate that Maryland, the state most synonymous with the Chesapeake Bay, it making positive strides towards meeting its reduction targets. The EPA expects Maryland to implement additional measures to reduce nitrogen pollution.
Also, much of the progress made in Maryland, including the recently proposed phosphorus management regulations, still must be implemented to achieve the projected pollution reductions. At this stage in the TMDL process, many of the projections are based on practices that have yet to be implemented. It is critical, that Maryland continue efforts to put practices into place. Sometimes, this is easier said than done. Similar regulations to the Phosphorus Management Tool regulations have been pulled and/or delayed in the past (the environmental community has advocated for stricter phosphorus management for over a decade now), so it is crucial for Maryland and the Department of Agriculture to follow through with implementation.
The interim assessments were released for the six Bay States’ 2014-2015 milestones. These assessments, which form part of the EPA’s overall accountability framework under the 2010 Chesapeake Bay Total Maximum Daily Load (TMDL) for the entire Chesapeake Bay watershed, play an integral role in evaluating the progress of the Bay States towards meeting their respective pollution reduction targets, and are used to identify areas of concern that require additional measures to meet those targets.
The EPA and Bay States are currently in Phase II of a three-phase, fifteen year process of the TMDL, which means that they are continuing to work towards implementing practices by 2017 that will meet sixty percent of the total pollution reductions needed to clean the waters of the Chesapeake Bay. The third and final phase is to be completed by 2025, and requires 100 percent of the pollution reductions measures to be in place.
Manure-to-Energy Plant on the Eastern Shore: A Solution to Phosphours Pollution in the Bay?
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: http://www.baltimoresun.com/features/green/blog/bs-md-poultry-litter-plant-20150320-story.html#page=1
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