EPA Releases More Detailed List Of PA Chesapeake Bay Cleanup Plan Deficiencies
The U.S. Environmental Protection Agency this week released a more detailed review of what it called "serious deficiencies" in Pennsylvania's plan to reduce nutrient and sediment pollution going to the Chesapeake Bay.
The comments followed up on a preliminary review last week which found Pennsylvania's plan failed to demonstrate an ability to actually fully deliver necessary and promised pollution reductions, the plan lacks specific funding, policy and program commitments to fully comply with pollution reduction milestones.
At the same time, EPA released a draft Chesapeake Bay Total Maximum Daily Load (TMDL), a mandatory plan designed to restore the Chesapeake Bay and its streams, creeks and rivers.
EPA opened the comments by saying, "EPA commends Pennsylvania for involving stakeholders through the WIP Management and Workgroup teams during development of the draft Phase I WIP. Stakeholder input is evident through connections being made in the WIP between local priorities and Bay TMDL implementation, such as rural economic development opportunities through innovative new agricultural technologies.
"EPA also appreciates the overarching themes of milestone implementation and tracking; innovation and trading; and improved compliance, especially with agriculture and stormwater, that are articulated in the WIP’s introduction. However, there was insufficient detail on quantifying the gaps, proposed gap-filling strategies and associated actions, and timeframes to assure that the necessary reductions would be achieved.
"EPA is concerned that the WIP falls short in meeting the nutrient targets, given the large amount of reductions Pennsylvania is responsible for to meet the Bay TMDL."
Among the steps EPA said need to be taken are adopting a limit of technology standard for wastewater treatment plants, assigning specific nutrient reduction standards to urban stormwater management programs, controlling erosion and sedimentation on all construction, requiring more permits for farming operations and more.
Among the EPA comments were--
-- PA WIP very weak compared to the amount of N, P, and sediment PA must reduce. Strategies do not equate to the reductions PA is proposing, nor provide reasonable assurance that nutrient and sediment targets will be met by the 2017 and 2025 milestones;
-- Agriculture: No detailed program capacity description, gap analysis, and strategies/timeframes to fill gaps;
-- Agriculture: No detailed plan for how to ensure compliance with existing regulatory programs;
-- Urban Stormwater: Most of the strong stormwater concepts described in the WIP are in policies, guidance and manuals, with questionable enforceability and accountability;
-- Wastewater: Many permits that have been issued with limits that will not become effective until after 10/01/2010, some as late as 2014, contrary to the permit schedule provided in the WIP; and
-- Growth: Offset program is not water quality-oriented for agricultural credit generation. Offset and trading credits cannot be generated until source achieves baseline TMDL compliance. There is no discussion how the “core four” practices meet base line TMDL compliance.
The Chesapeake Bay Foundation issued a statement last week saying Pennsylvania's Watershed Implementation Plan failed to meet EPA standards and said many more resources were needed to meet water quality cleanup standards.
The PA Farm Bureau also stressed the need to provide more funding to improve farm conservation programs.
Four public meetings to take comments on Pennsylvania's Chesapeake Bay Watershed Implementation are scheduled from October 18 to 21.
A copy of the EPA's detailed comments are available online.
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