CBF-PA Submits Detailed Comments On DEP Chesapeake Bay Watershed Plan
In its official comments this week, the Chesapeake Bay Foundation said the Watershed Implementation Plan submitted by the Department of Environmental Protection to meet federal Clean Water Act mandates to cleanup the Chesapeake Bay "demonstrates an inability to deliver on core programmatic items that are critical to meeting our water quality goals."
Matthew Ehrhart, Pennsylvania Executive Director of the Chesapeake Bay Foundation released this statement on Pennsylvania's Plan--
“The purpose of the WIP is to detail how the Commonwealth intends to meet pollution-reduction goals and improve water quality in local rivers, streams, and the Chesapeake Bay. The goal was not only to achieve the right numbers for pollution reduction, but also, and maybe more importantly, to provide reasonable assurance that the job will get done. CBF agrees with EPA that this draft plan fell short on both counts.
“Pennsylvania has the opportunity to create a viable plan for clean water that is tailored to its needs and creates jobs.
“DEP’s draft plan does not clearly articulate the strategy, programs, resources, and timing to be employed to meet the obligations of the TMDL and provide reasonable assurance that our goals will be met. Our conclusion is that the draft WIP is largely a summary of the programs and initiatives that already exist , and that improvements must focus on commitments of additional resources, staffing and prioritization to ensure that the pollution reduction goals are met.
“CBF looks to the Commonwealth to provide specific steps to meet the TMDL, and to establish expectation, outreach, implementation, and compliance mechanisms for all sectors to effectively reduce pollution.
"We hope (DEP's revised Plan) will chart a credible course toward clean water for Pennsylvania's rivers and streams, as well as the Chesapeake Bay."
The Department of Environmental Protection must submit a revised WIP Plan to the U.S. Environmental Protection Agency by November 28.
In its written comments, CBF said, "While Pennsylvania has made significant progress on some specific BMPs, the Commonwealth has demonstrated an inability to deliver on core programmatic items that are critical to meeting our water quality goals. This WIP is Pennsylvania's final opportunity to create a strategy for implement the TMDL that is built by Pennsylvanians, for Pennsylvania, and utilizes the details and efficiencies that are specific to the Commonwealth.
"CBF urges you to consider the following recommendations to construct a credible strategy to accomplish the necessary reductions. Otherwise, the Federal Government will use its Clean Water Act authorities to attempt to accomplish those reductions in Pennsylvania. The outcomes of that approach will be for more difficult and less efficient for the Commonwealth and its citizens."
The CBF comments mirror, in part, a review done by the U.S. Environmental Protection Agency earlier in the year which said Pennsylvania's plan had "serious deficiencies."
The comments make 25 specific recommendations for strengthening the WIP in the areas of agriculture, urban/suburban stormwater management, resource extraction and onsite wastewater disposal.
CBF said Pennsylvania agencies and conservation districts are woefully understaffed to provide the help 2,000 livestock operations and 16,000 farms need to meet their nutrient management requirements. Over 100 new staff are needed to help farmers.
"A significant challenge not resolved in the draft WIP is how PA will commit to a level of resources, particularly for agricultural financial assistance, that is on par with the need. While the federal government has increased conservation funding through Farm Bill programs, farmer demand for financial assistance consistently and substantially exceeds available funding.
"While the state faces historic financial constraints, this does not relieve the state of its obligations under the Clean Water Act. Pennsylvania policymakers did not make sufficient investments in agricultural nonpoint source programs during times of surplus; these were legislative and executive choices that make the current situation all the more difficult. The WIP must describe how this historic funding gap that continues to this day will be corrected."
The comments specifically recommend restoring funding to the Resource Enhancement and Protection (REAP) Tax Credit Program to help farmers achieve their conservation goals.
The PA Farm Bureau has also stressed the need to provide more funding to improve farm conservation programs.
A complete copy of the CBF comments is available online.
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