AMI Urges EPA to Withdraw Draft Chesapeake Bay TMDLTuesday, November 9, 2010
(American Meat Institute)
AMI joined a coalition of 30 agricultural and forestry organizations in submitting written comments to the Environmental Protection Agency (EPA) urging the agency to withdraw its Draft Chesapeake Bay Total Maximum Daily Load (Draft TMDL) citing numerous issues in the draft document and the potential for widespread economic and social impact.
In the comments, the organizations stressed the following points.
- In the Chesapeake Bay watershed,
agriculture and forestry organizations are
among those who have made possible the
significant reductions in nutrient and sediment
loadings to the Chesapeake Bay that has
occurred over the past 25 years. However,
EPA’s models do not account for many
agricultural and forestry practices that are
currently being employed to protect water
- EPA has failed to provide meaningful
public review of the Draft TMDL. The
Draft TMDL does not provide the public with
information on the assumptions that have been
made in the modeled scenarios that led to the
- The Draft TMDL is arbitrary and
capricious. The TMDL allocations are
based on data that EPA acknowledges are flawed.
EPA acknowledges that the allocations are
likely to be revised in 2011 when better data
is available and incorporated in the watershed
- The Draft TMDL is contrary to law.
EPA is attempting to exceed its Clean
Water Act (CWA) authority in the Draft TMDL by
asserting that it has the authority to issue a
TMDL over the objections of a watershed
jurisdiction, even though it has not gone
through the formal process set forth in the CWA
of disapproving a state TMDL.
- The proposed TMDL, if implemented, would
have a substantial and widespread adverse
economic and social impact. To date, for
the Chesapeake Bay, EPA has only considered
changes to water quality standards when
modeling has showed the standards are not
achievable even if EPA could turn the clock
back to the 1600s and impose complete
reforestation on the Chesapeake Bay watershed.
The Draft TMDL would result in
significant adverse impacts on agricultural
production, with significant impacts on the
availability of affordable food.
“The undersigned urge EPA to withdraw its Draft TMDL, address the flaws in its modeling and work with the watershed jurisdictions to develop TMDLs for the Chesapeake Bay Watershed that are attainable without causing widespread and significant economic and social impacts on the people who live and work in the Chesapeake Bay Watershed, as well as the people who rely on the food, fiber and fuel that is produced there,” the comments conclude.
the comments, click here: