AMI Urges EPA to Withdraw Draft Chesapeake Bay TMDL

(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 quality.
  
  
• 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 TMDL allocations.
  
  
• 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 model.
  
  
• 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.

To view the comments, click here: http://www.meatami.com/ht/a/GetDocumentAction/i/64122

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