GO Friday: a phosphorus follow-up

November 22, 2013 · Posted in GO Friday 

Last Friday I told you about the delay in new phosphorus regulations granted by the state of Maryland, giving local farmers some temporary relief from further onerous mandates. In the wake of that piece, District 38C Delegate candidate Mary Beth Carozza sent me a copy of her communication with Maryland Secretary of Agriculture Earl “Buddy” Hance decrying the proposal and its effect on local agriculture. Rather than use it as a postscript to the original, I asked if I could reuse it as an opinion piece and she allowed me to do so.

**********

November 15, 2013

The Honorable Earl D. Hance
Secretary, Maryland Department of Agriculture
50 Harry S. Truman Parkway
Annapolis, Maryland 21841

Dear Secretary Hance:

As a candidate for the newly-created Maryland 38C legislative district, I am joining with our Eastern Shore farm families, members of the Delmarva Poultry Industry and Maryland Farm Bureau, and the local business community to request an immediate withdrawal of the Maryland Department of Agriculture’s proposed regulations related to the Phosphorous Management Tool (PMT) and to allow time for an economic evaluation, as well as, for an extended phase-in of any new PMT tool based on a cost analysis and sound science.

After listening to individual families on their farms and attending the MDA briefings in Salisbury and Easton with approximately 400 concerned citizens at each forum, I strongly oppose moving forward with the proposed PMT regulations. It is simply unacceptable for the Maryland Department of Agriculture and our state government to impose new regulations without knowing the costly economic impact of the proposed PMT regulations and without the science to support that these proposed regulations would even improve the health of the Chesapeake Bay Watershed through reduced phosphorous leaving a farm.

Further, the proposed regulations do not take into account the improvements and efforts made by our Maryland farmers since the 2005 phosphorous implementation date of the Water Quality Improvement Act of 1998. Through Best Management Practices, Maryland farmers are doing more than their fair share in meeting the Chesapeake Bay Watershed goals and have exceeded them by 130 percent. Put simply, Maryland agriculture is the only sector to reach the Environmental Protection Agency’s cleanup goals.

Also, since the EPA is considering changes to the current Chesapeake Bay Model before the critical time period of 2017, which means reassignments of pollution responsibility by state and by sector, it only makes sense for the State of Maryland to wait for accurate model updates before proposing a new Phosphorous Management Tool. The updated Chesapeake Bay Model may indicate that Maryland farmers have already met their phosphorous reduction goals without the need for a new PMT, or the updated research may point to a new approach based on sound science to meeting the Chesapeake Bay Watershed goals.

Even more disturbing is that you, Secretary Hance, may be considering even going further in regulating the Agriculture community if municipalities cannot achieve and/or afford their WIP (Watershed Implementation Plan) by the Year 2017. It is almost impossible to expect the Agriculture community to accept almost the entire burden of the Chesapeake Bay Restoration program.

I believe the members of our Maryland farm community have proven their commitment over the years to meeting our Chesapeake Bay Watershed goals. As we move forward, I respectfully request that the Maryland Department of Agriculture consider this past progress, the economic impact of all proposed regulations, and sound science to ensure that any proposed regulations will improve the health of the Chesapeake Bay. I appreciate this opportunity to share my comments and look forward to working with you.

Sincerely,

Mary Beth Carozza
Candidate for State Delegate
Maryland District 38C

**********

Mary Beth added, “As way of background before writing the letter, I visited a couple local farms (Chesnik’s and Hudson’s), attended the Salisbury and Easton MDA briefings, one of the Tri-County meetings on this issue, and this week’s Salisbury Chamber of Commerce legislative meeting. Our farmers and AG business community really deserve credit for engaging and pushing back.”

It’s rare that the push back works, but sometimes we on the Shore catch a break.

It also should be pointed out that most, if not all, of the events she attended were outside Carozza’s district (although I believe the two farms are within the 38C district boundaries.)

While this piece more or less dropped into my lap, I could always use a Black Friday edition of GO Friday. No, I stay far away from the malls but would like to digest my Thanksgiving turkey without coming up with a new post. So have at it.

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