In the ongoing quest by Martin O’Malley and his administration to burnish his environmental credentials for a possible presidential run, the farmers of the Eastern Shore have been placed squarely in his crosshairs. I suppose this is MOM’s way to catch the fourteen counties not yet affected by his “rain tax,” although some local municipalities are joining in on that fun without waiting on the mandate.
At the beginning of the month, the administration began once again to try and enact the Phosphorus Management Tool, or PMT. The timing was important because the mandated public comment period comes to a close December 31, three weeks before MOM rides off into the proverbial sunset. Appeals for a public hearing have thus far fallen on deaf ears, so the comment period is really the only opportunity to make our voice heard. (Comments should be addressed to Maryland’s Secretary of Agriculture, Earl Hance. His e-mail address is firstname.lastname@example.org.)
Needless to say, the environmentalists are thrilled about this prospect, including a “Maryland Clean Agriculture Coalition” which doesn’t have a single farming-related entity within it. They note the 48,000 pounds (24 tons) of phosphorus the PMT is supposed to alleviate. Remember that number because it comes up later.
The Clean Chesapeake Coalition (CCC) chimed in with its appeal, which states in part:
In furtherance of this objective and in the interests of its individual county members, the Coalition opposes the re-proposed regulations and requests MDA to withdraw the regulations for the reasons explained below. In sum, the implementation costs to farmers, the costs to taxpayers, the adverse impacts on local and regional economies, and the overall added strain from more piled on Chesapeake Bay Total Maximum Daily Load (“TMDL”) driven regulations far outweigh the purported reduction in overall phosphorus loading to Maryland waters and other speculative environmental benefits that may result from the PMT regulations.
In reading their ten-page letter to Secretary of Agriculture Earl Hance, the points made by the CCC appear to be as follows:
- The economic effect on businesses is “grossly understate(d).” While the BEACON study was done in order to satisfy the demand for a study of these effects, its author admits it “was not meant to serve as a comprehensive economic impact study.”
- Remember that 24 tons of phosphorus these regulations address, at a cost of $61 million over six years in increased expenses from farmers and state subsidies? The flow running through the Conowingo Dam spews out 3,300 tons of phosphorus a year – it’s like sticking your finger in the hole in the dike and ignoring the water pouring over the top. Meanwhile, the pond behind the dam has another 130,000 tons just waiting to be scoured out in a significant storm event.
- Phosphorus concentration in tributaries of the Susquehanna River north of the dam is over 3.5 times greater than comparable tributaries on the Eastern Shore.
On that last point, it’s helpful to use the illustration the CCC provides:
Phosphorus is loaded into the Bay at an average annual rate of 3,300 tons (6,600,000 lbs.) from the Susquehanna River; not including what is scoured from the full reservoirs in the lower Susquehanna during storm events and on a more regular basis. Maryland’s annual average phosphorus loading to the Bay from agriculture of 985 tons (1,970,000 lbs.) is minimal when compared to the Susquehanna River.
Earlier this month, Exelon withdrew its request for renewal of its hydroelectric license at Conowingo Dam because more study of its effects on water quality downstream were desired. The utility has agreed to spend up to $3.5 million on studies of water quality downstream. It appears they’ve also become aware of the detrimental effects on the Chesapeake Bay, yet the environmentalists don’t seem to be interested nearly as much in Exelon and in the Conowingo Dam as they are the poultry industry.
A Washington Post story over the weekend noted the controversy, including remarks from Wicomico County farmer Lee Richardson, who seems to be something of a go-to guy when it comes to poultry growers. Many of the reader comments on the Post piece, though, illustrate the divide between the urban and suburban hipster whose idea of poultry is the organic chicken they buy at Whole Foods and the beleaguered grower who already has to comply with numerous state and federal guidelines without having to worry about arrangements to truck chicken droppings out of the area. The Post readers blame the industry itself, saying that its not carrying its weight in addressing the concerns about water quality – bear in mind these are the people who were just fine with enacting a nickel-per-bird “chicken tax” called the Poultry Fair Share Act which was supposed to raise $15 million a year.
In that fiscal note from the Senate bill, it’s noted that the Eastern Shore has “over 700” poultry farmers. For ease of calculations, I’ll set the number at 750. If the cost to farmers is $22.5 million over 6 years – as estimated in the BEACON study – it works out to $30,000 per farmer over the six-year period or $5,000 a year. That’s a significant compliance cost – assuming, of course, it’s really true because government estimates are generally optimistic on revenues and short on expenditures.
So here’s hoping that our efforts can bear fruit and stop this particular piece of madness once and for all. There’s still time to comment.