Five Pennsylvania agricultural organizations, including Pennsylvania Farm Bureau, are urging the Chesapeake Bay Partnership to include more specifics in its proposal for curbing nutrient pollution that enters the bay via the Conowingo Dam.
Specifically, the groups’ joint comments on the proposed Conowingo Watershed Implementation Plan (or C-WIP) call for the plan to be revised to include much more detail on how its pollution reduction goals will be achieved and how those efforts will be funded. The farm groups also urged the CBP to involve Pennsylvania farmers and state officials in its planning process since the proposed plan would put responsibility for achieving its goals almost entirely to the Keystone State—and the agriculture sector in particular. The groups also warned that finalizing the plan without addressing strategies and funding could deal a significant setback to efforts already underway in Pennsylvania to improve water quality in the Chesapeake Bay Watershed.
“Pennsylvania farmers have been leaders in implementing conservation practices to reduce nutrient and sediment pollution in the Chesapeake Bay and are continuing to do even more,” PFB President Rick Ebert said. “We understand even more work is needed to respond to pollution entering the bay via the Conowingo Dam. But we are concerned that the proposed C-WIP’s approach of putting that responsibility almost entirely on Pennsylvania without clearly identifying how those goals can be reasonably achieved or financed will jeopardize our ongoing and future efforts to improve water quality. We are urging the C-WIP Steering Committee to revise its proposal following the principles that have guided Pennsylvania’s planning related to the Chesapeake Bay: Establishing clear and realistic strategies, identifying funding to achieve goals, and working in partnership with the farmers who will ultimately implement the plan at the ground level.”
Other agricultural organizations, in addition to PFB, that jointly filed the comments were Pennsylvania Co-operative Potato Growers, Pennsylvania Corn Growers Association, Pennsylvania State Grange, and Pennsylvania Vegetable Growers Association.
State agencies—including the Pennsylvania departments of Agriculture, Environmental Protection, and Conservation and Natural Resources—expressed similar concerns in separate comments they jointly filed on the C-WIP. The state agencies raised particular concerns about funding, the need to engage stakeholders—particularly farmers—and the potential for undermining existing efforts.
“How will new outreach tools and strategies for the Conowingo WIP address and mitigate potential stakeholder fatigue from multiple Chesapeake Bay WIPs and from changing targets and goals due to impacts from climate change or modeling changes?” the state agencies wrote. “To maintain and expand critical stakeholder engagement and partnership in the development and implementation of the Conowingo WIP, we believe it will be important to look for opportunities to reinforce the fact that the work done to date by the agricultural community has made a difference in cleaning up the Chesapeake Bay and that we are continuing to move in a positive direction.”
Pennsylvania and other states in the Chesapeake Bay Watershed are on a federally mandated timeline to reduce nutrient and sediment pollution in the bay. Pennsylvania is in the process of implementing its Phase 3 Watershed Implementation Plan (WIP), which details how the state will reach pollution-reduction goals for 2025. Pennsylvania’s plan takes a ground-up approach with counties in the watershed establishing localized action plans for implementing farm conservation measures and other practices to meet water quality goals.
The Conowingo Dam, located near the mouth of the Susquehanna River in northern Maryland, has historically played a role in trapping nutrients and sediment before they reach the bay. Calculations used to determine states’ pollution-reduction goals in 2010 took that into account. Research since then has found that the dam is reaching its capacity to trap pollution. The proposed C-WIP was developed by a committee of staff from the CBP and partner states with the intent of planning additional, upstream pollution reductions to offset the additional nutrients—particularly nitrogen—released by the dam.
The proposed C-WIP calls for 95 percent of its proposed nitrogen load reductions to come from Pennsylvania, with 90 percent of those reductions coming from the agricultural sector. Reaching the goals outlined in the plan would cost an estimated $53.3 million per year, $45.44 million of that related to implementing additional farm conservation practices.
“With the extensive conservation measures that must be performed and the significant additional costs that must be incurred in achieving C-WIP’s envisioned goals, the pervading question to be raised and answered is how can achievement of these goals be practically accomplished and feasibly financed,” the farm groups wrote in their joint comments. “Yet the Draft C-WIP provides essentially no answer to this question.”
The C-WIP Steering Committee did recently issue a draft financing strategy after opening the draft C-WIP to public comments. PFB is reviewing that proposal.
The farm organizations also voiced concerns that the proposed C-WIP could interfere with Pennsylvania’s efforts to improve water quality as part of its Phase 3 WIP by competing for the same financial and administrative resources. And they cautioned, effectively moving the goal post for Pennsylvania without seeking greater public input and buy-in could undermine the enthusiasm and spirit of cooperation surrounding Pennsylvania’s ongoing efforts.
“Placing a new layer of performance obligations now on Pennsylvania will further deflate the will and confidence of Pennsylvania officials and stakeholders to more proactively pursue and implement the Commonwealth’s Phase 3 WIP,” the groups wrote. “We…believe that a ‘final’ release of the C-WIP in its current or similar form at this time would be a serious blow to the momentum in spirit and personal commitment among Pennsylvanians to materially improve water quality in Pennsylvania’s Chesapeake Bay Watershed.”