During the TMDL public forum event hosted by Rep. Lynwood Lewis at the Eastern Shore Community College Elaine Meil, Director of the ANPDC, promised to post the Shore's Watershed Implementation Plan on their website for public comment before submitting it to the State (this is not a requirement of the process, but it seems like a really good idea). While this was never done, many of us still submitted comments. This is what I had to say on the matter:
To Whom it May Concern,
My name is David Burden, and I am the Virginia Eastern Shorekeeper. As Shorekeeper I represent a membership of over 200 Eastern Shore of Virginia residents and business owners who care deeply about protecting, preserving, and improving the quality of the coastal waters of the Eastern Shore. The purpose of this letter is to encourage the Counties of the Eastern Shore and the ANPDC to be leaders in the implementation of the Bay TMDL, and to take advantage of the historic opportunity the program provides to restore the water quality of the Chesapeake Bay and the tremendous social, environmental, and economic benefits that accompany that restoration
The Bay TMDL is the latest step in a process that has been developing over more than 25 years. The Bay TMDL was called for in the 2000 Chesapeake Agreement as a follow-up measure if nutrient reduction goals were not met by 2010. The Watershed Implementation Plans (WIPs) were developed by the States. In Virginia, Bob McDonnell’s administration was responsible for our plan. It is also important to note that the steps called for in the plan are voluntary. No particular farmer, town, or business is being forced to implement any unique BMP. However, if the regions fail to meet their goals, then Richmond will step in and dictate how things are done. If Richmond fails to do so adequately then the EPA can get involved. It is in our best interest to be leaders in this effort rather than attempt to stall it and end up having outside parties tell us how to manage our lands.
I had hoped to be able to comment on the actual WIP compliance plans that the ANPDC had put together for the counties as the Director of the ANPDC had promised at the Bay TMDL Workshop that Del. Lewis had hosted at the Eastern Shore Community College. As these plans have not been made available, the public is forced to assume what direction has been taken by the ANPDC. This is very unfortunate and somewhat defeats the purpose of public comment. If the public comments of the Director of the ANPDC are an indicator of the direction that is being suggested to our counties, then I and many other Eastern Shore residents and business leaders will be very disappointed. The option that seems to be in favor - to complain about the TMDL and fight the clean up of the Bay while misleading the public to believe that the Eastern Shore is being singled out or forced to absorb all of the cleanup costs on our own - is counter productive, shortsighted, and will hurt the Eastern Shore for generations to come. Since the Eastern Shore is uniquely situated to benefit the most from a cleaner Chesapeake Bay, and we are only being asked to be an equal partner in reducing pollution, it is difficult to understand why either county would make such a shortsighted decision rather than leading the charge to secure grants and other funds for local municipalities, farmers, businesses and residents. I sincerely hope that the ANPDC is recommending that both Accomack and Northampton Counties reach out to both the State and the EPA to propose that the Eastern Shore of Virginia should be used as an example of how to best implement the Bay TMDL and the Watershed Implementation Plans developed to support it.
Funding for WIP implementation will not be unlimited. The best course of action for the Eastern Shore is to doggedly pursue the available funding to ensure that the cost of the implementation of the Bay TMDL does not fall on our local farmers and taxpayers. The farming community has raised some very valid concerns about the Bay TMDL process, and the EPA is working with farmers and their representatives to address these concerns. Among the solutions being developed are a “Safe Harbor” definition to guarantee farmers will not have to deal with a constantly moving goal of compliance. Farmers have never said that they cannot meet the goals of the Bay TMDL. They have made it clear that they are concerned about securing grand and other funding assistance and that they want clarity in the end goal for their farms. Accomack, Northampton, and the ANPDC should be leading the charge to secure funding for the Bay TMDL compliance efforts that local farmers are ready and willing to make rather than stalling the process and allowing those dollars to flow to other communities.
Just this week the Chesapeake Bay Foundation released a study that discusses “How Pollution Limits Encourage Jobs in the Chesapeake Bay Region. In this report, a citation is made of a University of Virginia study stating that “About 11,751 temporary jobs are expected to be created over five years if Virginia and the federal governments invest $804 million in farm runoff- control projects such as planting trees and building fences along streams to meet Bay-pollution goals.” These can be Eastern Shore jobs, or the jobs can go elsewhere. It is up to our leaders to demonstrate that we heartily support the cleanup of the Chesapeake Bay, that we are willing to do our part, and that the Eastern Shore is the perfect place for Virginia to invest those job-creating dollars.
The purpose of the Bay TMDL is to reduce the pollution stress on the Chesapeake Bay. The agriculture industry will have to be part of the solution to this challenge. However, agriculture is not being singled out. Reductions will continue to be made in wastewater treatment facilities, and urban storm-water runoff has to be dealt with as well. In places like the Eastern Shore where runoff from agricultural lands accounts for the majority of our Nitrogen and Phosphorus load, it may seem like an undue emphasis is being put on agriculture, but it is just one part of the puzzle. A significant facet of the Bay cleanup plan calls for the funding of grants and cost share programs to reduce this economic impact on farmers and land owners.
When the McDonnell Administration developed their strategy for meeting the goals of the Bay TMDL they decided that their priority would be to seek the most cost effective reductions in Nitrogen and Phosphorus. This means that they targeted Agricultural BMPs (Best Management Practices) as a large part of their strategy. Since both of our counties have a significant amount of agricultural land in production, we are being asked to make some significant pollution reductions. There are other contributing factors to Bay pollution that are being addressed, and it should be noted that Virginia has spent over $1 Billion in the last decade on improvements to wastewater treatment facilities throughout the Commonwealth including multi-million dollar grants to both the Cape Charles and Onancock wastewater treatment plants. These types of improvements have led to a 42% reduction in the amount of Nitrogen and a 68% cut in Phosphorus from municipal wastewater plants discharging into the Bay.
This is the type of progress and investment we should be proud of, and working hard to replicate. The Chesapeake Bay is a tremendous economic engine for the Eastern Shore. As the EPA finally steps up to do its job and hold every community in the Bay Watershed responsible for their part of the cleanup effort, the Eastern Shore should recognize that this is an incredible economic development opportunity for our region, and that to do anything less than embrace the TMDL and lead the charge for clean water is irresponsible. In addition to the cleanup related jobs that will be created by the TMDL, decision makers should take note of the following facts:
- A 2005 study by the Virginia Institute of Marine Science (VIMS) found that the value of annual fisheries landings was $13.7 million for Accomack County and $2.9 million for Northampton County.
- A report by the Virginia Tourism Corporation stated that in 2009 tourists contributed $137.5 million to Accomack County, creating 1,850 jobs and $4.4 million in local tax receipts. In Northampton County, tourists spent almost $56.9 million, supporting 730 jobs and nearly $1.2 million in local sales tax receipts.
- A new VIMS study found that 2010 revenue taken home by Virginia clam and oyster aquaculturists was $25 million and $5 million, respectively.
- Accomack and Northampton revenues depend heavily on local real estate taxes (which generate about 80% of local county revenues), which in turn, depend on property values. Studies show that clean water can increase the value of nearby property by up to 25%.
One of the under-appreciated aspects of the Bay TMDL is that we are actually relying on the Bay to clean itself as we reduce the amount of pollution stress we place on it. The costs of a polluted Chesapeake Bay are with us every day. Since 1993 the number of watermen working the Bay has fallen from 14,000 to 1,500. The collapse of the natural Bay Oyster population has cost us over $4 Billion over the last 3 decades. Restoring the natural health of the Chesapeake Bay is arguably the best regional jobs program we could possibly hope for. And with a value of over $1 Trillion, the Chesapeake Bay is an asset we can’t afford to continue to abuse. On behalf of the members of the Virginia Eastern Shorekeeper organization, I sincerely and strongly encourage the leaders of Accomack and Northampton Counties to work together with the State and the EPA to make the Eastern Shore a model community within the Bay TMDL program, and to doggedly pursue the funding assistance our farmers and localities need in order to meet their cleanup goals.
Respectfully,
Dave Burden
Virginia Eastern Shorekeeper
