are achieved in a cost-effective manner, local
water quality improves, and the credit-seller
is provided with additional revenue.
Local governments with urban stormwater
permits will likely be one of the main beneficiaries of a nutrient-trading program. The
high cost of achieving stormwater pollution
reductions is one of the greatest challenges
of implementing the Bay pollution limits.
Local governments could save millions of
dollars if they can purchase credits from, for
example, farmers who exceed their reduction goals.
An offset can be met by reducing load from
another existing pollution source, not just
from traded credits. For example, two point
sources discharge to the same river. One
wants to grow and get a bigger permit limit.
The other agrees to get a reduced limit in an
amount equal to the new pollution load.
That is an offset without a trade.
The concept of nutrient trading is not new
to the Chesapeake region. In fact, over the
past several years, Pennsylvania, Virginia,
Maryland, and West Virginia have all issued
regulations or guidance that allow nutrient
trading. And, all of the states are relying, to
some extent, on trading programs to achieve
and maintain the overall pollution cap estab-
lished by the 2010 limits.
Critics argue that trading allows a source to
“pay to pollute” rather than cleaning up its
own pollution. Others have expressed concern about local water-quality protection,
transparency and accountability, or the uncertainty of pollution reductions garnered via
credits, particularly those involving nonpoint
sources. (Unlike pollution that is discharged
directly from point sources like industrial and
sewage treatment plants, nonpoint source
pollution comes from diffuse sources.)
CBF shares this skepticism. While we all must
remain vigilant in the development of any trading program, one that is properly designed and
implemented offers both a way to achieve the
Bay’s pollution limits in a cost-effective and
environmentally beneficial manner, and a way
to maintain the pollution cap, once achieved.
Trading must ensure reductions are real and
•Protecting local water quality;
The design and implementation of nutrient-trading programs will, without question,
pose challenges. But such programs are critical to restoring the Chesapeake Bay and its
tributaries in the least possible time, at the
least possible cost.
Much good work is happening and success is in our sights. But, powerful forces
are working hard to throw our efforts off
course. CBF is fully committed to supporting the Bay pollution limits and seeing to the complete implementation of
the states’ plans to achieve them. We
urge our members to visit cbf.org/tmdl to
A Farmer Weighs in...
A number of national agribusiness lobbying associations are trying to
stop the Bay restoration effort by suing in federal court and lobbying in
Congress. But William Morrow (Emmitsburg, Maryland), who has partnered with the Chesapeake Bay Foundation for years, says enough is
enough. Read his response to “The Biggest Problem” published by The
Baltimore Sun on February 20.
New rules must require all farmers do their fair share
to clean up the Bay
Regarding your recent commentary on animal waste and pollution in
the Chesapeake Bay, I would like to point out that agriculture is not a
monolithic industry uniformly opposed to the regulation of harmful
nutrients that foul the Chesapeake Bay.
I am a farmer in Frederick County who took the time from my operation
to go to Annapolis Tuesday to testify in support of legislation to require
better management of farm animal manure and sewage. I raise sheep,
goats, hogs, and poultry whose manure would be subject to the new rules.
Our farm is bordered by Tom’s Creek, which feeds into the Monocracy
River and which ultimately drains into the Chesapeake Bay. Our water-
shed is one of many in the region that suffers from excessive runoff of
nutrients from agriculture.
We follow voluntary best management practices recommended by the state,
and although we get some financial and technical assistance, implement-
ing these best practices still costs us time, money, and the use of land adja-
cent to creeks and drainage swales that we have to take out of production.
It is frustrating to do all of this only to drive off my farm and see cows
standing in the creek, barren fields without any cover crops, and farmers
spreading manure on frozen ground in violation of state regulations.
Worse yet is to leave my driveway on warm, wet winter days and see
black/brown water running into the drainage ditch along the road,
which then dumps into the creek. The soil in our part of the county is
orange, not black/brown, so this is not sediment coming off our fields.
Taxpayers are footing the bill to fund best management practices on
farms across the state. The problem is you cannot have a patchwork in
which some farmers try to prevent the runoff of nutrients into the bay,
while others do nothing. We’re all on the same body of water, and we
will never clean it up unless we all do our fair share.
Voluntary, incentive-based approaches have failed. We’ve tried that
strategy for more than 30 years now. The reality is speed limits are for
speeders, not for people who never drive above 55. Rules are for peo-
ple who aren’t following them. Right now, we have a lot of farmers who
are not following the rules.
If we are serious about cleaning up the bay, what we need are a set of
uniform—and uniformly enforced—rules for all farmers to abide by.