In addition to highlighting EPA’s oversight of the agriculture community’s environmental stewardship efforts within the Bay, the comments criticize the Agency’s lack of transparency regarding the draft TMDL and the models used to develop the requirements.    

“Farmers continue implementing best management practices (BMP) but with no assurance from EPA these practices will actually achieve the desired water quality goals. In fact, EPA has provided no assurance that the Draft TMDL standards are even achievable with today’s population and economy. We have not seen any economic analysis of what this clean-up effort will cost taxpayers or how it will affect the food, feed and fuel supply provided by Virginia’s farmers,” said Longest. 

“The Agency has made it difficult for any farmer to understand what impact the TMDL will have, because EPA’s own information is constantly changing; providing a moving target. This has prevented a meaningful dialogue about the costs, benefits, and challenges for policy makers, the public and agriculture.”

Both VGPA and industry comments address EPA’s needed authority to implement such measures on Virginia taxpayers, citizens, land and waters. Comments state that EPA is clearly stepping outside the authority granted to them by Congress in the Clean Water Act.

“This is the most complicated, largest TMDL ever attempted. Establishing this type of precedent especially, with admittedly flawed data, is not the intent of the Clean Water Act,” said Molly P. Pugh, VGPA Executive Director. “In our comments, VGPA states, ‘EPA must not attempt to mandate “one size fits all” regulations and expect water quality goals to be met. On behalf of our members, VGPA requests that EPA produce proof of BMP impact to the Bay, provide a full economic analysis of the TMDL standards, provide the legislation that outlines EPA authority over the states and most importantly, provide for public review the full and complete data used to create the TMDL standards.’ Agriculture and forestry are Virginia’s top economic sector. Without creating a feasible balance between economic growth and environmental goals, Virginia’s economy will be devastated. That is an unacceptable trade-off for any goal,” said Pugh. 

Click here to see the industry’s full comments submitted by 29 state and national groups. Click here to see VGPA’s full comments.