“If USDA’s numbers are correct, agriculture has already significantly surpassed EPA targets for reductions in sediment and phosphorus,” said National Association of Corn Growers Director of Public Policy Rod Snyder. “It is crucial that farmers in the Bay watershed receive appropriate credit for their efforts to be good stewards of our land and water resources.”

The LimnoTech report also found that USDA and EPA make different assumptions about animal feeding operations (AFOs) and concentrated animal feeding operations (CAFOs). EPA attempts to model loads from the CAFO production areas, where animals are housed and manure stored, while USDA does not.  

Both EPA and USDA appear to model manure application on cropland on a nitrogen basis.

USDA estimates that 38 percent of cropped acres have manure applied. According to the study, it is not possible to determine from the available EPA documentation how much of the cropland in the EPA model receives manure.

“Because the TMDL will have immediate economic consequences, the quest for more accurate data must begin immediately,” said National Pork Producers Association Chief Environmental Counsel, Michael Formica. Should EPA proceed without an unassailable data set in hand, all stakeholders in the Bay should question not only EPA’s pollution assignments, but also its diet for cleanup.”

“The ANPC wanted to know if the differences in EPA and USDA estimates were significant enough to call the draft TMDL into question,” said Lisa Kelley of the National Council of Farmer Cooperatives. “The LimnoTech study provides a resounding “yes” to that question and we are urging EPA to step back and re-examine the precision and accuracy of its data.”

According to the LimnoTech study, the USDA model framework seems to more accurately represent real world, Chesapeake Bay watershed agricultural operations and management practices including consideration of crop rotations, varying levels of tillage (no-till, mulch-till, conventional-till) and actual nutrient management practices.

“Through the Bay TMDL, EPA is implementing a rule that will have significant impact on economic growth and development, including food production, in the watershed,” said American Farm Bureau Federation Senior Director of Regulatory Relations Don Parrish. “It is critical for EPA to get the facts right, including providing an accurate accounting for existing management and conservation practices before it imposes potential economic disaster on agricultural producers in the Bay watershed.”

The LimnoTech report is available at http://nutrientpolicy.org/ANPC_News.html