The PennAg Industries Association on Wednesday sent a letter to Sen. David Argall (R-Schuylkill) saying they “do not support [Senate Bill 724] as currently written due to our issues and concerns, contrary to a statement made by Ed Schafer, Bion Environmental Technologies, at a Senate Committee hearing May 6 that said they did.
Attached to the letter was a list of nearly three dozen questions PennAg had about the bill. The text of the letter follows--
Dear Chairman Argall:
In light of the May 6, 2015 Senate Policy Committee Public Hearing on wastewater and stormwater issues and legislation providing for the creation of a watershed improvement plan, the PennAg Board of Directors felt it was imperative that the record be clarified as to the position of PennAg Industries Association. Ed Schafer, Chairman of the Coalition for an Affordable Bay Solution testified that PennAg supports SB 724. That is not accurate. At the time of the hearing, the PennAg Board of Directors had yet to take a position on SB 724.
Since then, the PennAg Board of Directors have convened and discussed the merits of SB 724 as currently drafted and have a list of concerns regarding this bill. At this time and due to these concerns, the official position of PennAg is “Do not support the bill as currently written due to our issues and concerns”.
PennAg staff would like to meet with the applicable staff as well as other individuals or groups to discuss re-drafting this bill in a manner to satisfy our questions and concerns.
With that said, PennAg is supportive of innovative technologies and solutions as referenced in our official statement from 2011 (attached). Please note that we stipulate our support for technologies which advance Pennsylvania Agriculture. With that, Pennsylvania Agriculture is very diverse in size, scope, commodities raised in addition to a variety of topography challenges. Therefore an array of technologies and solutions must be available to truly meet the needs of our diverse agriculture community.
To further expand upon this issue, I can be reached at cherr@pennag.com or at (717) 651-5920.
Sincerely,
Christian R. Herr
Executive Vice President
PennAg
The text of the questions follows--
Pennsylvania’s obligation in the Chesapeake Bay Restoration is to add Nitrogen, Phosphorus and Sediment. At this time, the Commonwealth is making slow progress on Nitrogen and Phosphorus but little headway on the issue of Sediment Reductions. In regards to SB 724:
a. Will each technology be required to document reductions of Nitrogen, Phosphorus and Sediment before funding is committed?
b. Will each technology be required to be approved by EPA for credit in the Bay Model prior to receiving taxpayer dollars?
c. Will funding be allocated on a “sliding scale” based on the number of issues the technology will address? For example: an application will receive maximum funding if the technology addresses Nitrogen, Phosphorus and Sediment or partial funding if it only addresses one of those issues?
d. Will SB 724 fund “startup/experimental” technologies? What constitutes a “successful” technology – a system that works one week a quarter? A system that functions daily? How will the technologies be monitored to ensure performance at a level to ensure compliance and improvement to water quality therefore netting Pennsylvania improvements towards Bay obligations?
e. Where will the funds come from for this work? The bill references “State Treasury – Special Fund”. Is this a new funding stream? Is it possible that funds will be redirected from existing agriculture funding programs to fund the work of SB 724? Does SB 724 insinuate that it is the taxpayers’ responsibility to pay for a technology who defaults on a loan?
f. When considering “economies of scale”, what is the smallest size/volume of manure generated for these technologies to receive funding? Pennsylvania has in excess of 59,000 farms across the Commonwealth; will all 59,000 farms be eligible for funding under SB 724?
g. Will “smaller” farms have to compete in the RFP to receive funding? Operational reality is that the smaller farms may not have the time, resources or ability to complete a lengthy RFP.
h. Will SB 724 award projects on an individual watershed basis or will funds be targeted to specific animal dense locations? How will SB 724 ensure equitable distribution of funds to ensure environmental justice across Pennsylvania?
i. SB 724 addresses the topic of credit generation and necessary prices for credits – how will this compliment or differ from the existing nutrient credit trading program currently functioning in Pennsylvania? Within the intent of SB 724, where will authority for this credit trading reside? How will the price for credits be determined? The current structure of credits prices credits around $2. SB 724 references credits around $11 – why the difference and who is paying for the price difference? Will it be the responsibility of DEP (Department of Environmental Protection) to verify the credits? If so, have EPA endorsed this concept?
j. Within SB 724 and the focus on an RFP, credit generation and resale – how will this be applicable to all farms across the Commonwealth when under the current trading criteria, a farm must be a baseline before eligible to trade and then can only trade on the excess (above baseline). If SB 724 focus is on farms above baseline, how many farms are then eligible to submit an RFP and be a successful recipient of funding? EPA and DEP have already documented that smaller farms are the ones needing cost share, technical assistance and practices installed to improve water quality. That implies that these farms have not achieved baseline and therefore would be not eligible under the intent of SB 724.
k. If state funds are used to launch technologies under SB 724, what are the criteria for repayment of the funds? What are the consequences if funds are not repaid? Must the technology companies provide documentation to ensure they are creditable and stand behind their technology’s claims for reductions and overall environmental improvement?
l. What research has Pennsylvania conducted to show a demand for the structure outlined in SB 724? Does the research identify the number of the farms who would apply for the RFP and does the research anticipate the benefit to Pennsylvania in meeting the Bay obligations SB 724?
m. What is DEP’s role in SB 724? Will SB 724 necessitate a new regulatory program within the Department of Environmental Protection? Where will the funds come from to cover this expense? Could staffing and funds be redirected from existing DEP Bureaus to comply with SB 724?
As stated in our letter to Senator David Argall (dated May 13, 2015); PennAg supports the use of technologies as one of the approaches for the Commonwealth to utilize. However, there is not one, stand-alone solution which will generate the results for Pennsylvania to meet the Bay obligations. Instead, Pennsylvania will need to implement a suite of solutions across many urban and rural sectors to truly achieve the goals outlined for the State.
A copy of the letter and attachments is available online.
The PennAg Industries Association represents agribusiness in Pennsylvania of all sizes and types that support and serve the entire food chain and is based in Harrisburg.
Related Articles:
PA Environmental Council Cites Concerns, Opposes Senate Bill 724
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