EPA’s evaluation of the recently submitted PA WIP and milestones identifies both key strengths and needed improvements in order to meet Pennsylvania’s water quality goals.
Overall, EPA summarizes that while PA’s draft Phase II WIP provides updates on progress to date, it does not provide clear next steps and reasonable assurance that the objectives will be met. So significant are some of the deficiencies that if improvements aren’t made in the final document, Pennsylvania may face ramifications to federally delegated regulatory and enforcement programs and related federal grants.
“CBF joins EPA in commending DEP for strengths highlighted in the draft plan, including the development of a plan to ensure that farmers comply with current laws and regulations; an increased commitment to the Conservation Districts; enabling on-farm visits to ensure awareness of Erosion Control and the newly updated Pennsylvania Manure Management Manual; performing compliance inspections on agricultural operators; and increased training and permitting procedures related to General Permit for stormwater discharges for local communities," said Ehrhart.
“Additionally, EPA commends PA for taking strides to coordinate with federal agencies to reduce pollution entering our waterways and the Bay. CBF, as a working partner with DEP, agrees, and cites updates to compliance tools, such as the Manure Management Manual, as important advances to assist communities in meeting state water quality goals.
“At the same time, this plan is weak in several key areas. Overall, the draft Phase II WIP is too vague regarding the strategies, programs, resources, legislation, and timing to be employed to meet our water quality obligations. Nor does it provide reasonable assurance that our goals will be met.
“One critical shortcoming with the draft Phase II WIP is the lack of specific information regarding the expectations of counties to plan for and facilitate pollution reductions. For decades, Pennsylvania’s effort to restore the Bay has failed in large part due to the large-scale focus that disconnected farmers, citizens, and local governments and others from the process and responsibility. One of EPA’s central goals of the Phase II WIPs was to avoid repeating the mistakes of the past by making the effort more localized and, therefore, more relevant. This plan does not adequately do that.
“Providing communities with the information, tools, and guidance they need to achieve our water quality goals will be a challenge, but CBF is confident that DEP and EPA can do so. And with the increased funding to water infrastructure and the environmental stewardship fund through recent Marcellus Shale legislation provides Pennsylvania, a unique opportunity to address staffing and resource shortfalls, and to help DEP implement a plan, and meet our water quality goals. Counties receiving direct funding from the impact fee should also prioritize efforts toward meeting these key concerns.
“CBF looks to the Commonwealth to provide a detailed WIP that outlines the required steps, provides for the needed programs and resources, establishes expectations and compliance mechanisms for all sectors, and provides reasonable assurance that Pennsylvania will, by 2025, meet federal clean water requirements.”
