Monday, April 20, 2015

Analysis: Company Promoting SB 724 As THE Solution To The Chesapeake Bay Cleanup Creates Reality Distortion Field

Bion Environmental Technologies, the company who wrote and is heavily promoting Senate Bill 724 (Vogel-R-Beaver) as a solution to reducing pollution to meet Pennsylvania’s commitments to the Chesapeake Bay cleanup, has created a reality distortion field to pass the bill.
In Senate Bill 724 it has created a flawed RFP process that favors big, capital-intensive technologies to deliver nutrient reduction “credits” that it says will solve the Bay’s problems.  
Coincidentally, Bion’s business is developing capital-intensive, expensive manure treatment facilities.
When compared to other capital-intensive pollution reduction projects, this option certainly does look cheaper.
And dressed-up as a market-based solution, the process appeals to many legislators as the Holy Grail, the silver bullet, they are looking for.
Once you pierce the reality distortion field created by Bion, the facts tell a much different story.
The process outlined in the bill actually squeezes out small farmers who want to put much more cost-effective conservation practices on the ground.  
Would thousands of individual farmers, with much less expensive options, put in a bid in response to this RFP?  No.  They don’t have the time or money to do it.
The U.S. Environmental Protection Agency says manure accounts for about 16 percent of the nitrogen pollution in Pennsylvania waterways, but just over 20 percent is attributable to sediment carrying chemical fertilizers not addressed by manure treatment technology.
That means 86 percent of the nitrogen problem and 328 million pounds of sediment Pennsylvania must eliminate to meet the 2017 milestones are not addressed by manure treatment technology.
A stakeholder group convened in 2013 in response to last year’s version of Senate Bill 724 representing the agriculture community, Lycoming and York counties (who have their own innovative nutrient reduction plans), conservation districts, municipalities, Bion and Rep. Ron Miller (R-York), at the time Majority Chair of the House Environmental Resources and Energy Committee, discussed the issue of meeting Chesapeake Bay cleanup milestones, the legislation and the role of manure treatment technology.
The consensus of the group was Senate Bill 724 added complexity to the already very complex Chesapeake Bay cleanup program, MS4 stormwater management program and TMDL watershed cleanup requirements.
They did not see it as a useful tool and at worst it diverted resources away from practices we know work at less cost.
The consensus was that manure technology only dealt with part of the nitrogen problem Pennsylvania faces and that other, more cost-effective methods existed to deal with the pollution issues in the timeframe Pennsylvania is required to act.
Manure treatment technology and Bion’s technology is also not a practice that is now approved by the U.S. EPA as part of the Chesapeake Bay Program and there is no timeline for approval.  
As a result, any nitrogen reductions achieved by this technology would not count toward meeting Pennsylvania’s cleanup commitments for 2017 and beyond.
That could change in the future, of course, if one or more manure treatment systems is approved or even Bion’s, but Pennsylvania needs certainty given our deadlines, not a fuzzy future.
Pennsylvania has 607 days (as of April 27) to put practices on the ground to meet EPA’s 2017 Chesapeake Bay cleanup milestones.  
If these milestones are not met, the U.S. EPA is prepared to step in and implement backstop measures that would impose a variety of direct measures like requiring more farm permits, reducing discharge limits on wastewater plants and others to meet the milestones.
The other glaring omission from Senate Bill 724 is funding.  There is no funding for DEP to set up the complex program and no funding to buy any of the “credits” created by the bill.
Interestingly, changing the way livestock are fed can have significant impacts on the nitrogen and phosphorus in the resulting manure.  
Penn State’s College of Agricultural Sciences estimates a 40 to 60 percent reduction in nitrogen and a 30 to 50 percent reduction in phosphorus are achievable by precision feeding programs for poultry, dairy cattle and swine.
Perhaps treating the nitrogen pollution problem from the front-end rather than the back-end is the most cost-effective option, rather than building a costly manure treatment operation to treat the manure after it’s produced.
Stroud Water Research Center and the U.S. EPA Chesapeake Bay Program estimated that forested stream buffers remove 19-65 percent of nitrogen, 30-45 percent of phosphorus and 40-60 percent of sediment that would otherwise enter a stream.
Pennsylvania, the federal government and a variety of non-profit organizations, like the Chesapeake Bay Foundation-PA, now provide landowners with financial assistance in installing buffers and even annual payments for taking farmland out of production through the Conservation Reserve Enhancement Program.
Since 2000, Pennsylvania has required certain farms with livestock operations to have manure management and nutrient management plans.  These plans require farmers to develop a plan for managing on-farm manure to avoid over-application and provide for safe storage, barnyard improves and use. The plan also has to account for applications of chemical fertilizers.
Good farm management practices like controlling livestock access to streams and using stabilized stream crossing are also good tools to limit nutrient and sediment pollution.
Oh, and all these practices count toward our commitments-- now.
None of these options are now being implemented like they should be to meet Chesapeake Bay milestones, but they could be if given the right attention.
Let’s Summarize
Senate Bill 724 would--
1. Squeeze Out Small Farmers With Much Cheaper Solutions: Designs an RFP process favoring capital-intensive, high-cost technology to deliver pollution reductions, while squeezing out small farmers who want to install conservation practices.
2. Not Address A Huge Part Of The Problem: Manure treatment technology leaves 86 percent of the nitrogen problem and none of the 328 million pounds of sediment reduction problem needs solved to meet the 2017 milestone.
3. Manure Technology Doesn’t Count: Manure treatment technology is not a U.S. EPA approved practice and there is no timeline for approval, as a result it does not count toward Pennsylvania’s Chesapeake Bay cleanup milestones.
4. Stakeholders Found The Bill Was Not A Useful Tool: The consensus of a broadly representative stakeholders group found the legislation added complexity to all already complex Chesapeake Bay cleanup program and manure technology only dealt with a portion of the problem Pennsylvania faces and not in the timeframe we need to face it.
5. Much Cheaper Alternatives Count Now: Other, much cheaper, accepted practices are available and are being implement at some level that deal effectively with the manure issue.
6. Unfunded Mandate: There is no funding provided.  Does Pennsylvania really need another unfunded mandate?
Manure treatment technology may have a role to play, but circumstances are limited by scale, cost and on-going maintenance and management issues.  There isn’t a silver bullet as Auditor General Eugene DePasquale reported April 10.
Let’s see, low-tech, low-cost solutions that work and count now toward our Chesapeake Bay cleanup milestones, or building a complex manure treatment system that requires trucking manure to a central facility, people to operate, maintenance and upkeep and has a limited lifespan?
Which would you choose?
Stay tuned for more....
Related Article:
SB 724 Would Take Resources From Effective Pollution Reduction BMPs

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