Washington-The Fertilizer Institute on Jan. 8 submitted comments regarding the Environmental Protection Agency’s (EPA) documents that were developed in response to the Executive Order on Chesapeake Bay Protection and Restoration issued by President Obama on May 12, 2009. TFI said EPA’s Draft Strategy is of interest to a number of TFI members who own and operate facilities located on or near waters of the Chesapeake Bay. It is also of interest to member companies that hold National Pollutant Discharge Elimination System (NPDES) permits for point source and storm water discharges into the Chesapeake Bay watershed, and Clean Air Act permits that would be affected by federal and state actions delineated in the Draft Strategy. Additionally, TFI said it and its member companies have an interest in any precedents that may be established by EPA’s Chesapeake Bay restoration efforts. TFI’s comments addressed several concerns with the current Draft Strategy, including charges that it exceeds EPA’s Clean Water Act authority to set Total Maximum Daily Loads (TMDLs) for states in the Bay watershed; proposes to increase federal land management and regulatory reviews of land-use planning, reducing available land for economic activity; minimizes public participation in that EPA has proposed preliminary basin-wide working target loads for nitrogen and phosphorus in the absence of a finalized TMDL for the watershed; and overestimates nutrient contributions from agricultural sources, while combined sewer overflow remains unaccounted for in relative source contribution analyses. TFI said USDA and EPA should work with TFI and other agricultural experts to adopt the 4R nutrient stewardship system. More information is available by contacting TFI Vice President of Scientific Programs Bill Herz at (202) 515-2706, or by e-mail at wcherz@tfi.org.
Transparency Across the Fertilizer Value-Chain