As readers of this blog and watchers of the Bay restoration process understand, states are under increasing scrutiny regarding their progress, or lack thereof, implementing the Chesapeake Bay Total Maximum Daily Load (TMDL) as we approach the 2017 midpoint assessment. But behind the scenes, a federal-state partnership known as the Chesapeake Bay Program is also tasked with working on the framework for tracking implementation of the Bay TMDL. This framework consists of establishing and improving many guidelines and protocols used to assess the performance of states, sectors, and even the many different best management practices (BMPs) used to reduce pollution. All of the data collected and assessed under this framework is then fed through the Bay Program’s Watershed Model to provide the public and policymakers with the best guess as to how much pollution-reduction has actually been achieved so far. Given the importance of this framework and Model, an increasing level of scrutiny is now also being given to what exactly is going on behind the curtain.
The Bay Program’s experts are housed within six “goal implementation teams” or GITs. The Water Quality GIT is further divided into 14 work groups that focus on different sectors, pollutants, or other subject matter of interest. While many of these groups have been active for years, there has been a recent surge of interest in their work as a number of important decisions are coming up that will affect the way that future progress is measured. And given that the agriculture sector is the largest source of nutrient and sediment pollution to the Bay watershed, the work of the Agricultural Work Group is of particular interest to clean water advocates right now.
The Nutrient Management Panel is about to make final recommendations to the Bay Program’s Agricultural and Watershed Technical work groups. These recommendations include the amount of credit that will be assigned by the Model for agricultural operations that submit a nutrient management plan. Unlike many actions and BMPs that a state can claim pollution reduction credit for (such as a wastewater treatment plant upgrade, a stream buffer installation, or the creation of a rain garden), a nutrient management plan is merely a piece of paper, unable by itself to prevent any pollution. The question is how much credit should the submission of that paper be worth within the Watershed Model?
Nutrient management plans are, of course, only as good as the actions of the farm operator subject to the plan. If the operator faithfully adheres to the contents of the plan, then it can easily result in significant pollution reductions. Unfortunately, recent and credible studies and reviews of nutrient management plan implementation show widespread noncompliance with plans. The Nutrient Management Panel is left trying to consider these different studies and compliance rates and must use its best professional judgement as to how much credit, on average, a submitted nutrient management plan is worth.
The stakes are high. Nutrient management is one of the oldest and most widespread BMPs utilized in the Chesapeake Bay watershed, affecting millions of acres of farmland. As such, even a minor change in the pollution reduction value accepted by the Bay Program and assigned to the BMP in the Model can lead to an enormous change in the credit granted to each state’s agricultural sector.
The Model is only as a good as the data and assumptions used to build it. If the assumed rate of compliance with nutrient management plans deviates significantly from reality, then we will be left scratching our heads in 2025 when the Model tells us that we have successfully taken the actions needed to restore the Bay while our rural rivers and streams are still choked with farm runoff. The goal of the Bay Program is to make the model world approximate the real world as closely as possible. The Bay Program has a very important decision to make regarding the credit it assigns for nutrient management plans, as well as other important BMPs. If they don’t get it right, the Watershed Model, like the nutrient management plan, may end up looking good only on paper