Congressman Robert Goodlatte of Virginia has said that one of his biggest concerns about the Bay pollution limits is the cost burden it will impose, especially on farmers in the region.

Mr. Goodlatte does not detail those burdens, but he does blame the EPA for not having completed a cost-benefit analysis of the pollution limits.

Nor does he consider the substantial federal and state cost-share dollars that have been made available to the region's farmers. And his statement certainly does not reflect the recent investment commitments both Virginia and Maryland have made for farmers and other pollution sources during their recently concluded 2012 sessions.

Let's set the record straight. And, let's start from the beginning.

First, Goodlatte and others state that the EPA has a plan that dictates how the jurisdictions should meet their allocations. This is incorrect. In fact, the EPA has determined the pollution limits and allocated them to the states. The states have only recently (March 30) submitted to the EPA their Phase II plans describing how they plan to meet the pollution limits. Each of the states' plans is different, and each is uniquely the choice of the state.

As the ink is not dry on the states' plans, it would be impossible for the EPA or anyone else to know the true costs to the states, to farmers, to anyone at this point in time.

But, we can learn much from history. According to a 2010 fact sheet researched and compiled by the World Resources Institute (, both academics and economists have identified three realities about the potential costs associated with the pollution limits.

  • When the EPA issues regulations, industry - in this case the national agribusiness industries that support Mr. Goodlatte - often issues warnings about economic Armageddon. The Chesapeake Bay Foundaton also made this point in our "Jobs Report" last January, noting as far back as 1976 when Henry Ford predicted the clean air and fuel efficiency standards would destroy the Ford Motor Company, which - far from underwater - ranked 10th on the Fortune 500 list in 2010.
  • There is "extensive literature" demonstrating that the costs of environmental regulations "are more than offset by a broad range of economic, public health and jobs-related benefits." For example, the WRI noted that the estimated aggregate cost of the EPA's clean air and water regulations between 1999 and 2009 ranged from $26 billion to $29 billion while the benefits over the same period ranged from $82 billion to $533 billion. Even at the low end of the range, the return on investment is impressive.
  • The WRI noted that cost estimates "are consistently found to be overstated." Certainly, this reality has proven true in Virginia where the Hampton Roads Planning District Commission, the voluntary organization of 16 local governments established to foster intergovernmental cooperation and to provide support in addressing regional issues, found about 80 percent cost savings when relying upon a more flexible state-driven plan, which the commission estimated at costing $1.8 billion versus one that would have required additional federal involvement, which it estimated at $9.7 billion.

Second, year after year, the CBF and many others have worked hard in Congress and with state legislatures to bring cost-share dollars and provide technical assistance for Chesapeake farmers. Hundreds of millions of dollars, including $188 million in the last Farm Bill, have been directed to farmers in the Bay region. To suggest our farmers are unduly burdened ignores these facts.

And finally, again this year, Virginia and Maryland have stepped up to the plate, despite difficult economic times and worthy competing needs, to invest in environmental restoration programs.

In Virginia, for example, the legislature passed a bill that expands the commonwealth's trading program, which can certainly benefit farmers. Maryland doubled the "flush fee," which will increase monies for cover crops and provide additional funding to the states remaining major sewage treatment plants needing to be upgraded.

While no one disputes there will be costs to meeting the pollution limits, we can't overlook the fact that there are greater costs if we don't meet the pollution limits: costs to ourselves and to our future generations. Although it's early in the year, we're already seeing algal blooms and low dissolved oxygen in Maryland. It's past time for putting up obstacles.