Karl Blankenship fairly summarized the problem of Chesapeake Bay pollution caused by the land application of animal waste in”Solutions sought for excess manure piling up on farms,” June 2005. He touts the Chesapeake Executive Council “strategy” to deal with the issue “…without harming the agricultural industry.”

It is impossible to reduce pollution from animal waste without “harming” the agricultural industry. The pollution problem exists because animal waste is a very inefficient form of fertilizer and land application is the cheapest disposal practice. The best we can do is spread the “harm” around, for example, by taxing all poultry products to pay for the environmentally benign disposal of poultry litter.

A land application tax could be imposed based on the commercial value of the nitrogen and phosphorous that is applied to the land but not used by the crop. The tax would be paid to local Soil and Water Conservation Districts, half by the generator and half by the user, with the mandate to use the money to reduce nonpoint source pollution within the district.

To pretend that agricultural pollution can be significantly reduced without cost and without significant changes in agricultural practices (harm) is fantasy.

I recently served on a Technical Advisory Committee to Virginia’s Department of Conservation and Recreation regarding the stiffening nutrient management regulations.

I learned that in 2003, Virginia land applied at least 27 million pounds of nitrogen in animal waste that was not used by crops according to the DCR’s current regulations. To put this large number in perspective, the Virginia Tributary Strategies claim that Virginia rivers supply 78 million pounds of nitrogen to Chesapeake Bay annually. The 2010 Cap Load Allocation for nitrogen is 51 million pounds—a 40 percent reduction.

The amount of land-applied nitrogen in animal waste not used by crops in 2003 is similar to the goal of nitrogen pollution reduction, 27 million pounds of nitrogen annually, demonstrating unequivocally the massive significance of the land application of animal waste as a source of pollution. The pollution could be eliminated if animal waste was consigned to landfills.

The “directives” from the Chesapeake Executive Council—of which the EPA is a member—do not address how pollution from the land application of animal waste is to be reduced by 40 percent by 2010. The verbiage in the 1998 “Directive 98-4” was repeated in 2004 in “Directive 04-3” with no action in the interim.

An examination of the strategy (summarized on page 17 of the Bay Journal) demonstrates how hollow the strategy is. For example, if phytase could reduce the nitrogen content of poultry litter throughout the watershed by 40 percent—a highly unlikely scenario in my opinion—the 2010 nutrient reduction goal for poultry litter would be achieved.

But pollution reduction from land application would still fall far short of the 40 percent goal because poultry litter constitutes only about half of the land-applied animal waste in Virginia, and the nutrient content of manure and sewage sludge would remain unchanged.

“Creating markets for manure-based products” within the watershed (Directive 04-3) worsens the problem and increases pollution. “Coordinate manure transport and relocation programs across the watershed” (again, Directive 04-03) merely spreads the pollution around, but does not reduce it. The strategy certainly does no harm to the agricultural industry, but neither does it achieve any significant pollution reduction.

David Bancroft also addresses the issue of agriculture in “Include farmers in decision-making process,” June 2005. Farmers have never been excluded. Do we really expect farmers or agribusiness to voluntarily take action that reduces their profits in order to limit nutrient pollution from animal waste?

As long as “free fertilizer” is available, irrespective of the massive pollution it causes, some farmers will use it. Best Management Practices such as the split application of fertilizer or planting winter cover crops are more expensive than the alternatives, and few farmers will institute them voluntarily.

Additionally, these sorts of practices reduce pollution less than would be true if animal waste was land applied based strictly on the nitrogen and phosphorus requirements of crops. International influences on commodity prices and national economic issues such as balance-of-trade, make environmentally responsible farm practices unlikely to be successfully addressed at the watershed level.

Bancroft ends by encouraging us to work together so “that we can finish the job of Bay restoration.”

Give us a break! Fewer than half of the wastewater treatment plants in the watershed have nutrient reduction technology in place, and no significant restrictions on fertilization practices have been mandated. We have hardly started toward improvement, much less restoration!

The size of the summer dead zones and the low percentage of Bay bottom covered by submerged aquatic vegetation prove beyond all doubt that our progress so far has been minimal.

We are long overdue in dealing firmly and meaningfully with the biggest problem, namely agricultural pollution, recognizing that we all must ultimately share the burden of “harm” necessary to restore the Bay.