Several years ago, Don McNutt was surprised when he learned that the state of Pennsylvania claimed Lancaster County farmers were doing only 4,000 acres of no-till farming in its annual Bay cleanup reports.

In drives along the county's back roads, it seemed clear to McNutt, who heads the Lancaster County Conservation District, that large numbers of farmers had adopted no-till practices and stopped plowing their land before planting—something that reduces erosion and phosphorus runoff.

Now, McNutt has data to back up his hunch. His office recently surveyed 379 farmers, whose operations covered 15.7 percent of the agricultural acreage in the county, and found that no-till was practiced on more than 34,000 acres. The survey also found more stream buffers and cover crops than previously reported.

"The numbers pretty much came out where we thought they would," he said. "There is a significant under-reporting of a lot of good BMPs that the farmers have put in place on their own nickel."

Conservation measures, known as best management practices or BMPs, are typically tracked by agencies based on reporting from various programs that help fund measures such as planting cover crops, installing a streamside buffer or building a manure storage facility.

Efforts not funded through government programs typically go under-reported or not reported at all. No-till is a prime example. Many farmers have stopped plowing their land in recent years because of rising fuel costs. Sometimes, they simply borrow the equipment needed to plant crops without plowing from others, rather than resorting to programs to help buy it.

The problem is likely exacerbated in Lancaster County, with a high population of Amish and other Plain Sect farmers who don't accept government funding.

Under-reporting BMPs is an issue elsewhere, as well. A survey conducted in Pennsylvania's Bradford County not only found significant numbers of undercounted farm BMPs, but also found that many urban stormwater control practices that had gone unreported, including street sweeping and various stream protection measures.

As many call for more restrictions on farmers to help clean up the Bay, many agricultural agencies and organizations have countered that farmers are not being fully credited for actions they have already taken.

The issue of accounting for so-called "voluntary BMPs" has arisen on and off for years. But it has gained more urgency as the EPA develops a new regulatory cleanup plan, known as a total maximum daily load. Unlike past plans, states could face penalties if they fail to meet cleanup goals.

Just about every Bay jurisdiction said in their draft Watershed Implementation Plans submitted to the EPA in September that they planned to do a better job finding and reporting previously uncounted BMPs.

"If you take a blind eye to what you are doing on the ground, you are going to get half [of what you see] as a result," noted John Hines, deputy secretary for water with Pennsylvania's Department of Environmental Protection, at the September meeting of the Chesapeake Bay Commission. Because of such undercounting, the state's draft watershed plan says the nutrient reduction actions credited to Pennsylvania by the Bay Program are only "reflecting a portion of what is happening on the ground."

"We actually think there are many things that we are going to be able to identify that will give us credit," agreed Virginia Natural Resources Secretary Douglas Domenech at the same meeting.

The Virginia General Assembly this year passed legislation requiring agencies to develop a mechanism to count and track voluntary actions by farmers.

Mark Dubin, an agricultural technical coordinator with the University of Maryland Extension who works with the Bay Program, agrees that many BMPs go unreported. In addition to working on Bay issues, he owns and operates a farm in Pennsylvania.

"I am doing things that would be considered BMPs, but there is no opportunity for me to report what I am doing to the state," he said. "So even if I did want to report it, there is no mechanism. It requires a bit of retooling on everybody's part to do this."

But there are problems in crediting nutrient and sediment reductions from such voluntary BMPs, he cautioned. Practices implemented through cost-share programs must meet certain standards, and technicians must verify that those standards are met.

Practices that don't rely on those programs may not fully meet those standards. For instance, stream buffers may be narrower, cover crops may not be planted soon enough after harvest or may use less beneficial species, or no-till may be used only for some crop rotations.

As a result, Dubin said, it's possible that some voluntary BMPs may produce smaller nutrient reduction benefits, depending on their level of implementation.

"For the most value out of what is going on, there needs to be somebody who has the training to go out and look at something, and say, 'it meets what we are looking for,'" he said. "That is going to be part of that ongoing discussion. Who is going to do that? Where are the resources for doing that type of work?"

On-the-ground inspections can create their own issues, such as raising concerns by some farmers who are worried about confidentiality.

"When it comes down to doing the survey work, the concern is for trust and confidentiality," McNutt said. "Are you out here spying? Is my name going to show up in the newspaper tomorrow?"

But he said those problems can be overcome by working with farmers. During the county's survey work, he said, technicians found they could get information from farmers as long as their identities were "scrubbed."

If adequate reporting mechanisms are developed, EPA officials say they are open to counting those practices toward Bay goals in the future.

"If there are additional efforts out there that are not currently being counted by somebody, we are interested in looking to get that information on how much further the states are, or are not, ahead," said Shawn Garvin, administrator of EPA Region III, which includes most of the Bay watershed.

But, he said, mechanisms need to be in place to verify that those practices are properly installed, maintained and work. "We are going to be truth-testing all of this stuff."

Garvin noted that what counts toward removing the Bay from the EPA's impaired waters list is not the number of BMPs on the ground, but an improved Chesapeake. "Ultimately, the Bay, and the Bay's water quality will tell us how successful all these activities are."