The Delmarva Farmer Comment Page

Go to the meeting, come prepared

3.18.2008

Virtually everyone in the Chesapeake Bay watershed — which spans New York, Pennsylvania, Delaware, Maryland, Virginia, West Virginia and Washington, D.C. — is aware of the failing health of the Bay.
The Bay’s failing grade has not been caused by any segment of the population or of industry. The Bay continues to stay in bad health because of everyone; it’s not just wastewater plants, it’s not just development ... and certainly, it’s not just agriculture.
Everyone in the watershed should be held accountable. But new regulations proposed by the Maryland Department of the Environment (MDE) seem to send the message that the agricultural community should be held more accountable than others.
The regulations would require that poultry growers with more than 75,000 square feet of production capacity (roughly 100,000 birds) would have to apply for a Maryland Animal Feeding Operation (MAFO) permit, which has an annual fee, and complete and implement a Comprehensive Nutrient Management Plan (CNMP).
To develop a CNMP, it will cost farmers between $2,000 and $7,000 or more, based on the complexity of the farm operation.
That’s a lot of out-of-pocket money, money that already is quickly eaten up by skyrocketing costs of fertilizer, fuel, energy and land.
Farmers need to stand up and tell MDE how much these new regulations could cost them.
A public meeting, just like the one on March 6 in Ruthsburg, Md., will be held on Monday, March 24 at the Guerrieri Hall Auditorium at Wor-Wic Community College in Salisbury, Md.
It’s important — critical, even — that farmers attend and speak up about the proposed regulations.
It’s also just as important that those attending speak calmly and rationally, and advance recommendations to make these proposed regulations less burdensome.
Rightfully so, farmers are frustrated and upset about these proposed regulations; developing and implementing a CNMP overlaps with the state’s Nutrient Management Plan (TMP), causing unnecessary duplication. Which of course, is only one issue associated with these new regulations.
But getting angry at these public meetings isn’t going to solve anything. Venting is a one-way street.
Make plans to attend the March 24 meeting in Salisbury. Come prepared with questions and make comments that will help the MDE understand where you’re coming from.
At the Ruthsburg meeting, the MDE representative, under a verbal assault which at times bordered on the personal, said, “We’re not farmers. You’re the experts.”
So, take the time to sit down and review the proposed regulations at http://www.mde.state.md.us/AboutMDE/reqcomments.asp#CAFO.
Tell the MDE why these proposed regulations place an unfair burden on farmers.
Tell them that your Nutrient Management Plan addresses many of the same components that a CNMP will.
Tell them that a Soil Conservation Plan, provided free of charge from the Natural Resources Conservation Service, is a better plan to supplement the already established NMP.
Tell them these regulations put the agricultural community at a disadvantage, and that having yet another cost and even more paperwork could run you out of business and force you to sell your green open space to developers.
If you can’t make it to the March 24 meeting, you can submit your written comments to: estone@mde.state.md.us or to Maryland Department of the Environment, Water Management Administration, 1800 Washington Blvd., Suite 455, Baltimore, MD 21230, Attention: Edwal Stone.
Bottom line: Lay it on them.
Because if you don’t do it now, the bar will just keep getting higher.