From: <DePillis>, Alex DePillis <Alex.DePillis@state.vt.us>
Date: Friday, September 27, 2013 5:02 PM
To: Kirk Shields <kirk.shields@greenmountainpower.com>, "Griffin,
Bob" <Bob.Griffin@greenmountainpower.com>
Cc: Diane Bothfeld <diane.bothfeld@state.vt.us>
Subject: RE: GMP 2014 CEED Fund Workshop
Kirk Shields and Bob Griffin:
Thank you for the workshop and all the work you put into this process.
Below are my comments, limited to the proposal from Native Energy.
VALUE AND BENEFITS
The process claims to remove from the watershed more than 60%
of phosphorus in the manure stream. Actual accomplishments should
be measurable, and the proposal promises to measure and verify by
requiring sales records and by analyzing the phosphorus content.
The method of establishing the dollar value of phosphorus
reduction by using state estimates (page 17, excerpt appended) is a
valid approach to estimating the value of something that is not yet
traded.
THE TECHNOLOGY
New and innovative practices and technologies are within
CEED’s charge. This proposal strikes a good balance of being
relatively straightforward technology used in water treatment and
industrial processes, applied to the agricultural sector. There are a few
examples of centrifuges being used to remove manure solids, and the
timing seems good for this kind of a project in Vermont.
It passes the but-for test – our Agency of Agriculture and other
entities have made several forays into phosphorus reduction
technologies. To date, none of the approaches or equipment providers
have persisted, except for a few examples of centrifuges.
OTHER CONSIDERATIONS
The follow-on work is important, especially targeting critical
source areas with a screening tool, and adding this technology to
existing and upcoming manure digester projects.
Best regards,
Alex
Alexander DePillis
Senior Agricultural Development Coordinator
Division of Agricultural Development
Vermont Agency of Agriculture, Food, and Markets
(802) 505-3067 (cell and work)
===>
In 2011, the USEPA reconsidered its approval of the TMDL,
determined it did not comply with USEPA regulations, and withdrew
its approval of the Vermont portion of the Lake Champlain Phosphorus
TMDL. The original TMDL submission, among other things, established
reduction targets for agricultural land-based NPS P pollution of the
Lake, as well as budgets for mitigating this pollution by 2016. In total
Vermont was allocated an agricultural reduction target for agricultural
NPS P of 44.9 metric tonnes per year (99,000 lb/yr) and the State set
forth a budget of $76 million <13> over the remaining 13 years of the
period the reduction targets were to be achieved. On a present-value
basis (2002 dollars), this reduction target and budget amounted to a
cost of $667/lb/yr of P reduction. In its 2010 Revised Implementation
Plan for Lake Champlain Phosphorus TMDL, the Vermont Agency of
Natural Resources projected a cost range of $125 million - $175
million for addressing P reduction on agricultural lands. <14>
---------------<13> Note that this figure does not include additional expenditures
that will likely have to be made by farmers to comply with P-related
regulations and thus, this is a conservative estimate of the total
societal costs for P mitigation.
<14> See 2010 Revised Implementation Plan for Lake Champlain
Phosphorus TMDL, available at:
http://www.vtwaterquality.org/erp/docs/erp_revisedtmdl.pdf, pg 21.