210 SOUTH CROSS STREET, SUITE 101 CHESTERTOWN, MARYLAND 21620 PHONE: (410) 810-1381 FAX: (410) 810-1383 WWW.CLEANCHESAPEAKECOALITION.COM September 18, 2015 Dear Editor and Publisher: Please consider for publication and/or follow up reporting the following commentary on behalf of the Clean Chesapeake Coalition: More Hysteria, Less Science Maryland county officials involved in the Clean Chesapeake Coalition have read with keen interest your recent reporting on the latest crusade by a cadre of environmental organizations to single out and demonize the poultry industry as the greatest threat de jure to the Chesapeake Bay. Once again these advocacy groups claim to have sound science behind all of their proposals. In the context of the larger Bay restoration picture and major threats to Bay water quality, the obsession with phosphorus loading attributable to Maryland agriculture, and particularly Eastern Shore poultry farming, is folly peppered with hysteria. First consider the state of two keystone fisheries in proximity to chicken houses. In the lower parts of the Bay where poultry operations are said to be concentrated (113 in Wicomico County and 87 in Somerset County), the crab and oyster harvests have been the highest in recent years. In the upper Bay where poultry operations are more sparse (10 in Kent County and 40 in Queen Anne’s County), there is no oyster fishery to speak of and crabs are scarce. As goes the oyster goes the Bay. So ask all the environmental groups blaming poultry operations for the Bay’s poor health how it is that oysters are thriving in parts of the Bay nearest to most of the chicken houses while in the upper Bay where we have a relative few chicken houses oysters are non-existent. Perhaps it’s because chicken houses (and while we’re at it, septic tanks) are not major sources of pollution loading to the Bay. Where phosphorus loading to the Bay is the concern, context is essential if we hope to achieve meaningful and measurable improvement to overall Bay water quality. According to a 2012 Chesapeake Bay Program report, Maryland’s annual average phosphorus loading to the Bay from agriculture is 985 tons (1,970,000 lbs.). Meanwhile, the average annual phosphorus loading from the Susquehanna River (the largest tributary feeding the Bay) is no less than 3,300 tons (6,600,000 lbs.), not including what is scoured from behind Conowingo Dam and the other reservoirs in the lower Susquehanna River during storm events and now on a more regular basis because of lost trapping capacity. According to the U.S. Army Corps of Engineers, with the reservoirs for the dams in the lower Susquehanna River now being full, the amount of annual phosphorus loading from the Susquehanna River to the Bay is increased by 70% to 5,600 tons (11,200,000 lbs.). So from upstream pollution sources - including less regulated Pennsylvania farms - the Susquehanna River dumps nearly 600% more phosphorus each year into the Bay than the phosphorus loading attributed to all Maryland agriculture. Making matters worse, and magnifying the absurdity of finger pointing at chickens, is the estimated 130,000 tons (260,000,000 lbs.) of phosphorus accumulated behind Conowingo Dam waiting to be scoured into the Bay in shock loading proportions during the next storm event. Letter to The Daily Times Editorial Board September 18, 2015 Page 2 of 2 From the filing of Freedom of Information Act requests, we know for a fact that a March 2015 report titled “Understanding Nutrients in the Chesapeake Bay Watershed and Implications for Management and Restoration – the Eastern Shore” by the U.S. Geological Survey included photo-shopped satellite imagery and erroneous data. The gist of this USGS report, also known as Circular 1406, is that agriculture on the Eastern Shore of Maryland (which constitutes only 7% of the 64,000 square mile Bay watershed) is the leading culprit of the “ecological and economic degradation of the bay in recent decades.” However disingenuous, it was no surprise to Coalition county officials that USGS timed the release of Circular 1406 to coincide with the General Assembly session while the phosphorus management tool (PMT) legislation and regulations were being debated. In fact, records obtained by the Coalition reveal that USGS rushed Circular 1406 in order for a high ranking USGS official to testify in support of PMT legislation and, most curiously, when the Chesapeake Bay Foundation and like organizations testified in support of the same PMT legislation they cited to USGS Circular 1406 before its completion and release to the general public. Now, to further exaggerate the “phosphorus problem” linked to Eastern Shore agriculture, comes the latest report by the Environmental Integrity Project (“More Phosphorus, Less Monitoring”) citing multiple times to USGS Circular 1406 – which we now know was rushed and manipulated to fit a false narrative targeting relatively minor sources of water pollution at significant expense to our economic and cultural environments. The moral of this story is that the purported “science” justifying sweeping measures such as one-sizefits-all septic regulations, inflexible stormwater management mandates and now a moratorium on the poultry industry warrant scrutiny and in many cases challenge. All of the organizations currently advocating for a moratorium on chicken houses in the name of saving the Bay, especially those using federal and State grants funds to carry on their latest crusade, should be challenged to explain how and why dredging and maintaining the reservoir above Conowingo Dam would not be more ecologically and economically beneficial to the overall health of the Bay and to Maryland’s efforts and expenditures to restore the Bay. We are wasting time, money and the public’s attention focusing on marginal pollution sources, while common sense and the best science tell us to be looking upstream at the single largest source of concentrated sediments, nutrients and other contaminants threatening the Bay. The Clean Chesapeake Coalition is an evolving association of Maryland local governments whose elected officials have coalesced to pursue improvement to the water quality of the Chesapeake Bay in the most prudent and fiscally responsible manner possible – through research, coordination and advocacy. Sincerely, CLEAN CHESAPEAKE COALITION Ronald H. Fithian Chairman and Kent County Commissioner