What Are We Doing About the Bay TMDL?
We actively participate as a stakeholder in Watershed Implementation Plans on the state, county and local level. We are the sole NGO stakeholder participating in Bay TMDL implementation who is specifically dedicated to ensuring the health and vitality of the Susquehanna Watershed. In line with that mission, our unique citizen advocate organization is intently assessing Pennsylvania’s commitment and ability to fulfill its WIP obligations as a primary contributor of sediment, phosphorus and nitrogen to the Bay. We are particularly interested in the efficacy of Pennsylvania’s burgeoning nutrient trading program as a substantive means of pollution reduction, and in ensuring that state WIPs account for the effects of shale gas development on water quality.
We support the Bay TMDL, but we do not believe that, as a matter of law, the Clean Water Act allows nutrient trading as a mechanism for meeting pollutant reductions under a TMDL. Nutrient trading is not part of the Clean Water Act and further, has never been proven to achieve the stated goal of creating pollutant reductions. Instead, states should implement strong non-point source pollution control mechanisms; states possess CWA authority – but lack the political will – to regulate non-point sources of pollution. Non-point source pollution is the leading source of pollution to our local waterways and the Chesapeake Bay.
We engage scientists, educate and inform citizens, advocate among decision-makers, watch-dog state permitting, and remain passionately committed to ensuring transparency, accountability and enforceability. This means that we attend state and regional meetings where the nuts and bolts of implementing the Bay TMDL are decided. In addition, we watch-dog state permitting for polluting activities to make sure the law is followed. We are also part of the Choose Clean Water Coalition, an alliance of individuals and organizations from the Chesapeake Bay Watershed dedicated to clean water in the Chesapeake region. We also independently research scientific and legal questions that decision-makers and regulations fail to answer. Science, rule of law, and the health of the Bay and local waterways rightfully demand our strong commitment to meeting the Bay TMDL’s requirements.