Every once in a while we get a peek at someone who goes beyond the headlines and offers up something more like sense and sensibility.
No, I’m not writing Jane Austen visits Virginia. More like Austen meets de Tocqueville in Tappahannock – in other words, logic and passion and the Chesapeake Bay.
Last month, Molly Pugh offered testimony about how to protect the Chesapeake Bay from the perspective of the Virginia grain producers. Sounds dreadfully dusty and dry, I suppose, but behind the husk we find a grain of truth. Indeed a whole bushel of truths.
Molly Pugh is the Executive Director of the Virginia Grain Producers Association. Speaking before the U.S. House Transportation and Infrastructure Subcommittee on Water Resources and Environment, Pugh’s testimony laid out facts and principles that, had they been the keystone of prior decades of Chesapeake Bay policy, would have resulted in a Bay much further along in its recovery.
One of the great mysteries surrounding Bay policy is its over-reliance on a big, complex and ultimately inaccurate computer model run by EPA’s Chesapeake Bay Program. This model is not only supposed to identify who is polluting, how much they pollute and how that affects the Bay, but also explain who should stop polluting and how that will improve the Bay. From this the government establishes the Total Maximum Daily Limit for the Bay, a policy decision that determines how much pollution can enter the Bay from Virginia. Thereafter, the Commonwealth is expected, (some would incorrectly say ‘is required’) to sets enforceable limits on pollutors.
But what if the computer model is wrong? What if enforceable limits are disconnected from reality? Those are the problems Ms. Pugh pointed out, and with considerable intellectual force.
At present, the model assumes that between one-third and one-half of the Bay’s pollution comes from agriculture. Maybe – although actual water quality analysis is fairly sparse and EPA acknowledges the model relies on very old data. But, let’s start with that assumption – agriculture is a big contributor. The question then arises, how much more pollution control can farmers offer. One would begin with knowing how much pollution control already exists. Then one could estimate how much more there is to get. And, therein lies the rub.
In her testimony, Pugh said: “We are highly concerned that the obvious lack of complete data about current implementation of conservation practices significantly skews water quality reports and publishes misleading pollution load reduction assignments for any one sector.” She based her statement on facts that explain why the computer model results cannot possibly be correct.
In Virginia there are about 1.1 million acres of land in small grain and corn production. Virginia Tech examined the leading conservation farming pollution control practice, continuous no-till agriculture, an approach capable of reducing pollution run-off by over 90 percent. Virginia Tech reported that 40 percent of the 1.1 million acres used continuous no-till practices in 2007, but the model used by EPA does not take all 40 percent into account.
Pugh explains how EPA uses this data. Tech’s 2003 survey showed that out of 75,630 cropland acres in conservation practices that year, only 5,630 were supported through an incentive based government program. In other words, 70,000 acres in Virginia’s Coastal Plain region alone were neither counted nor reported in the Chesapeake Bay Program Model. Because EPA only counts subsidized conservation practices, the computer model failed to account for 92 percent of the pollution controls in place in 2003. There is every reason to believe that the model continues to significantly under-count pollution control from agricultural land and does so statewide.
Today, well in excess of 90 percent of Virginia’s cropland east of Route 95 is in continuous no-till planting, leaving little left to control on half of all Commonwealth crop land. There are some additional benefits that can come from still more advanced farming techniques – techniques that, like no-till, can increase profitability to the farmer. But with each advance, the amount of pollution prevention you can squeeze out of a crop farmer becomes less and less.
Clearly, as Ms. Pugh points out, it is time to make the computer model reflect reality. It is time to base decisions on actual observations. It is time to rely on science. It is time for honest peer review of the EPA computer model. It is time to limit EPA’s authority to arbitrarily change a state’s comprehensive plan. It’s time for both sense and sensibility. You can read the entire Pugh tesimony here. It’s a good read because it is Amercian Exceptualism incarnate. de Tocqueville would have been proud of Ms. Pugh’s contribution. So should Virginians.