The Fertilizer Institute (TFI) has joined 29 agricultural and forestry organizations in submitting comments to the Environmental Protection Agency (EPA) regarding water quality regulations it is proposing for the Chesapeake Bay. The comments outline the agriculture and forestry community’s concerns with the EPA’s draft of total maximum daily load (TMDL) requirements, while calling attention to the significant contributions agriculture has made toward improving Chesapeake Bay water quality.

“The agriculture community supports water quality protection and is taking action at the ground level to prevent pollutants from reaching waterways. In fact, even EPA’s data shows that since 1985, the agriculture community has reduced phosphorus loadings by over 21%, nitrogen loadings by 27% and sediment loadings by 24% within the (Chesapeake) Bay watershed,” says Ford B. West, president of TFI.

TFI says that EPA’s models do not account for many of the voluntary agricultural and forestry practices that are currently being employed in the Chesapeake Bay watershed, therefore the draft TMDL fails to acknowledge the successful efforts of the agricultural community and others. The comments also criticize the EPA’s failure to provide sufficient information for the public regarding the draft TMDL and the models used to develop the requirements.

“By withholding adequate information regarding TMDL, EPA has inhibited the agriculture community’s ability to properly evaluate and comment on the requirements,” West says. “The agency has also made it difficult for policy makers and the public to understand the magnitude of the economic and social impacts of the draft TMDL and this has prevented a meaningful dialogue about the costs, benefits, and trade-offs among various policy choices.”

In addition, the agricultural groups’ comments suggest that EPA is stepping outside of the authority it has been granted by the Clean Water Act in order to impose the draft TMDL. Read more about TFI’s stance online at