Direct Testimony of Thomas M. Hildebrand - Consumer Advocate ...

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we can get the greatest reduction for our limited financial resources. As with any
pollution management program, the greatest clean-up gains per dollar spent are
made from initial regulation. lust by implementing accountability standards and
establishing management programs, great pollution reductions are achieved in
the initial stages of poilution management, It is the later stages, generally those
that are working to virtually eliminate pollution from a particular source, that are
overwhelmingly costly. In the case of clean water, point source regulation has
been ongoing since the 1972 CWA, but non-point regulation has been severely
lacking and thus presents the greatest opportunity for pollution reduction,
Investing in Clean Water
A 2004 report by the Chesapeake Bay Commission identified six least-cost
options to clean up the bay. Five of them focused on agriculture and non-point
sources, indicating just how underdeveloped such programs are. The remaining
suggestion is just what the Harrisonburg-Rockingham Sewer Authority is doing,
upgrading its plant to the limit of present technology. They estimated that these
six options, if implemented, could achieve 75% of the reduction goal for Nitrogen
at the relatively low cost of $623 million total for all the bay states, but each
come with their own individual cost. As seen in figure 2 below, while water
treatment facility upgrades have great potential for reducing nitrogen loads, they
are the most expensive reductions to achieve per pound,
NITROGEN
PHOSPHORUS
SEDIMENT
Measures M. Ibs. $/lb.
Waste Treatment 35.0 8,56
Upgrades
Diet and Feed
Changes
Nutrient
Management
Enhanced Nutrient
Mgmt.
13.6 1.66
23.7 4.41
Conservation Tilage 12.0 1.57
CoverCrops 23.3 3.13
M. Ibs. $/lb. M. Ibs. $/lb.
3.0 74.00 na
0.22 0.00 na
0.80 28.26 na
0.80 95.79 na
2.59 1.68
0.44 0.22
na=Not applicable - = No additional cos
t
Implications
Total potential reductions for nonpoint
sources (2-6) at the edge of the field*
Totai potential reductions for nonpoint
sources (2-6) delivered to the Bay**
Total potential reductions for ail six
practices (1-6) delivered to the Bay**
Bay Agreement reduction goal (2002-
2010)
NITROGEN PHOSPHORUS SEDIMENT
53.6m lbs. 2.93m Ibs. 1.35m tons
45.4m Ibs. 1.99m Ibs. 0.90m tons
80.4m lbs. 4.99m ibs. 0.90m tons
103m ibs. 6.7m Ibs. 0.90m tons
* The reductions attributed to each agricultural practice ae less when
combinedwith outer practices on the same land. Therefore, the expected ttoal
reduction from combing agricultural practices is less than their sum.
** Agricultural reductions are measured at edge of field, and are reduced by
the time they reach the bay; this results in totla reductions in loadings from
those six practices as indicated. Waste treatment plant reductions estimates
are as delivered to the bay.
Figure 2: Nutrient reduction by cost. Source: Chesapeake Bay commission
"Cost-Effective strategies for nutrient and sediment reduction" 2004
Why then, did the state choose to promote this reduction above the others
suggested in the report? Primarily, point source reductions are the most
convenient to enforce, A monitoring structure is already in place for point source
reduction, and there is great potential for reduction in this category. Additionally,