— “The PMT regulation has been withdrawn twice in Maryland and is currently the subject of a legislatively-mandated economic analysis,” Fry explained. “Preliminary economic results this fall are expected to show considerable cost to the farm community if implemented.”
Better Bay Model Data Needed
In its press release, EIP calls on the EPA to fix the Bay Model to make sure Best Management Practices (BMPs) are properly accounted for and are given the correct “efficiency” ratings. Maryland Farm Bureau agrees. We have asked EPA to fix the model for many years. The reason the EIP and EPA make the conclusions they do is that they are using a flawed Bay Model, which we have begged EPA to fix. Here a few examples of the Bay Model errors:
The model uses crop yield data that is outdated and in many cases incorrect. The basis for crop yield data is the U.S. Census of Agriculture. The census is conducted once every five years. Modelers used three census numbers averaged together to come up with initial yield estimates for crops. This means they are using yields that are 15 to 20 years old averaged with yields that may be as old as five years. Technology changes considerably from year to year. Farmers are producing a much higher yield using much less fertilizer now than five years ago and much less than 20 years ago. There is annual data yield data available and that should be used rather than outdated numbers.
Corn yield example – The current model is using one number for the entire Bay Watershed region – all the way from New York to Virginia - for corn yields. The model assumes all fields yield 109 bushels of corn per acre. Here in Maryland we average 143 bushels per acre. In fact, irrigated fields have an even higher yield – closer to 160 bushels per acre. This is important because the yield number is used to calculate a lot of other assumptions in the model including fertilizer use, organic fertilizer (manure) needs, excess manure and more. If one number is off is skews the entire model output for this sector.