In advance of the Senate Republican Policy Committee’s planned hearing on Senate Bill 724 (P.N. 730), the Pennsylvania Environmental Council would like to share our concerns with this legislation. While, on its face, SB 724 appears to further Pennsylvania’s ability to meet its commitment to cleaning up the Chesapeake Bay Watershed, in reality this legislation may only benefit impractical pollution management practices.
The Total Maximum Daily Load credit purchase process outlined in the bill will only attract large, capital-intensive treatment systems. Farmers who desperately need assistance to install best management practices to control nutrient and sediment runoff will not have the resources to participate in the proposed RFP process.
In addition, the bill does not require those participating in the RFP process to have their management practices approved by the U.S. Environmental Protection Agency (EPA) Chesapeake Bay Program, nor does it require the “credits” generated by the process to meet EPA or Department of Environmental Protection regulations.
As a result, Pennsylvania could be forced to overpay for “credits” that are not approved and do not count toward our Chesapeake Bay commitments; taxpayers would be left holding “credits” that cannot be traded to any facility or developer because they do not meet regulatory standards. The bill also offers no funding for the Department to undertake the RFP process or to buy the “credits” created under the bill.
Pennsylvania is facing a 2017 deadline to install on-the-ground practices to meet specific milestone commitments to clean-up the Susquehanna basin. If we do not meet those milestones, the EPA has the authority to step in and impose measures that may prove undesirable to many communities and citizens. We already have the tools on the books to promote least-cost, effective conservation practices. We need to fully support them, and to do so now.
Senate Bill 724 would promote unproductive practices at significant potential cost, and should be opposed as currently written. We would be happy to answer any questions you may have.
Thank you for your consideration.