Honorable Members of the Maryland General Assembly Joint Committee on Administrative, Executive, and Legislative Review and other esteemed officials:
We the undersigned are concerned citizens from many and varied professions, areas of employment, and points of view. One thing we have in common is the grave concern for the economic impact on the state of Maryland in general, and the Eastern shore in particular, related to the implementation of the Phosphorus Management Tool legislation.
We feel strongly that it would be premature and extremely unwise to rush this onerous regulatory scheme through your committee without subjecting it to the kind of scrutiny that its’ projected impact on the Maryland economy would appear to warrant.
We would request that you support a committee public hearing to allow additional information to be presented, and that a ‘hold’ be placed on the legislation until it can be thoroughly vetted.
What is already known is that the Phosphorus Management Tool is not capable of determining how much less phosphorus will reach the waters of the state. Without those data, it makes little sense to adopt a regulation just for the sake of adopting it. Dr. Memo Diriker at Salisbury University, author of a Maryland Department of Agriculture study entitled, ‘A Scenario Analysis of the Potential Costs of Implementing the Phosphorus Management Tool on the Eastern Shore of Maryland’, has stated that he could find no data on water quality improvement, despite asking for them. It is important to know what the benefits of a regulation will be before it is put into place.
Secondly, Dr. Diriker estimates that over the next six years, the costs to Maryland’s agricultural community will be $22 million. He also estimates that $39 million in state assistance will be needed. These are likely conservative estimates which cannot take into consideration the inevitable unintended consequences and the additional costs so associated.
And given the dire state fiscal situation, with additional revelations and forecasts of shortfalls in this year’s budget and a growing structural deficit, it‘s worth asking whether that money will even be available? Rather than rush to enact a highly impactful regulation with many unanswered questions we would encourage you to exercise your wise and careful deliberation with full consideration of the consequences, both known and projected, prior to allowing this bill out of your committee.
Maryland’s farmers are making progress on water quality improvements ahead of schedule as shown by the most recent analysis from the Chesapeake Bay Program office. But as reported by the U.S. Geological Survey, water quality improvements due to better on-the-farm practices might not show up for years because of the slow movement of sub-surface water. Let’s allow the results of these earlier practices to show results before adding on another layer of mandates. Please allow a full hearing and consideration of our input and concerns prior to acting on this legislation.
Thank you for considering our views as concerned citizens of Maryland.
The members of the Wicomico County Republican Central Committee