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A new report from the Ohio Environmental Protection Agency (EPA) says ditches and streams that provide drainage for farmers' fields may not be adequate for sustaining aquatic life. OFBF is questioning whether that's an appropriate criteria for judging ditches.

OFBF submitted comments related to agricultural drainage in response to the EPA's Total Maximum Daily Load (TMDL) draft report for the Big Darby Watershed. TMDLs set pollution thresholds for waterways and determine which pollution sources will have to reduce or eliminate discharge.

The criteria are based on whether waterways are used for water supply, recreation or animal habitat.

"That's where we're running into some of our concerns in the Darby. We're looking at existing and proposed use-designations," said Larry Antosch, OFBF director of environmental research.

He said waterways created for agricultural drainage are being analyzed based on their ability to provide habitat for aquatic life. OFBF's concern is that farmers could lose their ability to efficiently remove excess water.

"You don't want to lose that capability just to make it a nice place for fish and bugs to live," Antosch said.

He said there are ways to improve habitat while maintaining drainage, such as enhancing riparian zones or alternative ditch designs, but they require taking additional land out of production.

"The benefit that society is getting out of a better habitat -- the cost is being borne by the landowner," he said.

Producers are already addressing concerns about nutrient application and sediment loss through voluntary programs such as the Livestock Environmental Assurance Program, the Agricultural Watershed Awareness and Resource Evaluation program and the Producer Environmental Self-Assessment Program, he said.

OFBF reviewed the report also to ensure a proper methodology was used to gather and analyze data, Antosch said. During the review of a past TMDL project, OFBF argued that it was wrong for EPA to assume that bacteria in a stream came from livestock.

"The bacteria loading model didn't take into consideration the ducks, the geese, the deer appropriately," Antosch said. "It becomes a blanket statement that we have to stop livestock access to streams."

Researchers are starting to use DNA analysis of fecal coliform bacteria to determine if the source is livestock, wildlife or septic tanks, he said.

Speaking at a recent OFBF conference in Columbus, environmental attorney Jack Van Kley said farmers need to be more involved with TMDLs.

"A TMDL simply tells the EPA how strict permit regulations have to be," Van Kley said. "Basically (farmers) are waiting until the hammer comes down, and by then its too late."

Antosch said the challenge is finding the time to devote to the TMDL process. The assessment, development, implementation and validation phases of TMDLs can take four years, and many of the public meetings are held during the day, which makes it difficult for farmers to attend.

Antosch said farmers need be involved to let the EPA know what solutions are acceptable.

"They have some local knowledge that they can bring into the process to identify issues or concerns, or to validate findings, or to say 'no you're not right,'"he said.

A new fact sheet titled "TMDLs: What the heck are they?" is available at www.ofbf.org by clicking Ecology of Agriculture, Issue Analysis then A.E.I.O.U. Series. For EPA's list of TMDL projects in Ohio click on Featured Links.