Ball Ford Compost Facility expands to Food Recycling

 A ribbon cutting was held in mid-September to mark the completion of the Balls Ford Composting Facility expansion. Prince William County residents have long been encouraged to bring yard waste, such as grass, leaves and small branches, to the Balls Ford Road Compost Facility in Manassas.

With the newly completed $10 million two year expansion has nearly tripled its capacity to produce compost. In addition to yard waste, the facility can now recycle food waste using state-of-the-art composting equipment and processes. Freestate Farms, who operates the Balls Ford Road Facility paid for the expansion  This is a part of the Prince William County’s efforts to recycle more, be more sustainable, to take more material that previously went into the landfill and make usable soil amendments to improve our environment.”

Before the expansion, yard waste of leaves, grass and brush is piled high into long rows that have to be manually turned with heavy equipment. The new system will significantly decrease the time it takes to make compost. According to Prince William County’s Acting Director of Public Works, Tom Smith “The new facility will use an advanced aerobic composting technology where the leaves and grass will be mixed and placed in large bunkers. Those bunkers will have a series of pipes underneath so air can be drawn … through the piles. It will be constantly monitored by computers, so it’s a much more efficient operation. The process now takes six to nine months. Under this new system, we can have compost within 30 to 45 days.”

The air used in the bunkers will also pass through bio-filters to control any smell that might otherwise come off of the composting piles, Smith said.

Turning yard and food waste into compost at the facility will keep tons of this material out of the landfill. Mr. Smith went on to say that collecting this type of waste, which would normally enter the landfill, would increase the useful life of the county’s main landfill past its current lifespan of 2060. “Based upon studies we have done, approximately 30 % of the waste going into the landfill is organics, leaves, grass, food waste, etc. If we can divert that waste into this facility to make usable products, we can increase the landfill life by 10 to 15 years.”

Freestate Farms will ultimately employ 20 to 25 people at the facility. The company will profit from the operation by charging commercial interests a “tip fee” on a per-ton basis. The company will also sell the compost, fertilizer and mulch it creates from organic waste. Residents will not be charged to drop off organic material and can purchase the products at competitive prices, Smith said.

If you are thinking of composting food waste at Balls Ford Road, you might want to bring your glass bottles and jars with you. If you bring glass bottles and jars to the compost facility and place them in the purple bins they will be recycled/reused. All colors of glass- clear, green and brown of glass food and beverage bottles and jars are acceptable for recycling/reuse and can be place in the purple bins.

Do not place glass dishes, drinking glasses, vases, shower doors, windshields, window and door glasses, and mirrors in the purple bins.  Put those items in the trash.

Hard Water Treatment Options

Water contains traces of minerals that are essential for human health. Water picks up tiny amounts of minerals and metals from rocks and soils. In elevated concentration these miners can be a nuisance, but in small enough quantities they improves the taste of water and provide essential elements. In many parts of the country water, especially groundwater contains high levels of dissolved calcium and magnesium ions. This is what is known as hard water. For generations water softeners have been sold to treat almost all well water ailments. They have been overused, and are bad for the environment and septic systems. There are other ways to treat water problems.

Water containing approximately 125 milligrams of calcium, and magnesium per liter of water or 7 grains per gallon can begin to have a noticeable impact and is considered hard. Concentration of magnesium and calcium above 180 milligrams per liter (10.5 grains per gallon) is considered very hard. As the mineral level climbs, there are observed impacts in our homes. Bath soap combines with the minerals and forms a pasty scum that accumulates on bathtubs and sinks. Hard water spots appear on everything that is washed in and around the home.

Many can live with the water spots and soap scum issues by adding vinegar to dishwashers and using hard water formulated shampoos, but it is the potential impacts on plumbing and appliances that induces them to get a water softener. When heated, calcium carbonate and magnesium carbonate are removed from the water and form a scale (lime scale) in cookware, metal hot water pipes, dishwashers and water heaters. As the scale builds up more energy is required to heat the water and hot water heater and appliances have work harder which will burn them out eventually. Thus, in hard water locations hot water heaters and other appliances have a shorter life.

The ubiquitous water softening system is an ion exchange system consisting of a mineral tank and a brine tank. The water coming into the house must pass through the mineral tank before it can be used. The mineral tank holds small beads of resin that have a negative electrical charge. The calcium and magnesium ions (along with small amounts of other minerals) are positively charged and are attracted to the negatively charged beads. This attraction makes the minerals stick to the beads as the hard water passes through the mineral tank. Sodium from salt is used to charge the resin beads. As the water is softened, the sodium ions are replaced and small quantities of sodium are released into the softened water making it taste salty. It is reported that the 10-year life-cycle costs for new, high-efficiency water softeners was $4,000 for water with 150 mg/L hardness. However, cost is not the only problem with the ion exchange water softeners. The brine tank is flushed out when the resin beads are recharged carrying the salty solution to the environment. The salinity of surface waters and groundwater is an emerging environmental concern. Research has shown that salinization has affected over a third of the drainage area of the contiguous United States even in areas without road salt.

Some regulators in California, Connecticut, Texas, Massachusetts, Michigan and Minnesota have identified the use of ion-exchange water softeners as a major source of sodium chloride to both surface waters and groundwater. Households that use ion exchange water softeners typically use sodium chloride; and the used brine is regularly discharged to either wastewater treatment plants or septic systems. Which in turn releases it into the environment since neither septic systems nor waste water treatment systems can remove salt.

The Bureau of Reclamation, California State Water Resources Control Board, Santa Clara Valley Water District, City of Phoenix, City of Scottsdale funded a study: “Evaluation of Alternatives to Domestic Ion Exchange Water Softeners.” The study took place in 2014 and was led by Peter Fox, Ph.D., a Professor at Arizona State University. They examined what in the industry is called water conditioner. Water conditioners often called “salt-free water softeners” do not remove calcium or magnesium, but rather render then less likely to deposit hard lime scale.

Using literature search to identify likely candidates, the researchers used DVGW – W512 the test physical water treatment techniques. DVGW-W512 is the test methodology used to determine effectiveness of water conditioning devices to prevent or reduce scaling in drinking water heating systems. The researchers measured scale reduction in water to see if physical water treatment techniques work. They looked at systems that did not require chemicals to be added to the water and the most promising techniques based on the literature review. These physical water treatment devices tend to work by forming subicron crystals of calcium carbonate that remain suspended in water and do not remove the calcium carbonate, so a water analysis would not have proven if these devices held the potential to be effective.

The researchers tested Template Assisted Crystallization, Electromagnetic treatment and electrically induced precipitation. They found that Template Assisted Crystallization worked best reducing lime scale by more than 95%. Both Electromagnetic treatment and electrically induced precipitation reduced scale formation by 40%-50%. The scale formed in the by the latter two was “soft” scale that easily brushed or washed off. The test does not determine long term accumulation

Water conditioners sold on the market today (six years later) work through a process called template assisted crystallization (TAC), have been certified by DVGW-W512 and are available in whole house units. In template assisted crystallization, water flows through a tank of TAC media. This media consists of tiny polymer beads covered in craters called “nucleation sites.” These nucleation sites act as templates to form the hardness micro-crystals. When the hard water comes into contact with the media, the magnesium and calcium ions are caught by the nucleation sites. As more calcium and magnesium ions build up within the sites, small micro-crystals form. and apparently retain their crystalline structure as they flow through your plumbing. They do not attach themselves to your water pipes as scale.

Electrically Induced Precipitation – An applied current induces the formation of “soft” scale on an electrode that must regularly cleaned off. I have seen this phenomena in my electric kettle which only requires a damp cloth to remove the soft scale while my old stove kettle needed to be replaced every few years. The scientists demonstrated why this was true in their tests.

Though magnetic devices have been sold for ages, there are none certified and no consistent standard. However, the researchers found that electromagnetic fields they created at the strength indicated in their study can reduce the formation of lime scale. There is no scientific consensus as to the effectiveness of magnetic water treatment and its removal mechanisms. No devises have been tested and certified. However, Dr. Fox’s team did test an electric current induced magnetic field around a pipe. That seemed to produce a soft precipitate.

These physical water treatment devices  do not remove the hardness minerals from the water, but to varying degrees reduce some of the problems associated with hard water. Today, water conditioners sold as “salt-free water softeners” are based on template assisted crystallization (TAC). Though these water conditioners do prevent the build up of lime scale, they do not produce soft water. Water softeners have been used for generations not only to prevent lime scale, but to remove low levels of iron, manganese and radionuclides from water. Iron can cause staining of sinks and fixtures, affect taste of drinking water, and contribute to pipe blockages. Iron and manganese can be removed with an iron filter or chlorination and filtration. Long-term exposure to high radionuclide levels can have many negative health effects. Reverse osmosis is effective in removing radionuclide levels, though some local health departments recommend replacing the well if possible. For generations the salt based water softener has been sold to remove other contaminants, but there are other options. Water conditioners can address lime scale.  Know your water chemistry and what contaminants you want to remove before buying any water treatment equipment.

Consider Climate Migration

Over the summer the New York Times did a series of article on climate migration. Fifteen years ago using some fairly crude extrapolations of the published climate projections my husband and I decided we should leave California. After retiring and studying our options, we made a bet on Virginia hoping that my crude estimates based on climate projections from the various models at the time were good enough. We chose northwestern Prince William County; the factors taken into consideration- water availability, distance from the coast, elevation, along with proximity to family, medical service, an airport and green spaces.

We proceeded to future proof our home, creating a French drain system and adding permeable pavers, a generator and solar panels. In 2016 the U.S. Environmental Protection Agency (EPA) said: “Virginia’s climate is changing. Most of the state has warmed about one degree (F) in the last century, and the sea is rising one to two inches every decade. Higher water levels are eroding beaches, submerging low lands, exacerbating coastal flooding, and increasing the salinity of estuaries and aquifers. The southeastern United States has warmed less than most of the nation.”

The EPA went on to state that “Tropical storms and hurricanes have become more intense during the past 20 years. Although warming oceans provide these storms with more potential energy, scientists are not sure whether the recent intensification reflects a long-term trend. Nevertheless, hurricane wind speeds and rainfall rates are likely to increase as the climate continues to warm.” They continue pointing out that “sea level is rising more rapidly along Virginia’s shores than in most coastal areas because the land is sinking. If the oceans and atmosphere continue to warm, sea level along the Virginia coast is likely to rise sixteen inches to four feet in the next century.“ 

From the Fourth National Climate Assessment released in 2018:“Because warmer air can hold more moisture, heavy rainfall events have become more frequent and severe in some areas and are projected to increase in frequency and severity as the world continues to warm. Both the intensity and rainfall rates of Atlantic hurricanes are projected to increase with the strongest storms getting stronger in a warming climate. Recent research has shown how global warming can alter atmospheric circulation and weather patterns such as the jet stream, affecting the location, frequency, and duration of these and other extremes.”

That certainly covers the high number of tropical storms this year. Though I read that with concern we are more than 30 miles from the shore, about 350 feet above sea level and there has been no flooding in our immediate area. So far, so good with our guessing. Sadly, no matter what mankind does in the next couple of decades, the expected impacts from climate change are still going to happen. It's too late to prevent it from happening. Any actions mankind takes now or in the next decade can only impact the second half of the 21st century. The climate for the next 20-30 years is pretty much baked into the existing level of carbon dioxide in the atmosphere.

“Because Earth’s climate system still has more energy entering than leaving, global warming has not reached equilibrium with the load of increased greenhouse gases that have already accumulated in the atmosphere (for example, the oceans are still warming over many layers from surface to depth). Some greenhouse gases have long lifetimes (for example, carbon dioxide can reside in the atmosphere for a century or more). Thus, even if the emissions of greenhouse gases were to be sharply curtailed to bring them back to natural levels, it is estimated that Earth will continue warming more than an additional 1°F by 2100.”

Though a new research paper was able to narrow the likely total temperature range to 4.7-7.0˚F. (This is equivalent to between a warming range of between 2.6°C and 3.9°C.) That research was conducted under the World Climate Reasearch Programme (WCRP) and funded in part by The Department of Energy Office of Science, Office of Biological and Environmental Research, published this past summer in Reviews of Geophysics available for free at this link. 

Now is the time to consider the what the future might hold and plan appropriately. Climate changes and population growth can combine to make some places increasingly challenging to live. For example; extreme rainfall combined with coastal flooding, can increasingly and repeatedly flood homes or make roads not passable. In other locations drought coupled with extreme heat, wildfire, and flooding can result in routine water restriction inability to maintain year round electricity 24/7, loss of property and even life, a higher instance of landslides that disrupt transportation systems. The compounding effects of these impacts result in increased risks to people, infrastructure, and the economy. Even if all of mankind takes immediate and drastic action to fight climate change it is very likely that some impacts, such sea level rise, weather pattern and others will not be reversed for hundreds of years.

Genetically Modified Mosquitoes to be released in Florida

In August the Florida Keys Mosquito Control District (Mosquito Control District) Board of Commissioners voted to allow the release of Oxitec’s Genetically Modified Aedes aegypti mosquitoes in 2021. This comes after a decade of study, focus groups and regulatory approvals for the project by the U.S. Environmental Protection Agency (EPA), the U.S. Centers for Disease Control and Prevention (CDC), and seven State of Florida agencies, including the Department of Health. A petition against the project had more than 25,000 signatures according to Science News.

This project will be overseen by Mosquito Control District, the EPA and the Florida Department of Agriculture and Consumer Services (Department of Agriculture). Independent evaluation of the project will be provided by the U.S. CDC, the University of Florida, the Department of Health, and local leaders.

Aedes aegypti mosquitoes are a non-native species in the United States. They can spread serious diseases such as dengue fever and chikungunya and are a known carrier of Zika. The Florida Keys Mosquito Control District has been working hard to reduce the Aedes aegypti population to control dengue fever and chikungunya, but spraying of mosquitos has only limited success in controlling the population. There were in August 47 cases of dengue fever that were locally acquired.

Using advanced genetics and molecular biology Oxitec has developed a genetically modified Aedes aegypti mosquito that is designed to control the Aedes aegypti mosquito population. Oxitec has used genetic modification to create male insects which seek out and mate with females. Male mosquitoes do not feed on blood (bite). After an Oxitec mosquito has successfully mated with a wild female, any female offspring that result will not survive to adulthood, and the male offspring will survive to become fully functional adults with the same genetic modification, providing multi-generational effectiveness that could ultimately lead to a reduction in Aedes aegypti mosquito populations in the release areas.

This approach is targeted at a single species, unlike conventional insecticides or pesticides which kill insects indiscriminately. According to the company, this is more effective and is much better for the environment than pesticide spraying. In the field trial the Oxitec modified mosquitoes will be released and monitored in an area of the Florida Keys over a year. Open field trials of the Oxitec genetically engineered mosquito have been conducted in Brazil, the Cayman Islands, Panama, and Malaysia. EPA anticipates that this could be an effective tool to combat the spread of certain mosquito-borne diseases in light of growing resistance to current insecticides. This will be the first release of any genetically modified mosquitoes in the United States.

The genetically modified mosquitoes have been engineered to encode a conditional or repressible lethality trait, which is a function of the overexpression of the tetracycline-repressible transactivator (tTAV) protein, and a red fluorescent marker protein. When tetracycline is not present, tTAV causes lethality in the female offspring of mating between genetically modified males and wild-type females. The fluorescent marker is used to identify the genetically modified mosquitos. In addition, according to Oxitec, the genetically modified mosquitoes are susceptible to pyrethroid pesticides which many Florida Keys Aedes aegypti mosquitos no longer are susceptible to. The field test will exclude areas where tetracycline may be openly available.

Maryland, Virginia and DC Sue the EPA

After months of threatening the Attorneys General in Maryland, Virginia, Delaware, and the District of Columbia filed suit in the District of Columbia Federal District Court against the U.S. Environmental Protection Agency (EPA). The suit charges EPA with failing to meet its responsibilities under the Clean Water Act. This was preceded by a complaint filed last week by the Chesapeake Bay Foundation (CBF) and its partners who filed a complaint against the U.S. Environmental Protection Agency (EPA) in the District Court for the District of Columbia charging EPA with failing to meet its responsibilities under the Clean Water Act by letting Pennsylvania and New York fall short in their nutrient and sediment pollution reduction goals in their latest plan for the cleanup of the Chesapeake Bay.

In their press release CBF President William C. Baker said “This is the moment in time for the Chesapeake Bay. If EPA fails to hold Pennsylvania, and to a lesser extent New York, accountable the Chesapeake Clean Water Blueprint will be yet another in a series of failures for Bay restoration... But unless pressure is brought to bear on Pennsylvania, we will never get to the finish line.”

The Chesapeake Bay Clean Water Blueprint was created by issuing a Total Daily Maximum Load (TMDL) limit for each contaminant; nitrogen, phosphorus and sediment in each segment of the Chesapeake Bay Watershed. The Watershed encompasses portions of six states and Washington DC. EPA used their existing authorities under the Clean Water Act to threaten “backstop measures” (reductions in the allowed nutrient releases from the permitted operations of wastewater treatment plants and MS4 outfalls) to ensure that all six states and the District of Columbia are accountable for implementing their share of the Bay TMDLs’ nitrogen, phosphorus and sediment reductions. Though the Chesapeake Bay TMDL itself “does not impose any binding implementation requirements on the States,” the EPA using the jurisdiction granted under the Clean Water Act and the agreements among the Bay jurisdictions, together, have legal authority to ensure the implementation of Chesapeake Bay Clean Water Blueprint. 

from EPA

In 2010 the EPA set a limit for release of nutrients into the Chesapeake Bay watershed that were then partitioned to the various states and river basins based on the Chesapeake Bay computer modeling tools and monitoring data. Each year, EPA evaluated the progress of the Bay jurisdictions based on reports of implemented practices and mitigation. The model then estimates the amount of nitrogen, phosphorus and sediment that would make it to the Bay under average conditions.

In 2017 when we reached the mid-point in the Chesapeake Bay Clean Water Blueprint, the EPA assessed the progress toward meeting the mandated nutrient and sediment pollutant load reductions. Using the Chesapeake Bay model, this midpoint assessment measured the state’s progress towards meeting the 2017 goal of having practices in place to achieve 60% of the pollution reductions from the 2009 levels.The intent of the midpoint assessment was to the jurisdiction to make changes in their programs and plans and develop the Phase III Watershed Implementation Plans (WIPs) that will allow us to meet the 2025 Chesapeake Bay Clean Water Blueprint restoration goals.

All six Bay watershed states and the District were required to submit plans last year spelling out the measures each would take by 2025 to make the needed pollution reductions. Only the District of Columbia and West Virginia had met their 2025 goals ahead of schedule. None of the others were on track to reduce nitrogen by the needed amount, so the Watershed Implementation Plans were revised to meet the goals.

Most of the plans indicate that states will have to increase pollution-reduction efforts to meet their cleanup goals. But Pennsylvania’s and New York’s plans don’t even pretend to achieve their goals on paper. Pennsylvania’s falls short on curbing nitrogen, the most problematic nutrient, by about 25%, while New York’s was around 33% short. Pennsylvania’s plan also identifies an annual funding gap for cleanup activities of approximately $250 million a year through 2025.

Those filing the lawsuits say that’s not enough. Unless the federal government holds all the states accountable for doing their part to reduce nutrient and sediment pollution, the decades long effort to restore the Chesapeake Bay’s water quality will fail. “The courts must ensure that EPA does its job,’’ Will Baker, the Bay Foundation president, said in an online press conference held with attorneys general from Maryland, Virginia and the District. Neither Pennsylvania nor New York are are defendants in the lawsuits, though the alleged shortcomings of their WIP III's is the issue of both complaints.

CA Fire: Continue to Burn, Air Quality Critical

In mid-August California experienced more than 15,000 lightning strikes from a pair of tropical storms that crossed northern California. This unusual amount of lightning combined with high temperatures, strong winds, forests that had been decimated by beetle infestations, the extended drought and had not been thinned for years and years resulted in an unprecedented series of wildfires that included the August Complex Fire which is the largest fire in the state’s recorded history.

As reported by Cal Fire on September 13th, since the beginning of 2020, wildfires have burned over 3.3 million acres in California. The acres burned is 26 times bigger than the acres burned in 2019 for the same period, and the total acres burned is larger than the State of Connecticut. There have been 20 fatalities and over 4,100 structures destroyed. The August Complex Fire increased significantly in acreage due to the merging of the Elkhorn, Hopkins, Willow, and Vinegar fires and was 24% contained on Sunday. Cal Fire has issued a Fire Weather Watch in effect Monday over the Northern Sierra because of gusty winds that potentially impact the North Complex that is only 26% contained.

Nonetheless, weather conditions have improved somewhat and the firefighters gained ground on the many of the wildfires that began three weeks ago in mid-August.” Friday there we more than 16,750 firefighters on the line of the 29 major wildfires burning across California. Although 33 new fires were sparked on Thursday, crews contained most of them quickly. It seems that Cal Fire will finally be able to contain the fires. “

Generally, the U.S. has good air quality. The hot spot in Virginia is Bull Run Mountain whose air monitor gauge has failed. 

Air quality in California for much of the state is “Unhealthy to Hazardous” due to all the smoke and particulates in the air. For a couple of days there California had recorded the worst air quality of any place on earth. Now that title is moving to Oregon.

Poor air quality can hurt the very young, the elderly and the sick. When particulate pollution is high it is best to stay indoors. On hot summer days even in areas without wildfires, air quality can be impacted. Long term exposure to particulate pollution can cause premature death in people with pre-existing cardiac or respiratory disease.

Air pollution in the form of fine particles with diameters smaller than 2.5 microns, called PM 2.5, lodge in the lungs which can aggravate other conditions both immediately and long term. This fine particulate matter can have immediate health impacts: itchy, watery eyes, increased respiratory symptoms such as irritation of the airways, coughing or difficulty breathing and aggravated asthma. Long term health effects can result from both short-term and long-term exposure to particulate pollution.

Air quality is typically measured with the Air Quality Index, or AQI. The AQI generally runs from 0 to 500 but in extreme hazard the scale can go up to 999. AQI tracks five major air pollutants: ground level ozone, carbon monoxide, sulfur dioxide, nitrogen dioxide, and airborne particles, or aerosols. However , airborne particles and aerosols seem to drive the score.

  The U.S. Environmental Protection Agency, EPA, requires states to monitor air quality and ensure that it meets minimum air quality standards. The US EPA has established both annual and 24-hour PM2.5 air quality standards (as well as standards for other pollutants). The annual standard is now 12 ug/m3 (an AQI of 39). The 24-hr standard is 35 ug/m3 (an AQI of 99.

Below is a look at California this past weekend. If you want to take a look at real time particulate pollution levels you can see what the monitors nearest your home are reporting. Recall that the levels are reported in AQI (0-50 AQI is good air quality and 51-99 is moderate air quality).

Dominion Keeping Nuclear Plants Running

In a news release last week Dominion Energy announced that they have filed an application with the Nuclear Regulatory Commission (NRC) to renew the operating licenses for the North Anna Power Station's nuclear plant for an additional 20-year term. If granted this will be the second 20 year renewal on top of the original 40 year for a grand total of 80 years.

The North Anna units are three-loop Westinghouse pressurized water reactors that can produce 1,892 MW, or about 20% of the electricity used in Virginia. Like all U.S. nuclear units, the North Anna units were originally licensed to operate for 40 years. The units' licenses were renewed for 20 additional years of operation on March 20, 2003, following a stringent review process authorized under federal law. Under its current licenses, the North Anna Units can continue to operate through 2038 and 2040. With renewed licenses, the units may operate to 2058 and 2060.

Dominion Energy filed a similar application to renew the licenses of the two Surry Power Station units in Surry County in 2018. The NRC is currently reviewing that application. Together Surry and North Anna produce approximately 30 % of the electricity used in Virginia. Previously, Florida Power & Light Co.'s Turkey Point reactors and Exelon Corp.'s Peach Bottom Nuclear Generating Station in Pennsylvania received license renewals that would allow them to operate for 80 years.

Nuclear power generation has found itself at the center of the nation's clean energy debate-is nuclear energy green because it is carbon free or dangerous? The industry sees the carbon emissions-free reactors as a chief way to meet carbon-free goals that states are mandating while maintaining reliability. The utilities view the nuclear power is essential for the baseload to avoid the rolling blackouts of recent occurrence in California. According to Dan Stoddard, Dominion Energy's Chief Nuclear Officer, "Renewing the licenses for both of our nuclear units in Virginia is critical to the company meeting the Virginia Clean Economy Act's requirements for zero-carbon electricity by 2045 as well as the company's net zero by 2050 commitment. It also positions Virginia for continued economic growth and will help the Commonwealth remain a leader in the production of clean energy among other states in the mid-Atlantic and South..."

Solar Farms in Virginia need Stormwater Management Plans

This summer Governor Ralph Northam officially launched Clean Energy Virginia, to push investment into renewable energy and help meet the Commonwealth’s of "100 % of Virginia’s electricity from carbon-free sources" by 2045. The Act requires Virginia’s two largest energy companies to construct 16,100 megawatts of solar and onshore wind power. If we learn from the experience in other locations we can avoid some of the problems they’ve faced and potentially avoid new ones.

In 2018 renewable resources generated less than 7% of Virginia's electricity, so we’ve got a ways to go. Biomass fueled more than 4% of the state's total electricity net generation and hydropower supplied nearly 2%. All renewable biomass sources emit carbon. Virginia does not have any wind-powered utility-scale electricity generation, yet . A test project, Coastal Virginia Offshore Wind, is to come on line this year in federal waters 27 miles off Virginia Beach. Virginia does have some solar power. Although solar PV electrical generation is less than 1%, it doubled in 2018. The largest share of solar PV generation in Virginia is provided by utility-scale facilities built in the last several years. So we will look at those.

An example of utility scale solar facility is the Remington Solar Power Facility developed as a public-private partnership with the Commonwealth of Virginia and Microsoft in 2017. The 20-megawatt project was built on approximately 125 acres of land acquired and owned by Dominion Energy near its Remington Power Station in Fauquier County, Virginia. The 125 acres is covered with almost 236,000 photovoltaic panels that at peak capacity can generate enough electricity to provide power for 5,000 homes.

from Dominion 

Though some of the 16,100 megawatts of solar and onshore wind power will undoubtedly ultimately be wind power, for the moment we will ignore that since only limited number of on shore locations in Virginia had high enough wind potential to support wind turbines. 

Doing a back of the envelop calculation 16,100 megawatts of solar PV generation would require 905,625 acres of land covered with 1,709,820 photovoltaic panels. According to the Farmland Information Center Virginia contains a total of 25,929,900 acres of land much of the land is covered with roads, towns, houses, federal facilities, state parks, and businesses. The only truly open land is agricultural and forested land. There were 8,184,600 agricultural acres in Virginia in 2016; however, 2,812,000 acres of that land was woodland. So that leaves 5,372,600 acres of crops or pastures in Virginia. In the all solar scenario the Commonwealth proposes to cover almost 17% of that land with solar panels (or a lesser amount and a portion in wind turbines). I will leave it to others to estimate the impact to food resources in Virginia instead look at other impacts.

Virginia is a wet state. It averages about 46 inches of rainfall a year, but in the last three rain years we’ve had more than 50 inches each year in Prince William. To a large extent we depend on our groundwater for drinking water supply. More than 25% of all drinking water in Virginia comes from groundwater. A solar farm has hard surface coverage over much of the land and can change the hydrology if the water resources and groundwater recharge are not part of the planning process.

When you convert agricultural field to a solar farm, land that would be open for stormwater infiltration and see minimal disturbance until planting is converted to a site that requires year-round accessibility by machines and workers during construction and operation. Solar arrays need maintenance and snow removal. Solar arrays cause concentrated or sheet flow to develop when it rains, though the hard surfaces may be discontinuous with solar panels arranged in rows; nonetheless the velocity of the stormwater increases. Even when there is vegetated surfaces (post-construction) in the dripline of each row, stormwater management and slowing the flow of the stormwater to encourage infiltration and reduce sediment flow must be planned carefully to maintain site hydrology after installation of a solar project. 

The key issues are the amount of hard surface and change in water infiltration and the amount of stormwater and sediment runoff and subsequent impact on surface waters. In many instances, stormwater management is not required under existing regulations. However, based on others' experience in other wet locations, stormwater management would be required to maintain the health and recharge of the watershed especially during design and construction to account for the changes in stormwater flow. In stressed groundwater basins, increasing hard surface coverage should be carefully considered before damaging the water recharge to our essential aquifers. Let’s not run out of drinking water because we decarbonized the power grid.

Clean Water Act is not a Universal Tool

Under the Clean Water Act, Congress explicitly directed the Agencies to protect “navigable waters.” Under the Clean Water Act, “the discharge of any pollutant by any person shall be unlawful.” 33 U. S. C. § 1311(a). “The discharge of a pollutant” is defined broadly to include “any addition of any pollutant to navigable waters from any point source.” 33 U.S.C. § 1362(12).

The Clean Water Act (CWA) of 1972 made it a crime to discharge pollutants from any point source into the "navigable waters of the United States." However, the U.S. EPA has continually tried to expanded what constitutes a "pollutant" or "navigable water" over the years. Especially in this century, the U.S. EPA attempted to manage new problems by illegally expanding the reach of old laws. This is wrong.

In 2015 the U.S. EPA attempted in defiance of the law’s own limits to expand protection and regulation under the 1972 Clean Water Act to include ephemeral streams, regardless of their size of frequency of flow, wetlands and open waters not in riparian areas and the 100 year floodplains; and to expand the definition of pollution to non-point sources of contamination including fill dirt and soil erosion. That version of the Waters of the United States was implemented under executive authority of President Obama and unleashed a torrent of Federal litigation.

Thirty-one states, many local governments, and private industry filed suite asserting that the rule unconstitutionally expanded the Clean Water Act’s reach and misapplied several Supreme Court decisions and long standing practice. The cases were consolidated before the Sixth Circuit in Cincinnati, which granted a nationwide wide stay in November 2015.

With that stay in place the Trump administration withdrew the rule. On January 23, 2020, the U.S. EPA and the Department of the Army (Army) released their Navigable Waters Protection Rule to define “waters of the United States” (WOTUS). Their rule lists four clear and common sense categories of waters that are considered “waters of the United States:”

1. Territorial seas and traditional navigable waters (TNWs)
2. Tributaries and intermittent rivers and streams that contribute surface flow more often than just after a single precipitation event.
3. Lakes, ponds, and impoundments of jurisdictional waters are jurisdictional where they contribute surface water flow either directly or through channelized non-jurisdictional surface waters, through artificial features, or through natural features.
4. Wetlands that physically touch other jurisdictional waters are “adjacent wetlands.”

This restored what could be regulated under the law to point source pollution discharge into rivers, lakes, streams and adjacent wetlands. Last month Science.org published an article by S. Mazeika Patricio Sullivan et al “Distorting science, putting water at risk (1)” damning the new rule as “inconsistent with science and (will) compromise the integrity of U.S. waters.” They are wrong in thinking expansion of the reach of the Clean Water Act is the way to manage the sustainability, availability and quality of the water ecology. Yes, wetland and ephemeral stream need legal protection, but they need protection from destruction not from point source discharge of pollutants.

I repeat, the Clean Water Act of 1972 made it a crime to discharge pollutants from any point source into the navigable waters of the United States. The regulation was intended to stop the free discharge of sewage and industrial waste into our rivers an it does that.

The authors of the Science article believe that hanging the law by expanding the definition of navigable waters to include wetlands, seasonal streams and any water that might at any time during the year impact or reach the navigable waters of the United States though any ecological means and ignoring the Clean Water Act’s requirement of a point source pollutant is necessary to protect the ecological benefits provided by these non-floodplain wetlands and ephemeral streams. In their zealousness the Science article authors would create a regulatory scheme that  is not only illegal but could be capriciously applied,  and as we’ve seen signed into law and signed out of law.

There needs to be a reasonable, obvious and consistent standard for navigable waters of the United States to protect them from industrial and waste water discharge. Over expansion of the definition of Waters of the United States would result in inconsistent determinations and a Kafkaesque regulatory process. That is unacceptable in the United States of America.

The proper way to protect the wetlands and seasonal streams that we now understand are so essential to a balanced ecology and healthy rivers and streams are regulations for the application of fill material, land use, non-point source pollution and other local issues. These are not issues address under the Clean Water Act. These are properly addressed on the state and local level. The Clean Water Act is the wrong tool. To speed the process for the national acceptance of these kinds of laws, Congress needs to act to create the basic framework for laws to protect the sustainability of our water resources for our future.

You can read the Science article for free  at https://science.sciencemag.org/content/369/6505/766.abstract

1. S. Mažeika Patricio Sullivan, Mark C. Rains, Amanda D. Rodewald,William W. Buzbee, Amy D. Rosemond; Distorting science, putting water at risk, Science  14 Aug 2020:, Vol. 369, Issue 6505, pp. 766-768 DOI: 10.1126/science.abb6899.