Last Friday, January 6th 2012 I attended the Potomac Watershed Roundtable meeting in Warrenton, VA. The Potomac Watershed Roundtable is a regional forum open to Virginia citizens, community groups and local governments to promote collaboration and cooperation on improving and maintaining water quality of the Potomac Watershed. In recent years this has become about the Chesapeake Bay pollution diet, the Total Maximum Daily Load (TMDL) mandated by the EPA to the six Chesapeake Bay Watershed states (Virginia, Maryland, Delaware, New York, Pennsylvania and West Virginia) and the District of the Columbia. The meeting’s first speaker was Jeff Corbin, Senior Advisor to the EPA Administrator for the Chesapeake Bay.
The TMDL addresses only pollution from excess nitrogen, phosphorus and sediment. The TMDL does not address toxic, carcinogenic or endocrine disruptors that may be present in the Watershed. The excess nitrogen, phosphorus and sediment in the Chesapeake Bay cause algae blooms that consume oxygen and create “dead zones” where fish and shellfish cannot survive, block sunlight that is needed for underwater Bay grasses, and smother aquatic life on the bottom. The result is fish kills and murky water that threaten the aquatic industry and recreational use of the bay.
The TMDL sets a total Chesapeake Bay watershed limit for the six states and Washington DC of 185.9 million pounds of nitrogen, 12.5 million pounds of phosphorus and 6.45 billion pounds of sediment per year which is a 25% reduction in nitrogen, 24% reduction in phosphorus and 20 %t reduction in sediment from the current levels. The pollution limits are then partitioned to the various jurisdictions and river basins based on the Chesapeake Bay modeling tools and monitoring data. The Chesapeake Bay TMDL and the Watershed Implementation Plans (WIP) Phase I and II are designed to ensure that all pollution control measures needed to fully restore the Bay and its tidal rivers are in place by 2025, with at least 60 % of the actions completed by 2017. While it will take years after 2025 for the Bay and its tributaries to fully heal, EPA expects that once the required best management practices (BMPs) are in place there will be gradual and continued improvement in water quality as BMPs reduce the nutrient and sediment run off and better control storm water so that the Chesapeake Bay ecosystem can heal itself.
Since 1985 the excess nutrient contamination to the Chesapeake Bay has decreased, but the Bay’s waters remain seriously degraded. Phosphorus, nitrogen and sediment are released to the Chesapeake Bay Watershed by waste water treatment plants that service the millions of residents of the watershed, and by rainwater that percolates to the groundwater carrying excess nitrogen from septic and washes soil, nitrogen, and phosphorus into storm water and ultimately reaches the rivers, streams and bodies of water that make up the Chesapeake Bay Watershed. Though control of nutrient contamination has improved in all areas of the region, the massive growth of the population and expansion of developed land since 1985 has contributed to the nutrient and sediment pollution problem while the reductions in nutrient contamination have not come fast enough to meet the goals agreed to in the past. More needs to be done to have a healthy Chesapeake Bay and federal action was taken to enforce faster action.
The US EPA has taken control of the situation and can utilize what they call “back stop measures”, but are simply reductions in the allowed (permitted) releases from point source permits (waste water treatment plants, municipal separate storm sewer systems, and confined animal feed lots) to achieve the TMDL. At this time EPA can regulate only point source contamination, they cannot regulate non-point source contamination, which is runoff from roads, parking lots, yards and agricultural fields. The point source reductions are the most expensive way to achieve the reductions in nitrogen, phosphorus and sediment in the bay and would serve as a penalty to the state for failure to meet the targets under the watershed implementation plans. While the Prince William County HL Mooney Advanced Waste Water Treatment Plant is state of the art, other plants in the state are not and the cost to achieve the reduced effluent numbers would far exceed the estimated cost of $7 billion to implement BPM’s to non-point sources.
The real plan is to implement (and maintain) enough BMPs to meet the reductions in the TMDL according to the Chesapeake Bay Model. The actual costs of BMPs are highly variable. For example the cost to plant a cover crop is much less than to fence a stream or stabilize an eroding river bank, and the $7 billion estimate may be the low cost estimate from implementing a BMP on every agricultural acre in the Virginia portion of the Chesapeake Bay Watershed. The local communities in Virginia have been asked by the Virginia Department of Natural Resources request to develop land use information and BMP inventory to meet the local WIP Phase I effort level. With the help of some computerized tools they are going to use the EPA model to determine the least cost method to reach the “acceptable level of effort” necessary to meet the EPA allocations.
Fundamentally, complying with the WIP is about spending enough money, putting in enough BMPs to have the Chesapeake Bay Model say that we meet our TMDL. BPMs are not always easy to see to the untrained eye. There are a long list of techniques to manage storm water to reduce runoff of nutrients and soil from urban, suburban and rural areas. A really expensive (and easy to see) BMP would be to repave roads and parking lots with pervious pavement so that storm water could soak into the road way thereby reducing runoff. This can be impractical as a retrofit because of cost of replacing roads and parking lots. More practical way to limit large volumes of storm water runoff would be to install a rain garden system along roadways and parking lots to infiltrate street runoff. Rain gardens look like landscaping. EPA has a long list of acceptable BMPs at various costs and effectiveness that can be used by communities to meet the requirements of the TMDL under the WIP. The challenge is determining what needs to be done, convincing people to do it (there is tremendous resistance to installing and maintaining BMPs by residents of communities, farmers and politicians) and paying for the BMPs.
Cost is a big issue. For FY 2012 EPA maintained the budget for the Chesapeake Bay Program at 2010 levels, $50 million, enough to monitor, advise and enforce the implementation of the seven WIPs, but clearly no money to pay for BMPs. In creating the Chesapeake Bay TMDL EPA has created an obligation of between $1,000 and $2,500 per person for everyone living in the Chesapeake Bay Watershed to meet the requirements of the WIP Phase I. The Virginia portion of complying with the WIP Phase I is estimated to cost at least $7 billion. As a conservationist, I fully support the common goal of a cleaner, healthier Chesapeake Bay watershed, but worry about the costs to implement the solution.
Showing posts with label TMDL pollution diet. Show all posts
Showing posts with label TMDL pollution diet. Show all posts
Thursday, January 12, 2012
Monday, February 7, 2011
Farmers and the Chesapeake Bay
Last fall the US Department of Agriculture released a draft of a report evaluating conservation practices in the Chesapeake Bay Watershed. The USDA report stated 81% of farms lacked comprehensive nutrient management plans and practices. The report found that on over 2 million acres of cropland, that conservation practices are not being used at all. According to the current version of the EPA watershed model (to be revised in 2011), cropland accounts for 25% of sediment in the bay, 32% of the nitrogen and 27.5% of the phosphorus while accounting for only 10% of the Chesapeake Bay watershed acreage.
The EPA model’s allocation of pollution origination is the basis for the current “green community” anti agriculture stance. The agricultural sector is being viewed as an excessive polluter, though farm management practices have improved over the years. The Chesapeake Bay Watershed Model is a good tool in understanding how nitrogen, sediment, and phosphorus loads from different sources are delivered to the Bay. On a major tributary basis, real world data has been used to calibrate and validate the watershed portion of the model. Thus, it can provide predictive results of implementing best management practices, a useful tool to help make decisions about tradeoffs to control the loads of nutrients and sediment in the Chesapeake Bay Watershed. Implementing and maintaining best management practices and conservation plans on farms is difficult, because it involves changing often long established practices and the way that farmers manage their land and operations and requires a management plan for each operation no matter the size.
Frightened by the prospects of the economic impact of the federally mandated TMDLs forcing farmers to build fencing to keep livestock out of creeks and drainage areas that flow in the watershed and institute comprehensive nutrient management plans on all crop lands, a coalition of agricultural groups engaged LimnoTech, an Ann Arbor headquartered environmental consulting firm, to mount a challenge to the TMDLs. They compared EPA’s Total Maximum Daily Loads with those in the draft U.S. Department of Agriculture (USDA) report “Assessment of the Effects of Conservation Practices on Cultivated Cropland in the Chesapeake Bay Region,” and produced a report titled, “Comparison of Draft Load Estimates for Cultivated Cropland in the Chesapeake Bay Watershed.”
Inconsistencies in data and modeling were found between the EPA and USDA. This is no surprise since there are significant problems with underreporting of nutrient contamination from the urban/suburban sector in the EPA model, while the calibrated and validated totals for the major tributaries are probably reasonably accurate based on the sampling validation. So, if the urban/suburban segment is under counted in its contribution to the nutrient contamination, then some sector or sectors are being assigned that additional load. It is probably true that a significant portion of the nutrient load from the urban/suburban sector has been attributed agriculture, and if you look at the potentially revised urban/suburban load with the septic and the wastewater treatment plants (after all the wastewater is coming from the urban/suburban sector) it becomes clear that the urban/suburban populations are responsible for the lions share of contamination. In addition, the food produced by the agricultural sector feeds the urban and suburban populations.
There is a world food crisis building. Virginia is blessed with a moderate climate and adequate rainfall. Eliminating agriculture from the Chesapeake Bay Watershed is short sighted and quite frankly a really bad idea on so many levels. Nonetheless, farm practices and land management need to change. The TMDLs require a reduction in total nutrient loading in the Chesapeake Bay Watershed. To achieve the TMDLs improvements in wastewater treatment plants, agricultural nutrient management plans, stormwater managements and reductions in population and economic activities are the only sources of these reductions. Agriculture is generally considered the least cost method of reducing sediment nitrogen and phosphorus. Implementing these changes will allow us to feed more people with the same land resources, bringing agriculture to the next level. We will carry this cost in either increased cost of food, or hidden in a nutrient trading program as an overall tax to economic activity. Nutrient contamination is about populations. We need to be very careful not to kill the economic viability of the region to meet the TMDL.
The EPA model’s allocation of pollution origination is the basis for the current “green community” anti agriculture stance. The agricultural sector is being viewed as an excessive polluter, though farm management practices have improved over the years. The Chesapeake Bay Watershed Model is a good tool in understanding how nitrogen, sediment, and phosphorus loads from different sources are delivered to the Bay. On a major tributary basis, real world data has been used to calibrate and validate the watershed portion of the model. Thus, it can provide predictive results of implementing best management practices, a useful tool to help make decisions about tradeoffs to control the loads of nutrients and sediment in the Chesapeake Bay Watershed. Implementing and maintaining best management practices and conservation plans on farms is difficult, because it involves changing often long established practices and the way that farmers manage their land and operations and requires a management plan for each operation no matter the size.
Frightened by the prospects of the economic impact of the federally mandated TMDLs forcing farmers to build fencing to keep livestock out of creeks and drainage areas that flow in the watershed and institute comprehensive nutrient management plans on all crop lands, a coalition of agricultural groups engaged LimnoTech, an Ann Arbor headquartered environmental consulting firm, to mount a challenge to the TMDLs. They compared EPA’s Total Maximum Daily Loads with those in the draft U.S. Department of Agriculture (USDA) report “Assessment of the Effects of Conservation Practices on Cultivated Cropland in the Chesapeake Bay Region,” and produced a report titled, “Comparison of Draft Load Estimates for Cultivated Cropland in the Chesapeake Bay Watershed.”
Inconsistencies in data and modeling were found between the EPA and USDA. This is no surprise since there are significant problems with underreporting of nutrient contamination from the urban/suburban sector in the EPA model, while the calibrated and validated totals for the major tributaries are probably reasonably accurate based on the sampling validation. So, if the urban/suburban segment is under counted in its contribution to the nutrient contamination, then some sector or sectors are being assigned that additional load. It is probably true that a significant portion of the nutrient load from the urban/suburban sector has been attributed agriculture, and if you look at the potentially revised urban/suburban load with the septic and the wastewater treatment plants (after all the wastewater is coming from the urban/suburban sector) it becomes clear that the urban/suburban populations are responsible for the lions share of contamination. In addition, the food produced by the agricultural sector feeds the urban and suburban populations.
There is a world food crisis building. Virginia is blessed with a moderate climate and adequate rainfall. Eliminating agriculture from the Chesapeake Bay Watershed is short sighted and quite frankly a really bad idea on so many levels. Nonetheless, farm practices and land management need to change. The TMDLs require a reduction in total nutrient loading in the Chesapeake Bay Watershed. To achieve the TMDLs improvements in wastewater treatment plants, agricultural nutrient management plans, stormwater managements and reductions in population and economic activities are the only sources of these reductions. Agriculture is generally considered the least cost method of reducing sediment nitrogen and phosphorus. Implementing these changes will allow us to feed more people with the same land resources, bringing agriculture to the next level. We will carry this cost in either increased cost of food, or hidden in a nutrient trading program as an overall tax to economic activity. Nutrient contamination is about populations. We need to be very careful not to kill the economic viability of the region to meet the TMDL.
Monday, January 31, 2011
In the EPA’s TMDL Pollution Diet The Biggest Looser is Northern Virginia
The most recent meeting of the Potomac Watershed Roundtable was in Warrenton, VA at Lord Fairfax Community College and had a series of speakers on the Chesapeake Bay strict pollution diet, the Total Maximum Daily Load (TMDL) mandated by the EPA to the six Chesapeake Bay Watershed states and the District of the Columbia. The TMDLs were assigned by the EPA to each segment of the Chesapeake Bay Watershed. For the TMDL, the Chesapeake Bay’s tidal waters have been divided into 92 tidal water segments. There are 35 segments controlled by Virginia and another five Maryland owned segments that include Virginia drainage areas. The different water segments are determined by their varying degrees of salinity, recalling that the Chesapeake Bay Watershed is an estuary. Finally, the TMDLs address only pollution from excess nitrogen, phosphorus and sediment. No action has been taken on other pollutants that might be present in the Chesapeake Bay and its tributaries.
On November 29th 2010 Virginia, submitted the final version of the Virginia Chesapeake Bay Watershed Implementation Plan (WIP) to the U.S. Environmental Protection Agency and December 29th the EPA accepted the revised version of Virginia’s WIP and issued the “final” TMDL, but with “enhanced oversight.” (Doesn’t that sound like fun.) The TMDLs were created by a series of models of the Chesapeake Bay Watershed that include various land use models, water quality models and watershed models. These computer models are mathematical representations of the real world that estimate environmental events and conditions. The models are at best imperfect, but they are nonetheless the best tool available to view the 64,000 square miles of the watershed. The Chesapeake Bay and its watershed are so large and complex, that scientists and regulators rely on computer models for critical information about the ecosystem’s characteristics and the impact of various environmental actions to reduce pollution. It is possible that they have been spending a wee bit too much time looking at computer output and missed the big picture.
Mike Rolband, President of Wetland Studies and Solutions, Inc. had an interesting presentation pointing out poor model behavior, mistakes and injustices of the current TMDL, what EPA has called the strict pollution diet, but really is an excess nutrient diet. When Mike showed the group his slides, several aspects of the Chesapeake Bay Watershed, the EPA’s models, the mandated TMDLs became very clear for me. First of all, the level of excess nutrients in each of the major tributaries to the Chesapeake Bay is fairly well known and well predicted and calibrated by the models. Second, this is indeed a diet, the Chesapeake Bay is overwhelmed with excess nutrients and sediment, and like an obese person, less nutrients will improve the situation. Thirdly, land use and population density matter, but generally the higher the population the more total nutrients are released. Waste water treatment plants and urban runoff and septic contribute a larger load of nitrogen than the agricultural sector. Finally, the EPA mandated TMDL and the approved WIPs to implement them require a percentage reduction in nutrient load from each sector.
This turns out to be vastly inequitable. Eliminating the agricultural sector, Northern Virginia with 46% of the watershed population is required to obtain a total nitrogen load for the waste water treatment plants, urban and septic of 2.52 pounds of nitrogen/person/year while the James River Basin is only required to obtain 6.38 pounds of nitrogen/person/year and the state target average is 4.43 pounds of nitrogen/person/year. This is the equivalent of mandating a diet for everyone in Virginia to lose 1/3 of their body weight. This might be just fine and actually beneficial for the 300 pound people who will be forced to lose 100 pounds, but it is lethal for the 150 pound Potomac Watershed that will have to loose 50 pounds each. We in northern Virginia are trapped in some Kafka version of a diet where slow death by starvation (stopping population growth and potentially reducing population) may be the unintended consequences of the EPA mandated pollution diet.
On November 29th 2010 Virginia, submitted the final version of the Virginia Chesapeake Bay Watershed Implementation Plan (WIP) to the U.S. Environmental Protection Agency and December 29th the EPA accepted the revised version of Virginia’s WIP and issued the “final” TMDL, but with “enhanced oversight.” (Doesn’t that sound like fun.) The TMDLs were created by a series of models of the Chesapeake Bay Watershed that include various land use models, water quality models and watershed models. These computer models are mathematical representations of the real world that estimate environmental events and conditions. The models are at best imperfect, but they are nonetheless the best tool available to view the 64,000 square miles of the watershed. The Chesapeake Bay and its watershed are so large and complex, that scientists and regulators rely on computer models for critical information about the ecosystem’s characteristics and the impact of various environmental actions to reduce pollution. It is possible that they have been spending a wee bit too much time looking at computer output and missed the big picture.
Mike Rolband, President of Wetland Studies and Solutions, Inc. had an interesting presentation pointing out poor model behavior, mistakes and injustices of the current TMDL, what EPA has called the strict pollution diet, but really is an excess nutrient diet. When Mike showed the group his slides, several aspects of the Chesapeake Bay Watershed, the EPA’s models, the mandated TMDLs became very clear for me. First of all, the level of excess nutrients in each of the major tributaries to the Chesapeake Bay is fairly well known and well predicted and calibrated by the models. Second, this is indeed a diet, the Chesapeake Bay is overwhelmed with excess nutrients and sediment, and like an obese person, less nutrients will improve the situation. Thirdly, land use and population density matter, but generally the higher the population the more total nutrients are released. Waste water treatment plants and urban runoff and septic contribute a larger load of nitrogen than the agricultural sector. Finally, the EPA mandated TMDL and the approved WIPs to implement them require a percentage reduction in nutrient load from each sector.
This turns out to be vastly inequitable. Eliminating the agricultural sector, Northern Virginia with 46% of the watershed population is required to obtain a total nitrogen load for the waste water treatment plants, urban and septic of 2.52 pounds of nitrogen/person/year while the James River Basin is only required to obtain 6.38 pounds of nitrogen/person/year and the state target average is 4.43 pounds of nitrogen/person/year. This is the equivalent of mandating a diet for everyone in Virginia to lose 1/3 of their body weight. This might be just fine and actually beneficial for the 300 pound people who will be forced to lose 100 pounds, but it is lethal for the 150 pound Potomac Watershed that will have to loose 50 pounds each. We in northern Virginia are trapped in some Kafka version of a diet where slow death by starvation (stopping population growth and potentially reducing population) may be the unintended consequences of the EPA mandated pollution diet.
Thursday, October 14, 2010
Tough Choices Ahead for Virginia
The Chesapeake Bay and its tidal waters are impaired by amongst other things the release of excess nitrogen, phosphorus and sediment. These pollutants are released from waste water treatment plants, from agricultural operations, urban and suburban runoff, wastewater facilities, air pollution and other sources, including septic systems that enter the tributaries and Chesapeake Bay. These pollutants cause algae blooms that consume oxygen and create dead zones where fish and shellfish cannot survive, block sunlight that is needed for underwater grasses, and smother aquatic life on the bottom. The US EPA has taken control of the situation and has developed a new federally mandated TMDL to restore the Chesapeake. The total maximum daily limit, TMDL, allocates a pollution budget among the states which will decrease over time.
The plan to meet the federally mandated TMDL is called a Watershed Implementation Plan, WIP. The six Chesapeake Bay states and the District of Columbia were required to develop WIPs to meet the federally mandated TMDLs. The EPA found Virginia’s WIP to have serious deficiencies. It did not meet allocations for nitrogen (6 percent over the limit) and phosphorus (7 percent over the limit), but did meet allocations for sediment (12 percent under the limit). In addition, the EPA found that the Virginia WIP relied on pollution trading programs but had no commitment to adopt new regulations relying instead on market forces. The EPA deemed the WIP to be vague and contain limited enforceability and accountability for filling the gaps identified by the EPA. The federal government will require Virginia to reduce their nitrogen release by an addition 12 million pounds per year, and their phosphorus release by 1.7 million pounds per year beyond those identified in the WIP. EPA has made it clear they will enforce reductions in the areas they can control under federal law to meet the TMDL. The EPA can only mandate reductions in waste streams from waste water treatment plants, CAFOs (concentrated animal feed operations), municipal separate storm sewage systems, MS4s and wastewater treatment plants.
To ensure that Virginia meets the TMDL goals the EPA will squeeze the MS4s, CAFOs and waste water treatment plants possibly beyond the economically feasible limit to get what they want. The EPA wants Virginia to develop a set of regulations for land use that will meet the TMDL. The Chesapeake Bay TMDL will force changes in how each of us lives, the costs for building new homes, hospitals, businesses and roads, the costs for repaving roads and redeveloping areas, the costs for building and operating a septic system, the cost of public water and sewage and taxes. That is the price of growing population density and a healthy and sustainable Chesapeake Bay. About half the land and 60% of the population of Virginia is within the Chesapeake Bay TMDL.
The first TMDL to be developed for Prince William County, Virginia (where I live) is for Cedar Run. The Cedar Run watershed is the land area that drains into Cedar Run and includes much of Nokesville. The nearly 87,000 acre watershed continues into Fauquier County. While EPA and environmental groups have emphasized the contribution of agriculture in the form of CAFOs and waste water treatment plants, the reality is that only a portion of Prince William County is serviced by the HL Mooney a WWTP and the Daly City units and the county only has two working dairy farms left. These days the horse farms greatly out number the beef cattle operations. Golf courses and suburban development are increasingly the sources of nutrient and sediment contamination in the watershed. The state and county is going to have to increase regulations on hobby horse farms, golf clubs and suburban developments. In order to meet the TMDL for the watershed changes will have to be made. No area will remain untouched by regulation.
For example along with the issue of backyard chickens, the county will have to readdress the zoning for horses. The keeping of a single horse produces approximately 45 pounds of manure per day, and depending on the type and amount you use, bedding can add another 20 +/- pounds of waste a day. If the horse was kept turned out year round (in our area that would require approximately 3-4 acres of open field per horse) then the horse would not be using bedding, which accounts for an addition 50% of the waste and the open acreage could serve as a solution to what to do with the manure. That single horse produces approximately eight tons of manure each year that would be "spread" by the horse at a rate of about two ton per acre per year. Spreading manure at this rate probably will not overload the plants or cause water quality problems through runoff. However, if the property lacks adequate field to keep the horses turned out, then the waste from the sacrifice area and paddocks needs to be managed to prevent excessive nutrient runoff and contamination of ground water. One of the things that will have to be addressed in future regulations is the open acreage requirements for horses.
Septic systems are another area that will have to be reexamined. Dutchess County New York did a study to monitor the nitrate concentrations associated with septic systems. They chose to use nitrate concentrations at half the drinking water level as a proxy for adequate dilution and natural attenuation of all contaminants. Historically, little thought was given to the dilution for wastewater components like nitrate and phosphorus in developing septic regulations. The NY Department of Health separation distances were assumed (and these are almost identical to the Virginia setbacks), but the overall regional density of septic systems was examined to ensure that groundwater and surface resources would not be overwhelmed by the total load of contaminants. The density recommendations were developed based on the nitrate concentrations. Nitrate was used as a proxy because all humans produce nitrate, it does not easily break down and there is a drinking water standard. The study found that overall average density of on-site waste disposal should not exceed one unit per 2-3 acres for an average size household to ensure water quality. In many neighborhoods septic density is much greater than one unit per 2-3 acres. In the WIP Virginia is beginning to address the possibility of requiring nitrate removal technology in new and repaired septic systems.
The county is currently considering a proposal to allow backyard chickens in residential areas. According to the Delaware Department of Natural Resources and Environmental Control, the typical household generates 10-15 pounds of nitrogen per year and 1-2 pounds of phosphorus per year. According to a Maryland state study, each chicken generates approximately 0.41 lbs of Nitrogen per year and around 0.35 pounds of phosphorus per year. Thus, each household with 10 chickens would generate 4.1 pounds of nitrogen and 3.5 pounds of phosphorus per year. This is a significant increase in the nutrient load of a typical house hold, a more than three fold increase in phosphorus load and an increase of nitrogen load by more than 30%. This additional waste is delivered in an uncontrolled manner to the surface. The poor location of a chicken coop could potentially impact ground water and well heads both on and off site and subject to runoff. Before Prince William allows additional nutrient loads they need to address reducing the current source of excess nutrient pollution.
The plan to meet the federally mandated TMDL is called a Watershed Implementation Plan, WIP. The six Chesapeake Bay states and the District of Columbia were required to develop WIPs to meet the federally mandated TMDLs. The EPA found Virginia’s WIP to have serious deficiencies. It did not meet allocations for nitrogen (6 percent over the limit) and phosphorus (7 percent over the limit), but did meet allocations for sediment (12 percent under the limit). In addition, the EPA found that the Virginia WIP relied on pollution trading programs but had no commitment to adopt new regulations relying instead on market forces. The EPA deemed the WIP to be vague and contain limited enforceability and accountability for filling the gaps identified by the EPA. The federal government will require Virginia to reduce their nitrogen release by an addition 12 million pounds per year, and their phosphorus release by 1.7 million pounds per year beyond those identified in the WIP. EPA has made it clear they will enforce reductions in the areas they can control under federal law to meet the TMDL. The EPA can only mandate reductions in waste streams from waste water treatment plants, CAFOs (concentrated animal feed operations), municipal separate storm sewage systems, MS4s and wastewater treatment plants.
To ensure that Virginia meets the TMDL goals the EPA will squeeze the MS4s, CAFOs and waste water treatment plants possibly beyond the economically feasible limit to get what they want. The EPA wants Virginia to develop a set of regulations for land use that will meet the TMDL. The Chesapeake Bay TMDL will force changes in how each of us lives, the costs for building new homes, hospitals, businesses and roads, the costs for repaving roads and redeveloping areas, the costs for building and operating a septic system, the cost of public water and sewage and taxes. That is the price of growing population density and a healthy and sustainable Chesapeake Bay. About half the land and 60% of the population of Virginia is within the Chesapeake Bay TMDL.
The first TMDL to be developed for Prince William County, Virginia (where I live) is for Cedar Run. The Cedar Run watershed is the land area that drains into Cedar Run and includes much of Nokesville. The nearly 87,000 acre watershed continues into Fauquier County. While EPA and environmental groups have emphasized the contribution of agriculture in the form of CAFOs and waste water treatment plants, the reality is that only a portion of Prince William County is serviced by the HL Mooney a WWTP and the Daly City units and the county only has two working dairy farms left. These days the horse farms greatly out number the beef cattle operations. Golf courses and suburban development are increasingly the sources of nutrient and sediment contamination in the watershed. The state and county is going to have to increase regulations on hobby horse farms, golf clubs and suburban developments. In order to meet the TMDL for the watershed changes will have to be made. No area will remain untouched by regulation.
For example along with the issue of backyard chickens, the county will have to readdress the zoning for horses. The keeping of a single horse produces approximately 45 pounds of manure per day, and depending on the type and amount you use, bedding can add another 20 +/- pounds of waste a day. If the horse was kept turned out year round (in our area that would require approximately 3-4 acres of open field per horse) then the horse would not be using bedding, which accounts for an addition 50% of the waste and the open acreage could serve as a solution to what to do with the manure. That single horse produces approximately eight tons of manure each year that would be "spread" by the horse at a rate of about two ton per acre per year. Spreading manure at this rate probably will not overload the plants or cause water quality problems through runoff. However, if the property lacks adequate field to keep the horses turned out, then the waste from the sacrifice area and paddocks needs to be managed to prevent excessive nutrient runoff and contamination of ground water. One of the things that will have to be addressed in future regulations is the open acreage requirements for horses.
Septic systems are another area that will have to be reexamined. Dutchess County New York did a study to monitor the nitrate concentrations associated with septic systems. They chose to use nitrate concentrations at half the drinking water level as a proxy for adequate dilution and natural attenuation of all contaminants. Historically, little thought was given to the dilution for wastewater components like nitrate and phosphorus in developing septic regulations. The NY Department of Health separation distances were assumed (and these are almost identical to the Virginia setbacks), but the overall regional density of septic systems was examined to ensure that groundwater and surface resources would not be overwhelmed by the total load of contaminants. The density recommendations were developed based on the nitrate concentrations. Nitrate was used as a proxy because all humans produce nitrate, it does not easily break down and there is a drinking water standard. The study found that overall average density of on-site waste disposal should not exceed one unit per 2-3 acres for an average size household to ensure water quality. In many neighborhoods septic density is much greater than one unit per 2-3 acres. In the WIP Virginia is beginning to address the possibility of requiring nitrate removal technology in new and repaired septic systems.
The county is currently considering a proposal to allow backyard chickens in residential areas. According to the Delaware Department of Natural Resources and Environmental Control, the typical household generates 10-15 pounds of nitrogen per year and 1-2 pounds of phosphorus per year. According to a Maryland state study, each chicken generates approximately 0.41 lbs of Nitrogen per year and around 0.35 pounds of phosphorus per year. Thus, each household with 10 chickens would generate 4.1 pounds of nitrogen and 3.5 pounds of phosphorus per year. This is a significant increase in the nutrient load of a typical house hold, a more than three fold increase in phosphorus load and an increase of nitrogen load by more than 30%. This additional waste is delivered in an uncontrolled manner to the surface. The poor location of a chicken coop could potentially impact ground water and well heads both on and off site and subject to runoff. Before Prince William allows additional nutrient loads they need to address reducing the current source of excess nutrient pollution.
Monday, October 4, 2010
Backyard Chickens, Virginia Chesapeake Bay WIP, and October 5th
October 5th is a busy evening in Northern Virginia for the environment. On the agenda for the October 5th meeting of the Prince William Board of County Supervisors, is a proposal to change to the zoning and land use regulations within the county. Currently chickens and other farm animals are allowed on 2 acres or more of agricultural land, but only if there's no house on the land. If there's a house, the property is considered residential and chickens are not allowed. County staff and Planning Commission have offered two differing recommendations for changes to the zoning regulations. The Planning Commission would allow chickens on properties under two acres within the county's rural area, whereas staff recommended that all properties should have to be at least two acres. Two emus, ostriches and similar large birds would be allowed on parcels of at least two acres, but less than 10 acres.
There are two risks that should be carefully considered by the Prince William Board of County Supervisors when making this decision, potential contamination of the drinking water supply for the area and potential for contaminated runoff to impact the Chesapeake Bay. As our area has become more suburban, density has increased, along with the utilization of groundwater for domestic purposes and the density of septic systems. This suburban development has increased the suburban runoff and nutrient contamination to our groundwater and watershed. The proposed zoning change would allow additional nutrient load in the form of backyard poultry. Unless, the county intends to regulate the micro poultry “farms” and require the implementation of and maintenance of BMPs to manage the waste and locating of coops according to the protective separation requirements of the septic regulations, the Prince William Board of County Supervisors should consider only the more conservative staff recommendation.
Also on October 5th is the Northern Virginia’s EPA's Chesapeake Bay TMDL public meeting. The meeting is being held on October 5th from 6:00 to 8:00 pm at the Annandale, campus of Northern Virginia Community College. The address and building appear in the list below. There are 4 public meetings and a webinar scheduled for Virginia. The meetings are scheduled to allow EPA to have a 40-45 minutes presentation, followed by an overview of the Virginia WIP for 15-20 minutes, followed by Q&A and public comments for about 1 hour.
Over the past quarter century the excess nutrient contamination to the Chesapeake Bay has decreased, but the Bay’s waters remain seriously degraded. As a result, US EPA has taken control of the situation and has developed a new federally mandated total maximum daily load, TMDL, of contaminants to restore the local waters. The TMDL (released as a Draft standard in July) allocates a pollution budget among the states which will decrease over time. There is no segment of the Virginia watershed that meets the TMDL at this time, yet Prince William is considering increasing the nutrient load on properties by allowing backyard poultry.
Virginia's secretary of natural resources, Doug Domenech, submitted Virginia's Watershed Implementation Plan to the Environmental Protection Agency on Sept. 3, 2010. For the urban and suburban storm water to meet the federal mandated pollution diet, new developments will be subject to storm water management, urban nutrient management and erosion and sediment controls that have recently be implemented and development of a nutrient exchange program to encourage voluntary implementation of BMPs (best management practices). However, the new storm water regulations will not address the sediment and nutrient loads associated with existing development and septic systems, or even the proposed expansion of residential nutrient loads by allowing backyard poultry. EPA is mandating nutrient and sediment reductions to the EPA’s determined acceptable level on a segment by segment basis. Prince William Board of County Supervisors needs to carefully consider what steps they are going to have to take to meet the federally mandated reduction in TMDL when considering any zoning changes. Even with statewide compliance and the new storm water management regulation the WIP talks of restrictions on lawn and turf fertilizers, increasing regulation on both traditional and alternative septic systems. Increasing the waste load from backyard poultry does not fit into these reductions in nutrient runoff.
The WIP does not specify how Virginia will reduce nonpoint runoff pollution from farms, suburban and urban areas beyond allowing the local governments to make those decisions. Prince William Board of County Supervisors have the opportunity to demonstrate how communities in Virginia will rise to the occasion. The reaction by EPA to the WIP and their comments at the public meetings will tell us if the federal regulators intend to regulate down to the suburban backyard or if they will allow the Commonwealth to have the local communities address how to reduce their contributions to pollution in the Chesapeake Bay. The actions of the Prince William Board of County Supervisors will tell us if they can rise to the challenge of restoring and managing our natural resources.
The Prince William Board of County Supervisors will meet on Tuesday, Oct. 5, 2010, in the Board Chambers of the James J. McCoart Administration Building. The zoning change is scheduled for the evening session.
EPA's Chesapeake Bay TMDL public meetings are being held in Virginia October 4th to 7th 2010.
October 4 - from 6:00 to 8:00 p.m. Grafton Theatre, James Madison University, 281 Warren Service Drive, Harrisonburg, VA.
October 5 - from 6:00 to 8:00 p.m. Northern Virginia Community College, Annandale Campus, Ernst Community Cultural Center, 8333 Little River Turnpike, Annandale VA
October 6 - from 6:00 to 8:00 p.m. Robins Pavilion Jepson Alumni Center, University of Richmond, 28 Westhampton Way, Richmond, VA
October 7, webinar 1:00 to 3:00 p.m.
https://www2.gotomeeting.com/register/689259867
October 7 - from 6:00 to 8:00 p.m. Crowne Plaza Hampton Marina Hotel, 700 Settlers Landing Road, Hampton, VA
There are two risks that should be carefully considered by the Prince William Board of County Supervisors when making this decision, potential contamination of the drinking water supply for the area and potential for contaminated runoff to impact the Chesapeake Bay. As our area has become more suburban, density has increased, along with the utilization of groundwater for domestic purposes and the density of septic systems. This suburban development has increased the suburban runoff and nutrient contamination to our groundwater and watershed. The proposed zoning change would allow additional nutrient load in the form of backyard poultry. Unless, the county intends to regulate the micro poultry “farms” and require the implementation of and maintenance of BMPs to manage the waste and locating of coops according to the protective separation requirements of the septic regulations, the Prince William Board of County Supervisors should consider only the more conservative staff recommendation.
Also on October 5th is the Northern Virginia’s EPA's Chesapeake Bay TMDL public meeting. The meeting is being held on October 5th from 6:00 to 8:00 pm at the Annandale, campus of Northern Virginia Community College. The address and building appear in the list below. There are 4 public meetings and a webinar scheduled for Virginia. The meetings are scheduled to allow EPA to have a 40-45 minutes presentation, followed by an overview of the Virginia WIP for 15-20 minutes, followed by Q&A and public comments for about 1 hour.
Over the past quarter century the excess nutrient contamination to the Chesapeake Bay has decreased, but the Bay’s waters remain seriously degraded. As a result, US EPA has taken control of the situation and has developed a new federally mandated total maximum daily load, TMDL, of contaminants to restore the local waters. The TMDL (released as a Draft standard in July) allocates a pollution budget among the states which will decrease over time. There is no segment of the Virginia watershed that meets the TMDL at this time, yet Prince William is considering increasing the nutrient load on properties by allowing backyard poultry.
Virginia's secretary of natural resources, Doug Domenech, submitted Virginia's Watershed Implementation Plan to the Environmental Protection Agency on Sept. 3, 2010. For the urban and suburban storm water to meet the federal mandated pollution diet, new developments will be subject to storm water management, urban nutrient management and erosion and sediment controls that have recently be implemented and development of a nutrient exchange program to encourage voluntary implementation of BMPs (best management practices). However, the new storm water regulations will not address the sediment and nutrient loads associated with existing development and septic systems, or even the proposed expansion of residential nutrient loads by allowing backyard poultry. EPA is mandating nutrient and sediment reductions to the EPA’s determined acceptable level on a segment by segment basis. Prince William Board of County Supervisors needs to carefully consider what steps they are going to have to take to meet the federally mandated reduction in TMDL when considering any zoning changes. Even with statewide compliance and the new storm water management regulation the WIP talks of restrictions on lawn and turf fertilizers, increasing regulation on both traditional and alternative septic systems. Increasing the waste load from backyard poultry does not fit into these reductions in nutrient runoff.
The WIP does not specify how Virginia will reduce nonpoint runoff pollution from farms, suburban and urban areas beyond allowing the local governments to make those decisions. Prince William Board of County Supervisors have the opportunity to demonstrate how communities in Virginia will rise to the occasion. The reaction by EPA to the WIP and their comments at the public meetings will tell us if the federal regulators intend to regulate down to the suburban backyard or if they will allow the Commonwealth to have the local communities address how to reduce their contributions to pollution in the Chesapeake Bay. The actions of the Prince William Board of County Supervisors will tell us if they can rise to the challenge of restoring and managing our natural resources.
The Prince William Board of County Supervisors will meet on Tuesday, Oct. 5, 2010, in the Board Chambers of the James J. McCoart Administration Building. The zoning change is scheduled for the evening session.
EPA's Chesapeake Bay TMDL public meetings are being held in Virginia October 4th to 7th 2010.
October 4 - from 6:00 to 8:00 p.m. Grafton Theatre, James Madison University, 281 Warren Service Drive, Harrisonburg, VA.
October 5 - from 6:00 to 8:00 p.m. Northern Virginia Community College, Annandale Campus, Ernst Community Cultural Center, 8333 Little River Turnpike, Annandale VA
October 6 - from 6:00 to 8:00 p.m. Robins Pavilion Jepson Alumni Center, University of Richmond, 28 Westhampton Way, Richmond, VA
October 7, webinar 1:00 to 3:00 p.m.
https://www2.gotomeeting.com/register/689259867
October 7 - from 6:00 to 8:00 p.m. Crowne Plaza Hampton Marina Hotel, 700 Settlers Landing Road, Hampton, VA
Thursday, September 16, 2010
More on Virginia’s Watershed Implementation Plan
“The Chesapeake Bay is truly a national treasure and an ecological wonder. As Virginians, we have an obligation to protect this incredible resource, and we are all committed to ensuring a clean and vibrant Chesapeake Bay for future generations to enjoy and cherish.” Thus begins the introduction of Virginia’s Watershed Implementation Plan, WIP, to the Environmental Protection Agency. The Chesapeake Bay watershed is more than that, it is our water and our life. Unless the Chesapeake Bay watershed is protected our groundwater and all our drinking water are at risk.
To cleanup of the Chesapeake the EPA has determined that nitrogen, phosphorus and sediment from waste water plants, septic, agriculture, urban/ suburban runoff and forest land runoff will have to be reduced. The EPA has divided the Chesapeake Bay Watershed into 92 geographical segments and assigned maximum loads for nitrogen, phosphorus and sediment to each segment. Although the Chesapeake Bay total maximum daily load, TMDL, is often discussed and thought of conceptually as a single TMDL, it is comprised of 92 separate segments with different sources of contamination and different TMDLs. Virginia lands drain into 39 of these segments within the watershed. All 39 segments are listed as impaired for excessive nutrients and sediments and thus each area within Virginia that is part of the Chesapeake Bay water shed needs to reduce the amount of sediment, nitrogen and phosphorus that is released to the Chesapeake from urban/ suburban run off, waste treatment plants, industrial plants, agricultural runoff, forest lands, and septic.
The WIP that Virginia submitted is fairly generic because it does not confer any additional regulatory or legal authority to governmental agencies nor does it propose to make any specific changes beyond expanding the Virginia nutrient credit program to allow the most cost effective pollution reduction strategies to be implemented statewide. However, the WIP does talk about future regulatory expansions. Any programs or strategies that are not currently authorized by state law may be pursued through the legislative process or through the Virginia Administrative Process Act, but those decisions are left for the future. Virginia is also bound by the provisions of state law that require cost evaluations along with a benefit analysis for implementation plans.
The Department of Natural Resources formed an advisory group last winter that seemed to include every regulator, business interest and environmental group, but failed to include representation for the Virginia homeowner. According to the Chesapeake Bay Foundation half of Virginia is drained by Chesapeake Bay watershed rivers, and two-thirds of the state's population lives within the Bay watershed. In addition there are 536,000 homes with septic systems within the Bay watershed. The WIP will control building, remodeling of homes, road construction, lawn maintenance, possibly increase requirements on homeowners with septic systems or require neighborhoods to install storm water management systems. Restoring the Chesapeake Bay and protecting the water for fishing recreation and water supply will cost money and impact our lives and the value of our property. Two thirds of the homeowners in Virginia live within the Chesapeake Bay watershed and they should have the most powerful say in how the TMDL is implemented in our neighborhoods.
The EPA will be having a series of public meetings and webinars attend one of the meetings. You need to be informed and look out for your interests because no one else is. The Virginia meetings are October 4th from 6-8 p.m. at the Grafton Theatre, James Madison University, 281 Warren Service Drive, Harrisonburg, VA.
October 5th - from 6-8 p.m. Northern Virginia Community College, Annandale Campus, Ernst Community Cultural Center, 8333 Little River Turnpike, Annandale VA
October 7th from 6-8 p.m. Crowne Plaza Hampton Marina Hotel, 700 Settlers Landing Road, Hampton, VA. There is also a webinar on October 7th from 1-3 pm
To cleanup of the Chesapeake the EPA has determined that nitrogen, phosphorus and sediment from waste water plants, septic, agriculture, urban/ suburban runoff and forest land runoff will have to be reduced. The EPA has divided the Chesapeake Bay Watershed into 92 geographical segments and assigned maximum loads for nitrogen, phosphorus and sediment to each segment. Although the Chesapeake Bay total maximum daily load, TMDL, is often discussed and thought of conceptually as a single TMDL, it is comprised of 92 separate segments with different sources of contamination and different TMDLs. Virginia lands drain into 39 of these segments within the watershed. All 39 segments are listed as impaired for excessive nutrients and sediments and thus each area within Virginia that is part of the Chesapeake Bay water shed needs to reduce the amount of sediment, nitrogen and phosphorus that is released to the Chesapeake from urban/ suburban run off, waste treatment plants, industrial plants, agricultural runoff, forest lands, and septic.
The WIP that Virginia submitted is fairly generic because it does not confer any additional regulatory or legal authority to governmental agencies nor does it propose to make any specific changes beyond expanding the Virginia nutrient credit program to allow the most cost effective pollution reduction strategies to be implemented statewide. However, the WIP does talk about future regulatory expansions. Any programs or strategies that are not currently authorized by state law may be pursued through the legislative process or through the Virginia Administrative Process Act, but those decisions are left for the future. Virginia is also bound by the provisions of state law that require cost evaluations along with a benefit analysis for implementation plans.
The Department of Natural Resources formed an advisory group last winter that seemed to include every regulator, business interest and environmental group, but failed to include representation for the Virginia homeowner. According to the Chesapeake Bay Foundation half of Virginia is drained by Chesapeake Bay watershed rivers, and two-thirds of the state's population lives within the Bay watershed. In addition there are 536,000 homes with septic systems within the Bay watershed. The WIP will control building, remodeling of homes, road construction, lawn maintenance, possibly increase requirements on homeowners with septic systems or require neighborhoods to install storm water management systems. Restoring the Chesapeake Bay and protecting the water for fishing recreation and water supply will cost money and impact our lives and the value of our property. Two thirds of the homeowners in Virginia live within the Chesapeake Bay watershed and they should have the most powerful say in how the TMDL is implemented in our neighborhoods.
The EPA will be having a series of public meetings and webinars attend one of the meetings. You need to be informed and look out for your interests because no one else is. The Virginia meetings are October 4th from 6-8 p.m. at the Grafton Theatre, James Madison University, 281 Warren Service Drive, Harrisonburg, VA.
October 5th - from 6-8 p.m. Northern Virginia Community College, Annandale Campus, Ernst Community Cultural Center, 8333 Little River Turnpike, Annandale VA
October 7th from 6-8 p.m. Crowne Plaza Hampton Marina Hotel, 700 Settlers Landing Road, Hampton, VA. There is also a webinar on October 7th from 1-3 pm
Monday, September 13, 2010
Virginia’s Watershed Implementation Plan
Virginia's secretary of natural resources, Doug Domenech, submitted Virginia's Watershed Implementation Plan to the Environmental Protection Agency on Sept. 3, 2010, two days later than requested. There may be some political message in that action beyond a tendency to procrastinate, who knows, maybe his dog ate it. The plan begins with the simple acknowledgement that:
“The Chesapeake Bay is truly a national treasure and an ecological wonder. As Virginians, we have an obligation to protect this incredible resource, and we are all committed to ensuring a clean and vibrant Chesapeake Bay for future generations to enjoy and cherish.”
In his cover letter, Secretary Domenech said: “Having only received our nitrogen and phosphorous allocations July 1, and sediment allocation August 13, it is difficult to develop a comprehensive plan such as this that may have an impact through 2025.” In addition, to meet reductions in non-point source pollution, pollution from agriculture, urban and suburban run off and septic systems, will require changes in regulations and laws and funding for implementation and enforcement. These changes could have tremendous economic and autonomy impacts on business and individuals in Virginia and need to be addressed by the state legislature and impacted communities.
According to the US EPA and the Chesapeake Bay Foundation suburban and urban spread is the fastest growing land use and that suburban and urban storm water run off and septic waste water are the only major source of pollution in the watershed that continue to increase. The experts believe that this has been caused by the increase in impervious cover (pavement, buildings and roadways) that is associated with development and increased density of septic systems as population increases and lots become smaller.
For the urban and suburban storm water to meet the federal mandated pollution diet, new developments will be subject to storm water management, urban nutrient management and erosion and sediment controls that have recently be implemented. In addition, a nutrient exchange program will be developed to encourage implementation of BMPs (best management practices). However, the new storm water regulations will not address the sediment and nutrient loads associated with existing development and the mandated TMDL (total maximum daily load of pollutants) will require reductions from the existing pollution load. EPA is mandating the acceptable nutrient and sediment reductions, not on a statewide basis but on a segment by segment basis. Virginia is proposing that the Commonwealth meet the goals on a statewide basis. Simply looking at an aerial map of northern Virginia demonstrates the problem. The predominant form of development is existing housing, neighborhoods, and roads. Without having to create storm water management for every existing neighborhood, there are few options. Even with statewide compliance and the new storm water management regulation the WIP talks of restrictions on lawn and turf fertilizers, increasing regulation on both traditional and alternative septic systems.
The preliminary response from the Chesapeake Bay Foundations was: “Upon initial examination, we have serious concerns about the WIPs lack of details. Absent dramatic changes, we ask EPA to consider, now, what actions it must take to ensure Virginia will accomplish its share of needed pollution reductions…While there are some good proposals in the WIP—to offset pollution from future growth, to offer tax incentives to farmers to use conservation practices—the document is stunningly deficient on how the Commonwealth will implement many of these proposals. In particular, the WIP does not specify how Virginia will reduce non-point runoff pollution from farms and urban areas.” The reaction by EPA to these comments and the WIP in general will tell us if the federal regulators intend to regulate down to the suburban backyard or if they will allow the Commonwealth to have the local communities address how to reduce their contributions to pollution in the Chesapeake Bay.
The EPA will be having a series of public meetings and webinars. The Virginia meetings are: October 4th from 6-8 p.m. at the Grafton Theatre, James Madison University, 281 Warren Service Drive, Harrisonburg, VA.
October 5th - from 6-8 p.m. Northern Virginia Community College, Annandale Campus, Ernst Community Cultural Center, 8333 Little River Turnpike, Annandale VA
October 7th from 6-8 p.m. Crowne Plaza Hampton Marina Hotel, 700 Settlers Landing Road, Hampton, VA. There is also a webinar on October 7th from 1-3 pm
“The Chesapeake Bay is truly a national treasure and an ecological wonder. As Virginians, we have an obligation to protect this incredible resource, and we are all committed to ensuring a clean and vibrant Chesapeake Bay for future generations to enjoy and cherish.”
In his cover letter, Secretary Domenech said: “Having only received our nitrogen and phosphorous allocations July 1, and sediment allocation August 13, it is difficult to develop a comprehensive plan such as this that may have an impact through 2025.” In addition, to meet reductions in non-point source pollution, pollution from agriculture, urban and suburban run off and septic systems, will require changes in regulations and laws and funding for implementation and enforcement. These changes could have tremendous economic and autonomy impacts on business and individuals in Virginia and need to be addressed by the state legislature and impacted communities.
According to the US EPA and the Chesapeake Bay Foundation suburban and urban spread is the fastest growing land use and that suburban and urban storm water run off and septic waste water are the only major source of pollution in the watershed that continue to increase. The experts believe that this has been caused by the increase in impervious cover (pavement, buildings and roadways) that is associated with development and increased density of septic systems as population increases and lots become smaller.
For the urban and suburban storm water to meet the federal mandated pollution diet, new developments will be subject to storm water management, urban nutrient management and erosion and sediment controls that have recently be implemented. In addition, a nutrient exchange program will be developed to encourage implementation of BMPs (best management practices). However, the new storm water regulations will not address the sediment and nutrient loads associated with existing development and the mandated TMDL (total maximum daily load of pollutants) will require reductions from the existing pollution load. EPA is mandating the acceptable nutrient and sediment reductions, not on a statewide basis but on a segment by segment basis. Virginia is proposing that the Commonwealth meet the goals on a statewide basis. Simply looking at an aerial map of northern Virginia demonstrates the problem. The predominant form of development is existing housing, neighborhoods, and roads. Without having to create storm water management for every existing neighborhood, there are few options. Even with statewide compliance and the new storm water management regulation the WIP talks of restrictions on lawn and turf fertilizers, increasing regulation on both traditional and alternative septic systems.
The preliminary response from the Chesapeake Bay Foundations was: “Upon initial examination, we have serious concerns about the WIPs lack of details. Absent dramatic changes, we ask EPA to consider, now, what actions it must take to ensure Virginia will accomplish its share of needed pollution reductions…While there are some good proposals in the WIP—to offset pollution from future growth, to offer tax incentives to farmers to use conservation practices—the document is stunningly deficient on how the Commonwealth will implement many of these proposals. In particular, the WIP does not specify how Virginia will reduce non-point runoff pollution from farms and urban areas.” The reaction by EPA to these comments and the WIP in general will tell us if the federal regulators intend to regulate down to the suburban backyard or if they will allow the Commonwealth to have the local communities address how to reduce their contributions to pollution in the Chesapeake Bay.
The EPA will be having a series of public meetings and webinars. The Virginia meetings are: October 4th from 6-8 p.m. at the Grafton Theatre, James Madison University, 281 Warren Service Drive, Harrisonburg, VA.
October 5th - from 6-8 p.m. Northern Virginia Community College, Annandale Campus, Ernst Community Cultural Center, 8333 Little River Turnpike, Annandale VA
October 7th from 6-8 p.m. Crowne Plaza Hampton Marina Hotel, 700 Settlers Landing Road, Hampton, VA. There is also a webinar on October 7th from 1-3 pm
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