Ann F. Jennings, Chesapeake Bay Foundation (CBF) Virginia Executive Director, issued the following statement regarding the Commonwealth of Virginia's final Watershed Implementation Plan (WIP) submitted to the U.S. Environmental Protection Agency (EPA) on November 29, 2010:
"The Chesapeake Bay Foundation (CBF) has reviewed Virginia's revised Watershed Implementation Plan (WIP), and we are encouraged by the new commitments outlined in the final plan. We acknowledge that the Commonwealth has made many changes to the initial draft WIP, and we applaud the state's commitment to this process, understanding that many state workers spent their Thanksgiving holiday working on the final plan.
"As CBF urged, the Commonwealth specifically commits to significant additional pollution reductions from wastewater treatment plants in the James River basin. As many have noted, obtaining nitrogen and phosphorus reductions by upgrading wastewater treatment plants is among the most cost-effective and accountable tools available. Virginia has committed to obtain up to 6 million additional pounds of nitrogen pollution reductions from wastewater, which will result in improved water quality for the Bay and Virginia's rivers. It should especially benefit the lower James River, which for years has been plagued by algae blooms from excess pollution.
"The plan also obligates the Commonwealth to greater pollution reductions from stormwater running off urban streets and parking lots by mandating reductions in state permits for large city stormwater systems. Runoff from our cities and homes remains the only source of water pollution in Virginia that continues to increase and therefore must be aggressively addressed if restoration of the Bay and our local streams is to succeed.
"Unfortunately, while the revised plan includes many more promising ideas for reducing polluted runoff from Virginia farms, it continues to lack commitments that such reductions will actually be achieved. The WIP calls for farms to implement "resource management plans" to reduce pollution but does not mandate what those plans should include and requires them only if adequate funding is available. Unlike the clear commitments to reductions from the wastewater sector, Virginia has not provided the same reasonable assurance from the agriculture sector. Because of this shortcoming, we anticipate that EPA will have no choice but to impose backstop TMDL measures, which could result in increased EPA oversight in order to comply with the Clean Water Act.
"Regrettably, the Virginia WIP continues to characterize the Bay cleanup plan as an unfunded federal mandate, ignoring:
Virginia's Constitution and State Water Control Law require state government to ensure clean water for all Virginia citizens by developing and implementing cleanup plans identical to those now called for by EPA, and Recent statewide polling shows vast majorities of Virginia voters believe providing clean water is an important function of state government.
"CBF applauds the Commonwealth's efforts to improve the WIP and urges Virginia and EPA to continue working to resolve outstanding issues, particularly regarding agriculture runoff pollution, and ultimately to ensure a Virginia plan that achieves clean water and a restored Bay."