Virginia's Blueprint for Clean Water

20 Milestones Hero VA

Excluding livestock from streams using fencing and forested buffers can greatly improve water quality. Virginia needs to implement more agricultural practices like these to meet its 2025 pollution reduction goals.

Will Parson/Chesapeake Bay Program

Overall, Virginia is currently on track to achieve its 2025 goals to reduce nitrogen and phosphorus pollution due largely to reductions from wastewater treatment plants. However, it risks getting off track unless it accelerates efforts to reduce pollution from agricultural sources and urban and suburban development and continues to make additional pollution reductions from wastewater treatment plants. The Commonwealth has a strong plan to make these reductions, but the plan must be implemented.

See where things stand in the Commonwealth below and learn about the current and future challenges we face.

Virginia's Progress Toward Pollution Reductions

We used EPA's scientific model to estimate pollution reductions made between 2009 and 2019 to determine if current trends are on track to meet the 2025 Blueprint goals, both statewide and for each sector. Virginia's pollution-reduction progress is summarized in the table below.

Wastewater treatment plant upgrades in Virginia have kept the state on track to meet its goals so far. But Virginia must accelerate efforts in pollution reduction from agriculture and urban/suburban runoff to stay on track.

Nitrogen Phosphorus
Urban & Suburban
Polluted Runoff
Wastewater &
Combined Sewer Outfall


red projected loads more than 25% off target or pollution is increasing
yellow projected loads within 10-25% of target
green projected loads less than 10% off target
* No contribution from this source sector
Any increasing trendline is red, regardless of percentage.

Pollution-reduction progress is assessed with modeled estimates of the benefits from implemented practices such as upgrades to wastewater treatment plants, best management practices like cover crops and streamside forested buffers on agricultural lands, and stormwater practices, like rain gardens, in urban areas. The “Total” progress for each state is assessed against the overall pollution-reduction target EPA assigned each state in order to meet the Blueprint goals by 2025. Each state is responsible for dividing EPA’s total allotment among the various pollution sources (sectors) in their state Clean Water Blueprints (Watershed Implementation Plans or WIPs). The progress for each sector (i.e. agriculture) is therefore assessed against the pollution-reduction target assigned to it in the states’ most recent Phase III WIPs.

Evaluating Virginia's Milestone Commitments

After examining the results of EPA's scientific model to estimate pollution reductions statewide and for each sector (see chart above), we looked at how well the states have implemented the programmatic commitments they made in their 2018-2019 milestone goals—in other words, the practices and programs they will use to get the job done. The following is our analysis of key Virginia commitments.


Graphic of building with smokestacks and raindrop inside a brown box.The wastewater sector accounts for more than 25 percent of Virginia’s nitrogen pollution overall. It makes up an even larger share of pollution in the James and York river watersheds, where wastewater treatment levels lag behind other tributaries. Virginia must continue cutting wastewater pollution to achieve its 2025 pollution reduction goals.

Commitment: Virginia did not set new milestone goals for the wastewater sector in 2018 because, by that time, the pollution reduction targets for that sector had already been met. Still, the midpoint analysis of progress released by EPA in 2018, the shortfalls in other sectors, and local water quality conditions suggest more pollution reductions are needed from wastewater to achieve the Commonwealth’s goals.

Progress: In Danger of Being Off Track

Steps taken: Virginia has made substantial progress in the wastewater sector and identified initiatives to achieve additional reductions in its Phase III Watershed Implementation Plan (WIP), also known as the Virginia Clean Water Blueprint.

Steps needed: Virginia must finalize updates to the Watershed General Permit that will establish new pollution limits for wastewater plants in the Chesapeake Bay Watershed. This action will incentivize further pollution reductions from wastewater plants directly and through Virginia’s strong nutrient trading program. Innovative technology, including an initiative in Hampton Roads to use treated wastewater to recharge groundwater, provides exciting potential. Related milestone goals to connect more homes to sewers and address pollution from septic tanks still need to be achieved.

Urban & Suburban Polluted Runoff

Graphic of rain falling on skyscrapers and houses.Growing urban and suburban areas contribute new polluted runoff to Virginia’s waterways, offsetting most of the progress made to control polluted runoff from existing cities and neighborhoods.

Commitment: Revise and reissue important permits to control polluted runoff from developed areas, including the Arlington Municipal Separate Storm Sewer System (MS4) Permit, Phase II MS4 General Permit, and the Construction General Permit.

Progress: Off Track

Steps taken: The Commonwealth reissued the Construction General Permit, which regulates polluted runoff from construction sites,and the Phase II MS4 General Permit, which sets requirements for controlling polluted runoff from smaller urban areas. The Virginia State Water Control Board also directed the Department of Environmental Quality to establish measurable standards for water clarity that are needed to protect Virginia waters from sediment pollution.

Steps needed: Virginia needs to promptly revise and reissue all 11 Phase I MS4 permits—which are issued to cover stormwater systems in localities with more than 100,000 people. Virginia has not reissued the Arlington MS4 Permit, which sets new, more stringent polluted runoff requirements for Arlington County, despite a commitment to do so by June 2020. Further, four other Phase I MS4 permits have been administratively continued, meaning the existing permits were allowed to extend beyond their expiration because the Commonwealth did not reissue new permits. This is a substantial and unacceptable delay to addressing Virginia’s 2025 pollution reduction commitments, and the Commonwealth must avoid further delay.

Commitment: Issue Stormwater Local Assistance Fund (SLAF) grants to provide money to municipalities to address polluted runoff.

Progress: On Track

Steps taken: In early 2020, Virginia made a historic step to support the SLAF program by approving an appropriation of $50 million in cost-share dollars, although the 2020 pandemic has created uncertainty regarding that full appropriation. Pollution reductions from urban and suburban runoff must accelerate in coming years, and this funding will be critical to the success of local governments.

Steps needed: Virginia must continue robust support for the SLAF program in the future. Further, the SLAF guidelines should be revised to allow support for grantees’ removal of nitrogen (as well as phosphorus) pollution as part of the evaluation criteria for funding.


Graphic of barn, silo, and cow.Agriculture represents nearly 70 percent of the remaining pollution reductions Virginia must make to meet its Blueprint goals.

Commitment: Track and report progress to keep livestock out of streams.

Progress: On Track

Steps taken: Virginia passed legislation that sets a clear goal to exclude cattle from all perennial streams and established an approach to evaluate the remaining work. Virginia farmers continue to implement livestock exclusion practices, such as fencing and streamside buffers, that are critical for improving water quality and stream health.

Steps needed: Virginia must increase funding for agricultural best management practices and accelerate efforts to achieve its goals for excluding livestock from streams and planting streamside buffers.

Commitment: Evaluate farms where poultry are raised in confinement—known as Poultry Animal Feeding Operations (AFOs)—and issue individual permits for facilities that need enhanced oversight due to polluted runoff violations.

Progress: Off Track

Steps taken: Virginia has taken steps through the reissuance of the statewide general permit for confined poultry operations to improve reporting of poultry waste by end-users, who store or utilize the waste for fertilizer or other purposes. However, the permit has not been finalized. Virginia also issued individual permits for two facilities within the Bay watershed that were discharging pollution in violation of the general permit.

Steps needed: Virginia failed to complete an evaluation of AFO facilities or provide an update on progress in its final report on implementation of the 2018-19 milestone goals.  Increased inspections and monitoring are needed to adequately determine if facilities are discharging pollution and need enhanced oversight. Further, Virginia still has not addressed ammonia emissions—a source of nitrogen pollution—from the growing poultry industry.  Through the general permit, Virginia should require poultry operations to report their use of materials added to poultry manure and other waste, known as litter additives, that can reduce ammonia emissions and begin addressing this substantial threat to water quality.

Planning & Growth

Graphic of bar chart with arrow angling upward to the right.Providing a clear plan to address growing sources of pollution represents a critical component of Virginia’s Clean Water Blueprint (Phase III WIP) to achieve water quality goals.

Commitment: Virginia did not set any specific milestones related to growth.

Progress: In Danger of Being Off Track
(In cases where a state did not set a specific milestone goal, yet the issue is relevant to the achievement of its pollution reduction goals, we assessed any related steps that have been taken to address the issue and whether those steps put the state on track for success.)

Steps taken: Virginia’s Blueprint considered forecasted growth and established several goals related to accounting for additional pollution. Specifically, Virginia committed to re-evaluate post-construction standards to control polluted runoff from new development, although this has not been initiated.

Steps needed: Virginia should establish milestones that specifically contemplate growth. Poultry facilities, new urban and suburban development, and solar power expansion all represent growing sources that need specific regulatory attention to ensure sustainable growth. An evaluation of new post-construction standards should be undertaken and promptly completed.

Climate Change

Graphic of water rising in front of house.Climate change is a real and imminent threat to the Chesapeake Bay, including warmer water temperatures, rising sea levels, and more extreme rainfall. These changes will make Bay restoration harder, requiring additional reductions in nitrogen and phosphorus pollution by 2025.

Commitment: Virginia did not issue any specific climate change milestone commitments.

Progress: On Track
(In cases where a state did not set a specific milestone goal, yet the issue is relevant to the achievement of its pollution reduction goals, we assessed any related steps that have been taken to address the issue and whether those steps put the state on track for success.)

Steps taken: While it did not set a specific milestone commitment for the 2018-2019 period, Virginia did plan for the additional pollution that will result from climate change in its final Virginia Clean Water Blueprint (Phase III WIP). Virginia has also taken important steps by joining the Regional Greenhouse Gas Initiative (RGGI) to reduce emissions that drive climate change and establishing funds to help communities prepare for floods. Still, more work is needed.

Steps needed: Runoff standards need to address new precipitation levels, water quality standards need to incorporate new conditions, and Virginia needs to ensure our restoration effort will be effective in a changing climate.

Finishing the Job in Virginia

Virginia’s Clean Water Blueprint (Phase III WIP) is a strong roadmap for getting the job done by 2025. The plan calls for comprehensive efforts to address agricultural pollution, including increased and more effective financial and technical support for farmers, as well as future requirements to exclude livestock from streams and improve fertilizer and manure management. The plan also proposes to address polluted runoff through improvements to post-construction standards for new developments. Finally, the plan identifies a clear pathway to reduce pollution from wastewater treatment facilities across the Commonwealth, providing reasonable assurance that the 2025 goal will be met.

The key is implementation. Virginia took some critical steps in the past two years by passing legislation to support agricultural best management practices and appropriating significant funding for all sectors. Still, important steps remain, including developing regulations that ensure future wastewater reductions, establishing dedicated funding for all sectors,and protecting and restoring natural filters such as forests and wetlands in a changing climate. Virginia has made tremendous progress towards improving its rivers and the Chesapeake Bay, but decision makers and the Bay partnership need to finish the job.

When the General Assembly adjourned in mid-March, the economy was thriving and budgets for clean water programs—from upgrading wastewater treatment plants to reducing polluted runoff from farms and developed lands—were at an all-time high. Now, given the pandemic’s impact on the economy, legislators will have to make tough budget decisions. Clean water is critical for the health of our economy and our citizens. Take action and weigh in now to keep key clean water programs a priority.
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