Virginia Regulatory Town Hall
Department of Environmental Quality
State Water Control Board
Water Quality Standards [9 VAC 25 ‑ 260]
Action Rulemaking to Adopt Numeric Turbidity Criteria
Comment Period Ended on 5/12/2021


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5/5/21  9:29 am
Commenter: Sandra Stuart

measuring turbidity

As a water monitor with River Trends, I've found the turbidity tube with a secchi disk easy to use. Is this considered sufficient measurement?

CommentID: 97926

5/7/21  10:11 am
Commenter: Joe Howard

Turbidity Questions

Since turbidity is typically more of a qualitative measurement rather than a quantitative one, respective of each surface water and it's place in the watershed, will there be different turbidity requirements for different streams/rivers (i.e. the Pamunkey River always flows murky; however, the Cowpasture River does not)?  Will empirical data be gathered prior to setting river-specific standards, representing baseline turbidity for a surface water? Since flow regime and turbidity fluctuate during a rain event over the course of time, will field-sampling timelines and guidance be set to account for "first flush" runoff vs. post 24-hour runoff? Will surface water substrate and baseline sediment transport be accounted for in turbidity standards? How will turbidity requirements relate to permits for construction projects, MS4 programs, industrial sites, etc? Thank you!

CommentID: 97980

5/10/21  6:46 am
Commenter: Brian Steffel

Turbidity standards

We definitely need a numeric standard with which to measure turbidity.

CommentID: 98040

5/10/21  10:57 am
Commenter: Gretchen Sukow, Rockbridge Area Conservation Council

Turbidity standards needed


I am writing as a member of the Watershed Committee of the Rockbridge Area Conservation Council and as a Rockbridge water monitor for the Alliance for the Chesapeake Bay.  As part of my monitoring each month I measure turbidity with a turbidity tube.  The state of Virginia needs to establish  a turbidity standard to support our efforts to protect and repair our waters where needed.

Thank you,

Gretchen Sukow

CommentID: 98045

5/10/21  2:18 pm
Commenter: Lisa Connors

Turbidity Standards

Hello. I am writing as a citizen water monitor in Rockbridge County through the Alliance for the Chesapeake Bay.  As part of my monitoring each month I am charged with measuring turbidity with a turbidity tube.  A turbidity standard established by the state of Virginia would greatly support our efforts to protect our waters and allow for guidelines for where and when to initiate restorative measures. Thank you.

CommentID: 98158

5/10/21  3:04 pm
Commenter: John Pancake, Rockbridge Area Conservation Council

Turbidity Standards

For the life of me, I cannot understand Virginia DEQ's reluctance to adopt numerical turbidity standards.

I live on the Maury River, just downstream from the Little Calfpasture River, which is impaired by sediment. I have been spending time in and on the Maury River for 74 years. Sediment has changed the nature of the Maury River where I live. But it is difficult to address the problem because there are no standards.

How impaired these waters are is difficult to say because of Virginia's refusal to adopt standards. Other states have standards. Why, oh why, can't Virginia?

I am quite familiar with water quality issues. I am chair of the Rockbridge Area Conservation Council's watershed committee. I monitor streams using macroinvertebrate sampling and chemical tests (temperature, pH, dissolved oxygen, bacteria count and turbidity). I use a turbidity tube to check water clarity on two streams every month. 

This shouldn't be hard.

Please, do what it takes to come up with numerical standards.

Thank you.

John Pancake

Goshen Pass, Va.

CommentID: 98181

5/11/21  9:34 am
Commenter: Anonymous

Turbidity Value standard

I monitor chemical water quality as well as turbidity for waterways in Rockbridge County, VA. Since higher levels of sediment as measured by turbidity greatly affects the health of a waterway, I would like to have a standard set for acceptable turbidity value throughout the state.

Thank you,

Catherine Siegel

Fairfield, Virginia

CommentID: 98282

5/11/21  10:45 am
Commenter: David Hopkins

Turbidity standard

I have been monitoring Cedar Grove Creek in Rockbridge County for approximately ten years and in the last two years I have been measuring turbidity monthly for the Chesapeake Monitoring Cooperative. This creek is subject to sediment runoff after rain and its clarity changes as a result of the runoff.  Since it is a shallow waterway the 120 cm turbidity tube appears to be an appropriate method to determine changes in water clarity.  If the water is sediment laden it will reflect a turbidity tube reading of less than 120 cm.  When it is clear it exceeds 120 cm.  Thank you.

CommentID: 98287

5/11/21  12:06 pm
Commenter: Connie Gianniny-stream monitor

Standardize Turbidity Testing

I am a stream monitor and although I know that turbidity is one indicator of stream health, currently we do not test for turbidity. Scientifically, it only makes sense that for those who do test turbidity, that there should be a standard method of testing, measuring, and recording turbidity. 

CommentID: 98299

5/12/21  2:49 pm
Commenter: Anonymous


Thirty percent of erosion is natural due to wind, water, ice, and gravity.  Therefore, certain sediment deposits in streams are natural and will always be in the water column at different levels depending on streamflow.  Recommend DEQ focus on sources of sediment and not just measuring sediment.  Enforcing the 19 minimum standards will decrease erosion and therefore sediment.   

CommentID: 98453

5/12/21  3:03 pm
Commenter: James Manley-50Ways Rockbridge Environmental Comm.


We absolutely agree with the need to have a state-wide standard for Turbidity.  As a basic measurement of the health of the streams and rivers in the Commonwealth, it will allow us to track over times how we are progressing.

CommentID: 98454

5/12/21  4:03 pm
Commenter: Chris McDonald, Virginia Association of Counties

VACo Comments on Turbidity

As the Department of Environmental Quality moves ahead in this process, we urge the Department to consider any possible detrimental impacts that any new standards may have on stormwater permitting and compliance and on economic development.  To that end, the Virginia Association of Counties (VACo) formally requests that we be included in any future discussions on or analysis of these matters, and we ask that we be a part of the any future Regulatory Advisory Panel.

Thank You,

Chris McDonald
Director of Government Relations
Virginia Association of Counties

CommentID: 98464

5/12/21  4:19 pm
Commenter: Molly Petty

Adoopt a numeric turbidity criteria

     As a water monitor for both Trout Unlimited and the Chesapeake Bay Alliance in 3 counties, I strongly encourage DEQ to adopt a numeric turbidity criteria that protects existing and designated stream uses in Virginia.  Virginia needs a better tool to protect its wildlife and streams, and we are behind the curve on this: "at least 30 states, four U.S. territories, and dozens of Native American tribes have addressed sediment pollution by adopting numeric criteria." (

     Back in April 2019, the State Water Control Board voted unanimously to direct DEQ "to develop numeric turbidity standards for use across the commonwealth,” “to make this a top priority,” and to handle it on “an accelerated schedule." Wild Virginia and West Virginia Rivers have suggested criteria suited specifically to Virginia streams; the EPA has suggestions for Virginia.  I do not understand why DEQ is taking so long to meet this directive.

     If ever there was evidence of the need for this tool to supplement the existing narrative criteria, the Mountain Valley Pipeline violations provide that evidence. 

     The many water monitoring volunteers throughout the Commonwealth have for years tested streams and rivers for turbidity.  By not making numeric turbidity standards a top priority, DEQ is devaluing citizen science and the role of volunteers in maintaining water quality in our Virginia streams and rivers.  It may be too late for streams in the path of the MVP in terms of sedimentation, but please adopt the Wild VA-suggested standards soon so that other streams and wildlife are better protected in the future.

Thank you,

Molly Petty


CommentID: 98470

5/12/21  5:11 pm
Commenter: Margaret A Leasure

Water Turbidity

Without overview of where we are currently with water turbidity we will not be able to access water quality changes.  I do support us having a state wide standard.  Great idea.

CommentID: 98478

5/12/21  6:21 pm
Commenter: John C Wise


I am a citizen of Rockbridge County and have learned that there is little regulation of suspended solids in the Virginia water quality regulations.  I hope that this will change as the environmental damage that is caused by those suspended solids is severe.  Of course there are natural / environmental causes of turbidity but there needs to be some regulations crafted (for activities that can be regulated) in and around water bodies.  If monitoring detects a rise in non environmentally caused activities, then actions need to be taken to limit or regulate those activities.  Thanks! 

CommentID: 98482

5/12/21  10:24 pm
Commenter: Barbara L. Walsh

Turbidity Standards

Turbidity standards are essential for measuring and analyzing water quality.  In Rockbridge County, monitors are collecting field data but currently have no standards to determine what is acceptable, or to correlate with declines in macroinvertebrate indicators or other stream impairment criteria.  Standards would also help improve the success of TMDL implementation plans in addressing erosion, storm water management, and sedimentation impacts on existing and designated stream uses.

Since as much as half or more of suspended load may be mobilized during storm events, it will also be important to provide guidance on sampling protocols to accurately account for variations in turbidity and provide insight into watershed-specific contributions to turbidity.

Standards for field measurements made with a secchi disk or other qualitative methods, as well as numerical nephelometric measurements should also be considered.  

I urge DEQ to promptly complete the process of developing turbidity standards and protocols that protect Virginia’s citizens, wildlife, and the water quality and health of our streams, rivers, and Chesapeake Bay.

CommentID: 98501