The Friends of the North Fork of the Shenandoah River oppose DEQs proposed regulatory action to increase the waste load allocation for Merck Pharmaceuticals and the Opequon wastewater treatment works.   Both facilities discharge nutrients and other pollutants directly into the Shenandoah-Potomac basin.   This action would result in Virginia exceeding the safe level of nutrient reductions needed to meet the State's water quality standards and commitments, not only in the basin but for the Chesapeake Bay.

Therefore, we request DEQ to (1) deny the requested increases and honor the State's commitments to permanently cap nutrient pollution and fully restore water quality in the Bay and its rivers and (2) require Merck and Frederick-Winchester Counties to find offsets or nutrient credits for their requested pollution cap increases.  This would result in a net-zero increase in nutrient pollution and the poolution caps would be maintained.  Also, we oppose stalling on Bay clean-up until EPA develops a TMDL for the Bay.  Even if a TMDL were to be completed by 2011, implementation is not guaranteed and is subject to many challenges.  Waiting for the TMDL to guide restoration puts off indefinitely real action to restore the Bay.