The Qpequon Watershed is a volunteer organization dedicated to understanding, protecting and improving Opequon Creek and its environment. 

We feel that any efforts on the Opequon that are beneficial for our watershed would help the health of the Chesapeake Bay as well as our local watershed.  So, while this stream is not part of the Shenandoah River watershed, increases in the level of pollution of the Shenandoah are undermining efforts made by us and other like-minded organizations and individuals whose projects are meant to help the bay as well as our local streams. 

With our rivers in poor condition already, it is especially important to us that you keep to the intent of the existing legislation and rules, rather than changing them to allow for more nitrogen and phosphorus to be deposited.

Please deny Merck and Frederick County Service Authority the ammendment to Water Quality Management Planning that would allow them to increase the load of phosphorus and nitrogen.  Promises to clean up our rivers and the bay in the future are not enough - the future is here and the cleanup needs to move forward.

Sincerely,

Sally Anderson, for the Board of The Opequon Watershed

It has come to my attention that DEQ has proposed authorizing pollution discharges into the Shenandoah-Potomac in excess of the “pollution caps” already determined by the Environmental Protection Agency to be protective of water quality in the Bay downstream.

I am specially speaking of the proposal that would allow Merck Pharmaceuticals and the Frederick-Winchester Service Authority to increase their pollution limits for nitrogen and phosphorus. These are the 2 main pollutants that are contributing to the degradation of the Chesapeake Bay.

Virginia’s commercial watermen have been saying for decades that the water quality of the Chesapeake Bay has been ruining the once vibrant seafood industry. By the Commonwealth’s own assessment over 10,600 miles of rivers and nearly the entire Chesapeake Bay DO NOT meet state water quality requirements.

In 2007, 88% of the Bay and its tidal tributaries did not meet water quality standards. 40% of the Bay was considered a dead zone. Many marine animals can swim out of a dead zone but larvae and the microscopic life that are so important to a rich and productive Bay are at the mercy of the tide and currents.

There are 2,980 commercial watermen in the Commonwealth of Virginia, down from 3,858 in 1993. These watermen depend on the Chesapeake Bay and its tributaries as their source of income. Not only does an unhealthy Bay affect these 2,980 watermen, but it also affects those people who process the catch and deliver the processed product. The effect is dramatic as it goes through the distribution chain.

Despite this reduction of watermen and record low catches, the Virginia Marine Resources Commission placed stricter regulations on the commercial watermen this year to achieve a 34% reduction in the female crab catch. The watermen are expected to abide by these new regulations.

I am sure the Secretary of Natural Resources expects VMRC to enforce these new regulations, just as I am sure he expects DEQ to live by the “pollution caps” and not authorize additional pollution to be addressed later in a future Bay cleanup plan.

Enclosed you will find a letter from Secretary Bryant where he tells me that he has every reason to believe that long established goals and pollution REDUCTION goals will be met.

I am writing to oppose the proposed increase of the nutrient-discharge caps for the Merck Pharmaceutical and the Frederick-Winchester Service Authority wastewater treatment facilities, unless the company and the authority are required to fund nutrient offsets within the Shenandoah-Potomac watershed that result in no net increase of discharged nutrients in the watershed.  This seems like a perfect opportunity to put the state's new nutrient credit exchange program into practice.

Alan Raflo

Blacksburg, Virginia

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.