DEQ should pause approving and funding stream restoration projects until their true nutrient reduction benefits have been studied and quantified.  A water monitoring study on Taylor Run in Alexandria, VA, completed in March of 2022, indicates that stream restoration may not improve water quality or reduce nutrients flowing into the Chesapeake Bay.  On the contrary, the study showed that most of the nutrient pollution flows into Taylor run from the upstream watershed.  So, a reengineering of this small urban stream would have done little to reduce the nitrogen, phosphorous, or sediment pollution in the Chesapeake Bay.  Worse, the use of construction equipment in the stream bed and stream valley would have likely increased sediment pollution flowing into the Bay.  As a result of the study, the City of Alexandria abandoned its plans to "restore" Taylor Run.  A few important takeaways from the study are listed below.  

• When evaluating nutrient reductions from a stream restoration project, do not rely on pollution reduction estimates derived from the Bank Erosion Hazard Index (BEHI) method.  They overstate nutrient reductions.  
• Stream bank soil sampling might give a better estimate of potential nutrient reductions from the proposed project, (but as we later learned, these estimates might also be badly inflated).  
• Water quality monitoring is the only way to accurately quantify nutrient reductions for a proposed stream restoration project.  
• Base nutrient reductions on good measurements and sound science.  

A copy of the Taylor Run final report has been forwarded to Tyler Monteith as an attachment to be included in these comments.  

Many environmental advocates have voiced concerns about the invasive and destructive nature of so called "stream restorations" which may do little restoration, but instead, a surprising amount of damage.  One advocate, Ken Bawer, has created a video on a stream restoration in Gaithersburg, MD that captures the concerns of many environmentalists.  Please take a moment to view this insightful video at: https://youtube.com/watch?v=NvTvPnG6Qs8.  

Given these concerns, it would be unwise and a poor management decision to accelerate the release of nutrient reduction credits for stream restoration projects.  

Virginia's streams and the stream in the rest of the Chesapeake Bay watershed are probably not the major source of nutrients degrading the Chesapeake Bay.  Nonpoint source pollution, transported by these streams to the Bay, is a problem that needs to be addressed, however.  

The Virginia DEQ is in a unique position to conduct water quality monitoring projects that clearly show the sources of nonpoint source nutrients that pollute the Chesapeake Bay.  It has the manpower and expertise to: 

• Conduct Taylor Run like studies that carefully quantify the benefits, if any, of a stream restoration project.  By monitoring at the upstream and downstream ends of a proposed project, DEQ can determine whether the stream is the source of the nutrient pollution or the upstream watershed.  
• Conduct water quality monitoring studies that clearly show where the nutrient pollution is coming from.  

Rather than reengineering streams, the Virginia DEQ should focus its manpower and resources on funding stormwater Best Management Practices (BMPs) in Virginia watersheds.  BMPs slow, filter, and sequester stormwater.  The upstream watershed appears to be the source of the nonpoint nutrient pollution problem.  Let's focus our efforts on the real problem.  

Thank you for the opportunity to comment on this proposed guidance document.  We would be happy to continue a dialog with the DEQ on this important matter.  

Sincerely, 

William Gillespie and Russell Bailey