Is the lake safe for 2025 swimming?

My concern is about the potential for delayed advisories if cell counts are no longer a primary trigger. This only covers up the issue and leaves the possibility of a lesser window for responding and protecting.property and people.

Thank you for the opportunity to share this.

Tom Krahling 

I am very concerned about the proposal to remove cyanobacteria cell counts as an early indicator of harmful algae blooms and the trigger for issuing HAB advisories in Lake Anna. The counts are highly valuable, as they serve as a critical component of the proactive and precautionary approach to HAB management. virginia needs a comprehensive advisory protocol that considers multiple lines of evidence, including cell counts, visual observations, and toxin testing for this growing, harmful issue.  Please donnot eliminate cell counts!

I share a home on lakefront property at Lake Anna with family members that include grandchildren.  Stopping the testing of the levels of bacteria in the water that delays HAB advisories and documentable testing results (data points) is unacceptable as it puts humans at increased risk that is avoidable.

It has been brought to my attention that the VDH is currently considering revisions to the HAB Advisory Protocol, and a key proposed change involves eliminating cell counts of cyanobacteria as a primary trigger for issuing a HAB Advisory.  Please reconsider this proposal.  Early warning and consistent monitoring of harmful algae is critical to the health and well being of all who visit Lake Anna.  Lake Anna is visited by 10 of thousands each year.  Since the effects of HAB's are often unknown and hidden, lake visitors could be exposed with little or no knowledge.  The health and well being of the people of Virginia is the responsibility of the Dept. of Health.  Please reconsider this proposal.  The added expense is small in comparison to the safety of 10 of thousands of people.    

Read the subject line 

Treatment needed before sickness  not  following illness

· I have significant concerns about the potential for delayed advisories if cell counts are no longer a primary trigger.

· consider the importance of a proactive and precautionary approach to public health protection.

· Try to understand the value of cell counts as an early indicator of potential HAB risks.

· There is huge need for a comprehensive advisory protocol that considers multiple lines of evidence, including cell counts, visual observations, and toxin testing.

· it needs to be demonstrated that the ongoing HAB issue at Lake Anna to secure continued mitigation funding.

An ounce of prevention is worth a pound of cure. Basing the swim advisory on the cyanobacteria cell count is applying an ounce of prevention. It informs people before the toxin level becomes dangerous. If the advisory is based on toxin level, swimmers may get that advisory after they've already been exposed and become sick. Then they'd need the pound of cure. Water quality is not measured on a continuous basis, so it is unlikely that if a problematic toxin level were reached, it would happen coincident with a water quality test. Basing the advisory on toxin level also assumes that there is no gap between the advisory being issued and the advisory being seen. If the advisory is issued at 8 am, too bad for the boaters who got out on the lake early to enjoy a peaceful swim while the lake is uncrowded.

I strongly disagree with the proposed change to the HAB Advisory Protocol! The proposed change to eliminate cell counts of cyanobacteria as a primary trigger for issuing a HAB Advisory. These tests serve as a very important factor in the rapid detection and alerting of potential HAB risks to public health and safety. These tests play a vital role keeping our environment safe and healthy for all our families. VR Sam

As a home owner on Lake Anna, I am very much concerned about the proposed changes to the VDH HAB Advisory protocol.  The plan to remove cell counts of Cyanobacteria as a primary trigger for a HAB advisory is short-sighted and dangerous.  Cell counts are very valuable as an early indicator, along with visual observations and toxin testing.  It is important to be proactive and precautionary when it concerns public health.  Without the cell counts there is the potential for delayed advisories leading to human health issues.  Thank you for your attention to this matter.  Sally Molenkamp

Apparently the people determining how and when to report on harmful bacteria’s do not live at or use Lake Anna. WHEN the algae blooms release their toxins is ONLY PREDICTABLE if you are measuring the CELL COUNT. If you are only watching for the blooms, you are TOO LATE…it has already released the toxins, so you are TOO LATE in reporting to the public of the danger or any advisory for contact with the water OR eating fish in the lake.  This affects residents, tourists, their pets, and property values. 
I cannot believe you are willing to put the residents and VISITORS (who know nothing about this) at risk for the sake of skipping the CELL COUNTS! 
Please use cell counts to protect our health and the health of all living creatures in and around the lake. Better yet…FIX THE PROBLEM! Fight for funding using our tax dollars. 
Thank you from this worried science-educated person. 

Hello, I am writing because I am concerned about the proposed changes.

We've been coming to the lake for almost 40 years, bought property in Windwood Coves shortly after it opened & were able to build here finally in 2021. We love the lake and have been encouraged by the progress being made over the last few years in keeping the water clean & safe. We joined LACA to support that work & believe it is important, especially with our warmer weather. My understanding is that cell counts are early indicator of potential HAB risks and there is potential for delayed advisories if cell counts are no longer a primary trigger. The "no swim" areas seem to be including more & more of the lake. Concern for the health of my grandchildren as well as friends and neighbors makes me speak up. 

   This is not my area of expertise (I am a nurse) but I believe in the importance of a proactive and precautionary approach to public health protection. Please continue the active funding and ongoing efforts to maintain a healthy environment for us all to thrive in here at Lake Anna.

Thank you.

As an owner on Lake Anna with 12 grandchildren who range in age from 1 to 20 years of age, I am very concerned regarding the proposed change involves eliminating cell counts of cyanobacteria as a primary trigger for issuing a HAB Advisory. 

This seems to be an imperative aspect of determining the safety of the lake water. It is short-sighted and dangerous to eliminate such an important step.

Thank you for your attention to this concern,

Dr. Carol Walker 

We are waterfront residents in Lake Anna's Cuckoo's Nest community and are concerned about a proposed change to the VDH HAB Advisory Protocol which would eliminate cell counts of cyanobacteria as a primary trigger for issuing a HAB Advisory. We have had HAB outbreaks in our cove over the past several years and believe these pose a serious health risk to all who use the lake. Recording cell counts are part of a proactive approach to dealing with the HAB problem, and we are concerned about the potential for delayed advisories if cell counts are no longer a primary trigger. We are also concerned about the potential impact this changed could have on demonstrating the ongoing need for funding and support for HAB mitigation efforts at Lake Anna, as historical cell count data provides critical evidence of the persistent nature of these blooms. We support a comprehensive advisory protocol that considers multiple lines of evidence, including cell counts, visual observations, and toxin testing.

As a Lake Anna homeowner, I am writing to express my concerns over proposed regulation changes to the HAB advisory protocol.  Should cell counts no longer be a primary trigger, there is the potential for advisories to be delayed, creating a potential health hazard.  The value of cell counts is an early indicator of potential HAB risks and should be continued.  Furthermore, the need exists for a comprehensive advisory protocol that considers multiple lines of evidence, including cell counts, visual observations, and toxin testing.  Lake Anna is our home and both I and our community are dedicated to keeping it a safe place for water activities.  Thank you for your consideration.

I am concerned if there is not a robust way to measure HAB and inform the public.  We live on Lake Anna and want to keep ourselves and our guests safe.

BLUF:   We object to the proposed change eliminating cynobacteria cell counts in the Lake Anna HAB Advisory Protocol and support the Lake Anna Civic Association efforts to continue current HAB advisory protocols.

For the past 2 summers, we have been short term rental STR owners of a mid-lake home on the public side of Lake Anna.   While our location has not been affected by HAB, we have had comments that our location was preferred based upon notifications recieved from VDH.     We belong to a group of STR owners who also identify that VDH notifications asssist in the management of their properties. 

This year, we have pulled our house from the STR market to conduct a major renovation in preparation for making Lake Anna our primary residence.    VDH ability to accurately track HAB using every tool (including cell counts) will keep my family safe and enjoying the lake. 

I am writing to express strong opposition to the Virginia Department of Health’s (VDH) proposed edits to the Guidance for Cyanobacteria Recreational Advisory Management, specifically the proposal to eliminate the use of cyanobacteria cell counts as a criterion for issuing harmful algal bloom (HAB) alerts, as noted in the public comment period from April 21 to May 21, 2025. As a risk management professional and a concerned homeowner, I believe removing cell counts from the decision-making process undermines the scientific rigor, transparency, and precautionary approach necessary to protect Virginia’s residents, visitors, and pets from the risks posed by HABs. Below, I outline the critical role of cell counts in HAB monitoring and provide evidence-based arguments for retaining this metric in advisory determinations.

Importance of Cyanobacteria Cell Counts in HAB Monitoring

Cyanobacteria, often referred to as blue-green algae, are naturally occurring microorganisms that can proliferate rapidly under favorable conditions, forming HABs that pose significant risks to human and animal health. These blooms can produce cyanotoxins, such as microcystins and cylindrospermopsins, which are associated with skin irritation, gastrointestinal illness, neurological damage, and, in severe cases, liver damage or death. The decision to issue a recreational advisory must rely on robust, quantitative data to ensure timely and effective public health interventions.

Cell counts of cyanobacteria are a well-established, objective metric used by numerous state and federal agencies to assess the potential toxicity of a bloom. Eliminating cell counts as a criterion disregards this evidence-based framework and risks weakening the ability to detect potentially harmful blooms early. Cell counts provide a direct measure of cyanobacteria abundance, which is critical for assessing bloom severity before toxins reach dangerous levels. Unlike toxin concentrations, which may only become detectable after cell lysis or death, cell counts can serve as an early warning indicator, enabling proactive advisories that prevent exposure before toxins are released into the water column.

Scientific and Practical Limitations of Relying Solely on Toxin Concentrations

The proposed shift to rely primarily or exclusively on cyanotoxin concentrations for issuing HAB alerts is problematic for several reasons:

1. Delayed Detection of Risk: Cyanotoxins are often released into the water only after cyanobacteria cells die or rupture, meaning that toxin-based monitoring may fail to identify a bloom in its early stages. Cell counts, by contrast, can detect rising cyanobacteria populations before significant toxin release occurs, allowing for earlier public notification and intervention. For instance, the VDH’s own monitoring of the North Fork of the Shenandoah River in 2021 demonstrated that cell counts and visual observations of benthic cyanobacteria mats prompted advisories, even when toxin levels in the water column were below advisory thresholds. This proactive approach likely prevented human and animal exposure to potentially harmful conditions.
2. Variability in Toxin Production: Not all cyanobacteria blooms produce toxins consistently, and toxin production can vary based on environmental factors such as temperature, nutrient levels, and light intensity. A bloom with high cell counts but low detectable toxins at the time of sampling may still pose a future risk if conditions change. The EPA notes that cyanobacteria like Microcystis and Dolichospermum can produce toxins under specific conditions, and cell counts provide a reliable proxy for assessing this potential. Excluding cell counts ignores this latent risk and may lead to premature lifting of advisories.
3. Limited Accessibility of Toxin Testing: Toxin analysis, such as testing for microcystins or cylindrospermopsins, requires specialized laboratory equipment and expertise, which can be costly and time-consuming. In contrast, cell counts can be performed more rapidly through microscopic enumeration, often in collaboration with institutions like the Old Dominion University Phytoplankton Laboratory, which supports Virginia’s HAB Task Force. The VDH’s own protocols highlight the efficiency of cell count-based assessments in guiding initial responses to suspected blooms. Removing this metric could strain resources and delay advisories, particularly in rural areas with limited access to advanced testing facilities.
4. Incomplete Risk Assessment: Toxin concentrations alone do not capture the full ecological and health risks of HABs. Dense cyanobacteria blooms, even if non-toxic, can deplete dissolved oxygen, cause fish kills, and disrupt aquatic ecosystems, as noted by the EPA. High cell counts can also indicate excessive nutrient pollution, signaling the need for broader environmental management actions. By focusing solely on toxins, the VDH risks overlooking these secondary impacts, which have significant implications for recreation, tourism, and local economies.

Public Health and Safety Implications

The VDH’s mission is to protect public health, and the current hybrid approach—using both cell counts and toxin concentrations—ensures a precautionary stance that prioritizes safety. The proposed elimination of cell counts could erode public trust in advisories, particularly in light of past HAB events in Virginia, such as those in Lake Anna.

Pets and livestock are particularly vulnerable to cyanotoxins, with documented cases of fatalities in dogs that ingested contaminated water or licked algae from their fur. The VDH’s advisories, informed by cell counts, have been critical in preventing such incidents by warning pet owners to avoid affected areas. Removing cell counts could delay or prevent these warnings, increasing the risk of exposure for vulnerable populations, including children, who are more susceptible to cyanotoxins due to their lower body weight.

Economic and Community Impacts

Virginia’s waterways, including Lake Anna, are vital for recreation, tourism, and local economies. HABs pose a financial burden to communities reliant on water-based activities, as noted by the Virginia Department of Environmental Quality (DEQ). Accurate and timely advisories, supported by cell count data, help mitigate these impacts by clearly defining affected areas, allowing safe recreation to continue where possible. For instance, in the 2021 Shenandoah River advisory, the VDH noted that activities like kayaking could continue in areas with low contact risk, a determination informed by cell count and mat observations. Eliminating cell counts could lead to broader, less specific advisories, unnecessarily restricting access to unaffected areas and harming local businesses.

Recommendation

To maintain a robust and protective HAB advisory system, I urge the VDH to Retain Cell Counts as a Core Metric. Continue using cyanobacteria cell counts alongside toxin concentrations to ensure early detection and comprehensive risk assessment. The proposal to eliminate cyanobacteria cell counts from HAB advisory determinations is a step backward in protecting Virginia’s residents, visitors, and ecosystems. Cell counts are a scientifically validated, proactive, and accessible metric that complements toxin testing and ensures timely advisories. Retaining this metric aligns with national and international standards, and supports public health. I strongly urge the VDH to reconsider this proposal and maintain the current hybrid approach to HAB management.

I am a Lake Anna waterfront property owner since 2012.  We have experienced summers marked by issuance of repetitive VDH No Swim Advisories for the past five years and while frustrating, I am grateful for them as we have nine grandchildren who regularly visit us and the advisories have helped keep them from becoming sick by swimming in (and ingesting) our lake water.  

I believe it is a serious mistake for VDH to change the basis for issuance of swim advisories to toxin cell count level only from the current hybrid cell density and toxin level standard.  Fact is, HABs are a problem at Lake Anna and this change in basis will create a perception by the public and state/local legislators that there is no problem anymore.  The Lake Anna Civic Association (LACA) in collaboration with local and state government offices, is actively engaged in efforts to remediate the excess nutrient conditions that materially contribute to HAB problem at Lake Anna.  No swim advisories are an overt signal that this excess nutrient conditions persists.  

In deference to the safety and well-being of everyone that lives on or recreates at Lake Anna (and every other body of water in Virginia), do not change the swim advisory basis.  It does not infringe on anyone’s ability to take a decision to swim/recreate in the lake despite its issuance…but serves the greater good by providing a warning of the potential effects swimming hold as well as providing a glaring reminder to lake residents and, equally importantly, state and local legislators that the underlying causes of HABs remain unsolved and resources continue to be needed to successfully remediate the excess nutrient presence in the lake that are HABs’ root cause.

Hab

I am concerned and perplexed by the decision to limit Swim Advisory notifications for Lake Anna based on the elimination of cell counts of cyanobacteria as a primary trigger for issuing the Advisory. 

Historically, elevated cell counts, in conjunction with visual observations and cyanotoxin testing, have served as important indicators of potential HAB risks. The issuance of a  swim advisory based on high cell counts, which is the precursor to a toxic bloom, the public was then able to make informed decisions regarding when and where to recreate in the lake. 

The recently proposed HAB Advisory Protocol, removing cell counts as a primary trigger, will essentially eliminate the “warning”, delaying public notification of conditions that in themselves could cause minor sickness to animals and humans, but moreover leading to the condition where the “warning” will be issued after toxins are present, and  sickness or worse from exposure to the toxins could have already occurred. Have we not learned anything from the EColi  issue experienced during the Memorial day weekend of 2024?

I live on Lake Anna in the effected areas where high cyanobacteria counts commonly occur in the heat of summer. I know first hand the value of cell counts as an early indicator of potential HAB risks and the need for a comprehensive advisory protocol that considers multiple lines of evidence, including cell counts, visual observations, and toxin testing.

 This issue for Lake Anna and other freshwater lakes in Virginia is not going to go away or in any way be mitigated by changing the testing and notification protocols. Please rethink this approach before we have an issue that everyone regrets. We must continue to fund the required testing, and notifications that result from it, and while we are at it, a mitigation strategy that is appropriate for the HAB issue the state is facing. In this way you will also be protecting this valuable resource that brings tens of millions of tourism and real estate tax dollars to the state and local governments. 

I'm writing about eliminating cell counts of cyanobacteria as a primary trigger for issuing a HAB Advisory. I am concerned that this will delay advisories if cell counts are no longer a primary trigger. Please be pro-active not re-active. Is this change being made for budgetary reasons? Please consider not only the health and safety of those recreating at Lake Anna, but the economic impact that harmful algae blooms have on the community. Please keep the cell counts as a trigger for issuing advisories. Thank you

It is very  important to have  a proactive and precautionary approach to the HAB issue at Lake Anna VA for the health and safety of those who live here, visitors and all who swim in our lake, including our pets.  I believe we need to keep cell counts as an early indicator of potential HAB risks.

I am very concerned about the potential for delayed advisories if cell counts are no longer a primary trigger.  We need to have a comprehensive advisory protocol that considers multiple lines of evidence, including cell counts, visual observations, and toxin testing.

We have property at Lake Anna and enjoy living here.  However, over the past several years, more and more HAB advisories have been issued for certain parts of the Lake with recommendations to curtail water activities for individuals and pets.  We appreciate those HAB early warnings, however, the new protocol will delay advisories if "cell counts" no longer trigger warnings of HAB at an early stage.  Visual observations and testing for toxins is also important.  Rather than a proactive approach to public health, this new protocol would be reactive and we would potentially have very late advisories for HAB.  Not only is HAB a health risk, but it is important that there be continued funding for mitigation of HAB for those living here and visiting the Lake.  As the media learns about HAB at the Lake and it becomes known around VA, DC and MD, fewer people will be interested in coming to the lake or even living here.  They will simple go elsewhere to spend their money.  Consequently, it is imperative there be continued efforts to eliminate, mitigate, and have appropriate protocols for HAB.  Thank you for your attention to this important issue.

The Lake Anna Civic Association (LACA) submits these comments with significant concerns regarding the proposed removal of cell counts as a primary trigger for issuing Harmful Algal Bloom (HAB) advisories. While understanding the rationale for protocol modifications, we believe eliminating cell counts as a key determinant for public health advisories risks reducing the proactive and precautionary nature of the current protocol, potentially increasing public exposure to harmful cyanotoxins.

Cell counts, used with visual confirmation and cyanotoxin testing, offer a valuable early warning system for potential HAB risks. Removing this primary trigger could lead to a reactive approach, with advisories issued only after toxins exceed health thresholds. This delay could expose recreational users, especially vulnerable populations, to harmful conditions during early bloom stages when cell densities are substantial, even with low initial toxin levels.

Eliminating cell counts as a primary advisory trigger will diminish the perceived severity of HABs at Lake Anna, as documented by historical data. This could undermine future funding requests, as justifications often correlate elevated cyanobacteria biomass (cell counts) with potential cyanotoxin production and ecological/public health risks. Removing this direct indicator weakens the case for continued investment in mitigation strategies targeting nutrient loading from non-point sources in the Lake Anna watershed.

Furthermore, cell counts are a cost-effective and rapid indicator of potential HAB development, often preceding significant toxin increases. This early warning allows proactive communication and targeted management. Sole reliance on resource-intensive, reactive toxin testing may inadequately capture bloom dynamics and associated risks linked to high cell biomass, even with inconsistent toxin exceedances at sampling times.

We urge the Virginia Department of Health to reconsider removing cell counts as a primary advisory trigger. We recommend integrating cell counts as a crucial line of evidence alongside visual observations and cyanotoxin testing for a comprehensive, protective HAB advisory system. This integrated approach enables earlier public notification and preventative measures, ultimately better safeguarding public health and ensuring continued support for mitigation efforts.

My husband and I have visited Lake Anna for over 30 years and have lived here for 8 years.  We have enjoyed the beauty and water quality of the lake for many years, but the past 5 years have become increasingly concerned about the HAB’s at the lake and water quality in general.  We personally choose to never swim in the north section of the lake due to the HAB advisories even knowing there are proactive measures in place today for early detection of HAB.  It makes no sense, why would our government entertain stopping a HAB protocol that works and provides early warning to the public.

It is alarming to think that our state agencies would even entertain HAB testing protocol changes given the history of HABs at Lake Anna as well as the Ecoli event in 2024.  The state agencies mission and priority must be to continue to protect the health and well being of the public.  Please do not approve the proposed HAB changes. 

Please continue to fund Lake Anna for HAB testing and mitigation to ensure that the lake can remain a viable economic engine for Central Virginia and home to many citizens.  Don’t make citizens living here want to leave because we cannot rely on Virginia government agencies to protect us when swimming at Lake Anna. 

It would be terrible if Lka waiting for a solution instead of being proactive for its residents and people who enjoy our beautiful place!! Do not make any negative changes to the work already done! 

We are counting on you to protect our recreational health at Lake Anna.  You need to take every possible opportunity to keep us safe and the Lake CLEAN and not harmful to our health.

Do your JOB

As a property owner on Smith Mountain Lake, I have concerns about the change to the existing HAB guidance document for Recreational Advisory Management. The policy change is apparently supported by an over simplified analysis of a 406-sample dataset that includes paired cell counts and toxin assays. The analysis concluded that there is no correlation between cell counts and toxin concentrations. To ensure complete transparency, the dataset should be made available to the public, and should include important data elements such as sample date, location, cell counts, when sample collected within the bloom cycle, cyanobacteria species (if available), targeted analyte, analytical method, detection level, reporting level and the result. Despite the general conclusion of no correlation between cell counts and cyanotoxins, knowing there are cyanobacteria species that produce greater (or multiple) toxin concentrations based on cell count is crucial for informed management actions. Given the complexity of this issue, it makes more sense to approach advisory decisions using multiple lines of evidence that also takes cell counts into consideration.

We have been homeowners at Lake Anna since 2016, and since that time have noted increases in the HAB in the lake.  We have personally encountered the cancellation of guest rentals out of fear and concern about the matter, and are aware of illnesses caused as a result of HAB.  I am concerned that the proposed protocol in "Guidance for Cyanobacteria Bloom Recreational Advisory Management", which eliminates cell counts as a primary trigger, could shift the protocol towards a more reactive approach.  This could potentially delay public notification and increase the risk of exposure to harmful cyanotoxins, especially during the early stages of bloom development when cell densities can be high even before toxin levels spike. This protocol does not provide enough advance warning regarding HAB to ensure the public safety of both residents and guests.  Cell counts provide valuable information and are early indicators of potential risks.  HAB is an ongoing issue that must be addressed on multiple fronts including, visual observation, toxin testing and cell counts.  Please keep this important matter a priority to ensure continued mitigation funding.  

Thank you.

I am against the proposed change in guidance for issuing Cyanobacteria Bloom Recreational Advisories. The basis for the change relies on EPA 815-R-15-010, "Recommendations for Public Water Systems to Manage Cyanotoxins in Drinking Water June 2015", which has little to do with Recreational Water Quality. Drinking water quality is measured continuously while recreational water quality is measured at best once a month. The proposed change will delay the issuances of swimming advisories significantly, thereby putting the public at unnecessary increased risk.

It is obvious that much thought and review of past data resulted in the advisory protocol changes.  Targeted monitoring of algae toxins during an algae bloom is good!  It is not good to effectively issue a "No Swim Advisory" for thousands of acres of Smith Mountain Lake over several months during the prime summer months, especially since 5 years of testing showed no algae toxin levels were even close to advisory levels and the vast majority were "below detectable levels".  This occurred at Smith Mountain Lake in 2023.  Media coverage made the whole lake sound bad.  

It is good that DEQ and VDH will be aligned with the final recommendations from the U.S. Environmental Protection Agency (EPA).

As the Executive Director for the Smith Mountain Lake Regional Chamber of Commerce, I can definitively say that nothing is more important to the Chamber’s 700-plus members than monitoring and maintaining the quality of water at Smith Mountain Lake.  Our member’s livelihood is dependent upon this body of water remaining pristine both now and for generations to come.  Our members have and I assume will continue to support the testing of our water by the DEQ along with our local efforts with the Smith Mountain Lake Association’s partnership with Ferrum College which is now in its 38^th year monitoring all aspects of water quality at SML.

I also understand the enormous economic impact that a VDH Swim Advisory can have on our tourism industry, having experienced that firsthand in the Summer of 2023.  While the cell counts in certain portions of SML were elevated that year, none of the blooms ever resulted in elevated toxicity levels, and none of our swimmers were in any danger from a toxic bloom.  Obviously, ensuring public safety outweighs the hinderance to tourism caused by a “swim advisory”, and no one wants anyone swimming in any water that might cause them harm.  However, issuing misleading swim advisories based solely on cell count when the water is not actually toxic to swimmers causes a number of issues.  First, the issuance of overly cautious swim advisories erodes the credibility of the VDH and the DEQ and could undermine the effectiveness of their efforts to warn swimmers should an actual toxic event occur.  People will quickly learn to ignore swim advisories when the advisories are issued when no true threat exists. Secondly, unneeded swim advisories will depress tourism in our area as people will avoid coming to the lake if they incorrectly believe the waters are not safe. 

Most importantly, the “new” standards are not truly new.  All the VDH seeks to accomplish in modifying their standards is to bring Virginia’s monitoring of our waterways into alignment with the federal EPA guidelines.  While there may be outliers, one would think it is safe to assume many, if not all other states, are following these EPA guidelines.  Having our bodies of water held to a different set of standards for a swim advisory than other areas seems extremely counterproductive in predicting possible harm to swimmers, and also to promoting tourism in Virginia.  So, I certainly understand the logic of the VDH following the nationally set EPA guidelines and support the decision to change the guidance document.

I assume our members will continue to support the monitoring of our lake by DEQ and on a local level…we have too much invested in this beautiful body of water to do anything else. Nonetheless, the new guidelines of the VDH should be adopted and supported.

We are long time waterfront property owners and full time residents at Lake Anna. We fully support the commenters that have responded to this survey in favor of the importance that cell counts of Cyanobacteria continue to be used as a trigger for issuing a HAB advisory.  These individuals are intelligent and knowledgeable about the potential public health risks caused by HAB.   The VDH’s goals should ensured that ALL local families, visitors and pets are safe while recreating at Lake Anna.  Therefore, we strongly oppose any change by VDH that would compromise cell counts of Cyanobacteria as a trigger for issuing HAB Advisories.  

Observation:  Only a fraction of water bodies in Virginia are monitored for algal blooms and toxins, so it’s important for people to become familiar with signs of a bloom, exposures and symptoms by visiting VDH and VDEQ websites and having ready access to information about Harmful Algal Blooms (HABs) through other avenues as well.  The agencies are making good progress in this direction.  More needs to be done.

Comment 1:

One avenue of information recognized in the draft guidance that needs to be made stronger is outreach and communications with the veterinary medicine community.  More consistent coordination with and a reporting mechanism for veterinarians is warranted.  Neither seems to exist based on an online search or in the edits to the guidance.

A process to work with the veterinary community to issue pre-emptive public warnings following reports of dog illnesses or deaths possibly resulting from cyanotoxin exposure is needed.   These pre-emptive warnings will help with identifying immediate next steps to inform the public about the possible presence of cyanobacteria in a water body.

Consistent communication about and reporting of HABs from the veterinary community is needed based on:

• Dogs can get extremely ill, and even die, within minutes to hours of exposure to cyanotoxins from drinking water, licking their wet fur or eating floating mats or dried crust along the shore.  
• Toxin testing is only possible for certain types of cyanobacteria. When testing is done, results are typically available within two weeks.  Reporting of HABs encounters from the veterinary community may be more timely.
• Even with lifted advisories illness in pets can still occur at lower toxin values, so there is a need to continue to exercise caution with pets at these areas.

The guidance on Page 4 is too vague.  Draft generic announcement language should be included in the edits to the Guidance.  The language on page 13 clearly supports the need for reporting of HAB animal mortalities, and suspected mortalities, to VDH and DEQ.

Comment 2:

The edited guidance states “New Zealand has a traffic light system based upon coverage of substrate by attached mats and mats detaching and washing up on shore.”   VDH currently has an online Harmful Algal Bloom Map (Dashboard) that also includes a traffic light system.  The revised guidance should be expanded and enhanced to outline and make use of a simple green/yellow/red local advisory process for the public.  https://www.vdh.virginia.gov/waterborne-hazard s-control/algal-bloom-surveillance-map/

Comment 3:

Any difficulties with accessing information online need to be addressed in a timely and on-going fashion.  For example, 

There is out of date HABS information on the VDH webpages: 

For example, see “Health Topics A-Z” (accessed through Lord Fairfax Health District website )

https://www.vdh.virginia.gov/waterborne-hazards-control/harmful-algal-blooms/harmful-algal-bloom-faqs/

Last Updated: July 28, 2023

Within that FAQ there is a broken link:

“Information on freshwater HAB toxins are available here.”

Better information regarding HABs is found with the VDH cyanobacteria link:

https://www.vdh.virginia.gov/waterborne-hazards-control/harmful-algal-blooms/cyanobacteria/

which might be a much better link for HABS in the “Health Topics A-Z” webpages.

Thank you in advance for your consideration of these comments.