| Action | Chesapeake Bay Nutrient Criteria - 2007, 2008 and 2010 Criteria Assessment Protocols Addenda |
| Stage | Fast-Track |
| Comment Period | Ended on 12/22/2010 |
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5 comments
I see no mention of a standard for salinity. Tidal creeks on the seaside of Virginia's Eastern Shore have suffered reduced flushing action as the result of the headwaters of many of the creeks having been dammed, either by the construction of agricultural ponds or by the construction of Route 13. The creek on which I live (Kings Creek in Northampton County) suffers from both causes. As a result, there is minimal flushing of the creek, leading to increased levels of fecal coliform bacteria, decreased levels of salinity - as the salt wedge cannot move upstrean on high tides, and decreased numbers of oysters and clams growing in areas in which they were formerly plentiful.
The upper portions of Kings Creek and many others are very shallow, not at all channelized, and do not flush properly. This leads to reduced numbers of fish and shellfish. Since shellfish are lacking, the water is no longer filtered effectively, leading to increased levels of fecal coliforms, and algal blooms. Crashing of the algal blooms can exacerbate low DO levels.
Every creek leading to the Chesapeake Bay in Northampton County has shellfish closures, due to high levels of fecal coliform bacteria, because of this poor flushing.
The only solution I see ot this problem is instituting a salinity standard, removing the dams which cut off the headwater flows and dredging the creeks to restore the channels and flushing of the upper portion of the creeks.
Department of Environmental Quality
State Water Control Board
Water Quality Standards [9 VAC 25 ? 260]
After reviewing the information on the Proposed Modification to
9VAC25-260-185. Criteria to protect designated uses from the impacts of nutrients and suspended sediment in the Chesapeake Bay and its tidal tributaries.
It appears there is a complete lack of knowledge of aquaculture with regard to water quality needs for propagating shellfish, and the contribution that watermen and aquaculture in Northampton County make to the Commonwealth of Virginia.
Your regulation only addresses a portion of the problem generated by development and growth not the effects of your proposed resolution (includes filtering of the bay waters by mollusks) of the total problem. The proposed regulation is only reviewing the discharge from Sewerage treatment plants, food processing, chemical and paper industries. These industries could be discharging “PERRIER” and the negative effect (degradation of the shellfish nursery areas) on the seafood industry would be the same.
There is:
No consideration given to the need of salinity to propagate Clams and Oysters. Your proposed regulation only mentions/addresses fish spawning and nursery areas and they are much different than shellfish spawning and nursery areas.
An effect on private property owners that have Riparian rights to Oyster Grounds. Please review Va. Code § 28.2 -602 and 603
An effect on small business as there is a need for salinity levels of 20,000 to 30,000 PPM in order to propagate clams that Watermen in Northampton County attempt to grow and people all over the world eat.
No mention of the bayside creeks of Northampton County in this regulation. There is no acknowledgement that they even exist.
No mention of the bayside creeks of Northampton County providing a significant number of jobs to the residents in your Environmental Impact Statement.
The continuing effort of the Commonwealth of Virginia to create a “ONE SIZE FITS ALL REGULATION” does not correctly nor adequately address the needs of the Commonwealth. It is evident that those persons creating the regulations need broader experience and knowledge in the needs of the citizens of the Commonwealth. I respectfully request DEQ, DCR and the Office of Planning and Budget to contact other stakeholders and further review its report.
Water Quality Standards [9 VAC 25 ? 260]
After reviewing the information on the modification to the Proposed Modification to the
9VAC25-260-185. Criteria to protect designated uses from the impacts of nutrients and suspended sediment in the Chesapeake Bay and its tidal tributaries.
There is:
No consideration given to the need of salinity to propagate Clams and Oysters. It only addresses fish spawning and nursery areas and they are much different than shellfish spawning and nursery areas.
An effect on private property owners that have Riparian rights to Oyster Grounds.
An effect on small business as there is a need for salinity levels of 20,000 to 30,000 PPM in order to propagate clams that people all over the world eat.
No mention of the bayside creeks of Northampton County in this regulation. There is no acknowledgement that they even exist.
No mention of the bayside creeks of Northampton County providing a significant number of jobs to the residents in your Environmental Impact Statement.
I respectfully request DEQ, DCR and the Office of Planning and Budget to contact other stakeholders and further review its report.
In review of the Proposed Modification to 9VAC25-260-185. Criteria to protect designated uses from the impacts of nutrients and suspended sediment in the Chesapeake Bay and its tidal tributaries; I find inaccuracies in the following areas:
1. There is an economic effect on private property owners that have Riparian right to Oyster Grounds.
2. There is a biological need for salinity to propagate Clams and Oysters.
3. The change in regulation addresses purity of industrialized discharges. It does not consider the fact that pure water has a “NEGATIVE EFFECT” on the ‘SALTWATER” seafood industry. This may be great for brook trout, but lethal for clams and other mollusks.
4. There is a negative effect on the aquaculture economy when the Commonwealth of Virginia creates an environment is neither conducive to propagate clams or to the harvest of selfish.
Your reports are not accurate and need additional review. Northampton and Accomack Counties are still part of the Commonwealth of Virginia. There appears to be a complete lack of knowledge of aquaculture with regard to water quality.
Thank you.