As a water monitor for both Trout Unlimited and the Chesapeake Bay Alliance in 3 counties, I strongly encourage DEQ to adopt a numeric turbidity criteria that protects existing and designated stream uses in Virginia.  Virginia needs a better tool to protect its wildlife and streams, and we are behind the curve on this: "at least 30 states, four U.S. territories, and dozens of Native American tribes have addressed sediment pollution by adopting numeric criteria." (https://www.virginiamercury.com/2020/05/11/even-after-pipeline-pollution-deq-is-still-resisting-water-protections-and-public-participation/

     Back in April 2019, the State Water Control Board voted unanimously to direct DEQ "to develop numeric turbidity standards for use across the commonwealth,” “to make this a top priority,” and to handle it on “an accelerated schedule." Wild Virginia and West Virginia Rivers have suggested criteria suited specifically to Virginia streams; the EPA has suggestions for Virginia.  I do not understand why DEQ is taking so long to meet this directive.

     If ever there was evidence of the need for this tool to supplement the existing narrative criteria, the Mountain Valley Pipeline violations provide that evidence. 

     The many water monitoring volunteers throughout the Commonwealth have for years tested streams and rivers for turbidity.  By not making numeric turbidity standards a top priority, DEQ is devaluing citizen science and the role of volunteers in maintaining water quality in our Virginia streams and rivers.  It may be too late for streams in the path of the MVP in terms of sedimentation, but please adopt the Wild VA-suggested standards soon so that other streams and wildlife are better protected in the future.

Thank you,

Molly Petty