Tag Archives: implementation plan

Time to Pay Attention to Oxygen for the Bay

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Blocked VDOT roadside ditch flooding adjacent land.

Blocked VDOT roadside ditch flooding adjacent land.

I wrote a report in 2012. If anyone in authority had paid attention then, we’d be seeing results now, instead of looking at more flooded ditches and damaged roads. Expect our TMDL numbers (total maximum daily load) for E. coli levels to stay the same, because the problem is not primarily land-based. It’s VDOT ditch based.

Although nothing about dissolved oxygen levels made it into the final EPA-accepted Water Quality Improvement Plan, there was a recommendation for a Ditch Task Force involving the Virginia Department of Transportation. The intent was to discuss and plan ways to improve the drainage for our state roads. Instead, we have the Middle Peninsula Planning District Commission advocating the creation of a Ditching Authority to charge landowners and counties for VDOT’s failures.

MPPDC is basing its Ditching Authority concept on states and countries which drained wetlands for agricultural purposes–and must continue to drain them to continue farming. Ohio, for example, drained 7.4 million acres of wetlands, and today, 2/3s of their cropland and 500,000 homes depend on that land staying drained. They have a Ditching Authority.

Our drainage problem is rainfall from state roads cannot reach receiving bodies of water because of failed and neglected VDOT maintenance. The cause is not wetland drainage, not agricultural land drainage, not private property drainage, not sea level rise, not land elevation or land subsidence.

Read the report and see for yourself if it makes sense.

Report for Working Groups for the Shellfish TMDL Implementation Plan for the Piankatank River, Gwynns Island and Milford Haven Watersheds, August 27, 2012

submitted by Carol J. Bova

A review of the original Shellfish Sanitation Surveys and outstanding violations for the Piankatank River, Gwynns Island and Milford Haven Watersheds doesn’t document enough ongoing septic system violations to account for the continuing high levels of bacteria in the TMDL waters. From the June 30th report, only Healy Creek had one prior uncorrected septic issue. There were two kitchen deficiencies: one at Healy Creek and one at Edwards Creek.

There are no large agricultural operations, fewer farms than decades ago when the waters were not impaired, and not enough hobby livestock to account for current bacterial impairments. It’s equally unlikely that pets are the main factor, and while wildlife contributes a significant amount, it is not the sole source.

Based on scientific findings over the last six years across the United States, in Canada and in Europe, naturalized E. coli is the most likely major source of the ongoing high bacterial readings.

These studies show E. coli does not require a human or animal host to survive for extended periods in soil, sand, sediments and water. Wind and storms stir up sand and sediment and release bacteria back into the water column. Bottom feeding fish like spot and croaker can take in E. coli while feeding and become carriers. Studies in Michigan show E. coli can survive 5 months in water as long as the temperature is above 39 degrees Fahrenheit. Average water temperatures for the TMDL areas only go below that in January and February and may not go that low in some years. E. coli doesn’t only survive on its own–it can reproduce if it has adequate carbon based nutrients. The presence of muck, which is partially decomposed vegetation, provides that nutrition and shelters E. coli, because no sunlight can get through it. It takes four days of sunlight to kill E. coli.

Part of the key to eliminating E. coli in the TMDL waters is to get the water clear enough to allow sunlight to penetrate. The plan to restore oysters is intended to do that, as well as filter the water, but oysters can’t live in the muck and must be suspended above it. The headwaters and some of the small inlets of the creeks are among the worst areas, with heavy muck, little circulation and probably low levels of dissolved oxygen in the water which must be addressed before oyster placement. Submerged aqueous vegetation will also benefit from more sunlight.

The long-term goal of restoring oysters is solid, but needs to be backed up with a multi-layered approach to cleaning up the waters, with a plan tailored to the characteristics of each TMDL segment. In Queens Creek, for example, at least 3-4 feet of muck exists on the sides of the channel, possibly more in the center. If the channel could be dredged to remove most of that muck, the creek could then be treated with probiotic decomposer bacteria to help break down what remains. This would create a more favorable environment for oysters and other water animals and allow sunlight to reach deeper into the water, killing even more E. coli.

Using small aeration units attached to private docks to provide additional oxygenation has been tried in Maryland. William Wolinski of Talbot County Maryland Dept. of Public Works stated the aeration used there from May through October created ‘oxygen sanctuaries’ for fish and other creatures and allowed positive bacterial action to break down sludgy sediment. A simple unit costs about $500-$600 and covers 1/4 acre placed at a 4′ depth according to one manufacturer. Any aeration provided will improve the action of probiotic bacteria in decomposing muck sediments.

Before any direct action is taken in TMDL creek headwaters and inlets, the Virginia Department of Transportation roadside ditches and related outfall ditches leading to those waters must be cleaned, pipe blockages cleared and overgrown vegetation removed to allow clean rainwater to reach the waterways. Currently, the water in outfall ditches is deoxygenated by decaying plant matter and has little to no flow except during storm events. Major storms flush the stagnant water into areas leading to the headwaters, and the load of rotting vegetation and silt with it adds to the mucky sediment already present.

The Virginia Department of Transportation should be named a stakeholder in the TMDL Implementation Plan for low dissolved oxygen levels in water in ditches which connect to TMDL waters. Credit trading should not be an option because the actions required to improve oxygenation fall within normal roadside maintenance and budget. DCR and DEQ staff can support citizen requests for a VDOT 5-year plan for roadside and outfall ditch maintenance to provide an outlet to an adequate receiving channel and body of water as required by VDOT Drainage Manual policies. This will allow clean, oxygenated rainwater to reach TMDL waters, giving other measures a better chance of success.

Good Turnout for TMDL Meeting – But We Missed the Part About The Army Corps of Engineers And Oyster Sanctuaries

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About 50 people came to the TMDL meeting in Hartfield, including Mathews County Supervisor Janine Burns and Planning Director John Shaw. About the biggest piece of new information was the BST test– bacterial source tracking — is no longer being used to identify the most likely source of fecal coliform contamination. That takes care of concerns over accuracy of the tests, but we don’t know yet how, or if, specific sources can be determined at this point.

As most of those attending expected, septic systems, agricultural practices, livestock and pets were cited as the areas the implementation plan will target. Wildlife, including Canada geese, were initially dismissed as a significant factor, but the residential/recreational workgroup did get a recommendation on record to involve DGIF or other agencies in exploring this aspect of the problem. It’s still unclear why agencies involved with wildlife are not participating in TMDL meetings from the beginning, if only to provide fact sheets and a point of future contact.

The Department of Environmental Quality (DEQ, along with the Departments of Conservation and Recreation (DCR) and Mines, Minerals and Energy (DMME), issued a TMDL Six Year Progress Report for 2000 – 2006, in March, 2007. In discussing the challenges faced in the Metro Richmond area, the report cited: “Wildlife (such as geese, ducks, beaver, & deer) likely contributes to the impairment.  Methodologies to address these sources may need to be explored and evaluated.” (If there are more recent reports about the results of such evaluations, they’ll be reported here as soon as they’re identified.)

Questions about possible discharges from boats caused heated exchanges, as did the question of the necessity to attempt to bring impaired waters up to the strict standards necessary for shellfish cultivation. For Virginia to continue interstate sales of shellfish, there is no option other than for the state to continue to monitor and report on all shellfish shoreline areas and to develop plans to attempt to clear up impaired waters.

The lack of a sound system and projected graphs and charts that were only visible from the front rows added to the charged atmosphere at times, but overall, the meeting was civil, and DEQ and DCR representatives and residents in attendance were able to express their points of view. There were questions left unanswered due to the time restraints, but by the next meeting, answers should be available on all of them.

This process leading to the creation of TMDL Implementation Plans is not going to be quick or easy. Some of the possible BMPs (Best Management Practices) presented at the meeting may be helpful. We’ll know better after these are reviewed and considered in depth.  I do believe the people involved on all sides are sincere and care about the results, and that the IPs will not just be cookie-cutter versions of other IPs. There is a lot of work to be done locally to achieve that result.

But just when I thought we had a sense of how this whole TMDL process works, we learned from a Southside Sentinel article that the Army Corps of Engineers has plans in progress for the Piankatank and other rivers in the Chesapeake Bay watershed in Maryland and Virginia involving oyster sanctuaries, a fairly significant detail not mentioned in the TMDL meeting, and not at all obvious on either the DEQ or DCR websites. I’ve looked at a lot of TMDL related documents the past few weeks, and the Army Corps of Engineers and oyster sanctuaries didn’t pop out anywhere. A quick look at the Norfolk District Army Corps of Engineers website found this image-link:

http://www.nao.usace.army.mil/News/20120329_PublicMeetingsOysterRestoration.asp
to a public meeting notice about “native oyster restoration plans for VA, MD” and that notice said in part, “The long-term goal is to restore an abundant, self-sustaining oyster population that performs important ecological functions such as providing reef community habitat, nutrient cycling, spatial connectivity, and water filtration, among others, and contributes to an oyster fishery.”
Sounds great, except for what I read in the Sentinel article and in a quick look at “The Master Plan.” Guess I have some homework to do this weekend.

Are Year-round Geese Part of the Water Contamination Problem?

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Sunset facing mouth of Queen’s Creek courtesy of Davie Cottrell©

Each impaired shellfish area has unique challenges, so this post is only about Queens Creek, which is listed in the 2007 Gwynn’s Island-Milford Haven watershed TMDL report. It states “septic systems should be a primary implementation focus because of health implications….” Like many official statements, it sounds good at first hearing, but if septic systems are failing near Queens Creek, why would the human contamination drop to 0% on any month’s reading, much less for 3 of 6 readings taken between October, 2005 to August, 2006? But Figure 4.6 B shows 74% for the average annual fecal coliform contributions from wildlife.

Residents on Queens Creek have seen the geese population go from staying half the year to settling in year-round. Does that have anything to do with the high wildlife contributions? Can’t tell from the reports because the details aren’t provided, only totals and percentages for ‘wildlife’.

Mouth of Queen’s Creek courtesy of Davie Cottrell©

Other questions are, “Do the geese increase the phosphorus load too? Are they causing any additional shoreline erosion by eating young shoots?”

 And we need to consider whether there are other conditions that  are making the situation worse? Where are the computer models for evaluating the impact of the lack of dredging? The waters in Queens Creek used to be navigable, but they’re not for many craft today. If the Creek is dredged, would more water flow in and out with each tide change the capacity to process the impact of wildlife contamination? How much has settled in the silt at the bottom of the shallower creek to be stirred up by storms? (And on a separate point, if dredged material is spread in the sun, can the natural UV  disinfect it so it would then be usable to nourish the marshes that are being eroded by wave action and storms?)

But as things stand, continual contamination means the waters have no possibility of recovery naturally, so what happens to the areas further downstream?

The report acknowledges that for some areas, “water quality modeling indicates after removal of all of the sources of bacteria (other than wildlife), the stream will not attain standards under all flow regimes at all times. However, neither the Commonwealth of Virginia, nor EPA is proposing the elimination of wildlife to allow for the attainment of water quality standards….The reduction of wildlife or changing a natural background condition is not the intended goal of a TMDL.”

What is their plan? Even if all the effluent, pet and livestock elements are reduced as far as humanly possible, according to the 2007 report, the bottom line is the state agencies don’t plan to do anything–except change the assigned use of the waters–probably permanently.

It’s relatively easy for TMDL plans to go after the obvious 8% human element, 9% livestock and 9% pet contamination the state tests indicate. It’s not going to be easy to deal with the rising population of geese, but information is available about how to address the problem. Now we have to see if our state agencies are going to go beyond the obvious and deal with the 74% of bacterial contamination attributable to wildlife. Wonder if we’ll find out on the 23rd.