The mission of the Clean Chesapeake Coalition is to advocate, raise awareness and act to improve the poor water quality of the Chesapeake Bay in the most effective and fiscally responsible manner possible.
What We Advocate For
The Coalition is advocating that the following Bay restoration activities, in the order listed, would result in the most meaningful and lasting improvement to the water quality of the Bay in the most cost effective manner:
(*with “cost-effective” defined as the cost of the practice per volume of nutrients and/or sediments prevented from polluting the Bay and its tributaries)
1. Address long-term sediment accumulation behind the Conowingo Dam and other northern dams on the Susquehanna River to restore trapping capacity.
Sediments have accumulated behind the Conowingo Dam and other lower Susquehanna River dams over many decades, reducing their ability to retain material during high-flow events. Dredging or other sediment-management strategies should be evaluated and implemented, as appropriate, to help restore trapping capacity and reduce the downstream impacts associated with sediment scouring and the transport of fine clays and silts during storm events.
The Chesapeake Bay system is increasingly deprived of coarse sediments while receiving elevated loads of nutrient-laden clays and silts. Reservoirs behind the dams preferentially retain heavier sand, while finer sediments are more readily transported downstream into the Bay. During extreme flow conditions, scouring of accumulated reservoir sediments further contributes to increased sediment and nutrient loads passing through or over the dams.
As a result, the physical and chemical characteristics of water entering these reservoirs differ from those of water released downstream. Available evidence indicates that reservoirs behind the lower Susquehanna River dams no longer provide meaningful long-term sediment trapping capacity. In light of these conditions, EPA should reevaluate and recalibrate the Chesapeake Bay Total Maximum Daily Load (TMDL) to account for the diminished trapping assumptions reflected in Appendix T of the 2010 TMDL.
2. Implement agricultural BMPs (Best Management Practices) that are recommended and proven by farmers to reduce runoff.
Agriculture is a significant source of nutrient and sediment loading to the Chesapeake Bay. Research conducted since adoption of the Bay TMDL has raised questions about the effectiveness of certain agricultural BMPs previously promoted in all contexts, including practices such as no-till farming, nutrient management plans (NMPs) based solely on nitrogen, and NMPs applied to fields with subsurface drain tiles.
To achieve more meaningful outcomes, agricultural policy should encourage innovation and adaptive management rather than uniform application of prescriptive measures. Providing farmers with greater flexibility—where environmental risks are low—can support the development and implementation of practices that address site-specific conditions and underlying causes of runoff. This includes permitting, incentivizing, and rigorously evaluating farmer-recommended approaches through verification testing and performance monitoring.
Experience indicates that agricultural BMPs are most effective when tailored to local conditions. A flexible, evidence-driven framework that builds on proven, field-tested practices is more likely to achieve durable water-quality improvements than a one-size-fits-all regulatory approach.
3. Focus on Bay-wide oyster and SAV restoration, including the strategic use of power dredging where appropriate.
Power dredging can play an important role in restoring buried shell beds by exposing and cleaning shell material, thereby creating hard, suitable substrate conditions that support spat attachment and oyster recruitment.
We support the allocation of funding to assist watermen in reintroducing spat to power-dredged beds. We also encourage further research to assess whether the reintroduction of sand is necessary to provide suitable substrate conditions for submerged aquatic vegetation (SAV), particularly in areas where several feet of clay and silt have accumulated on the Bay floor.
While discussion often highlights the recovery of SAV in the Susquehanna Flats, available studies indicate that SAV conditions remain significantly degraded in areas extending from north of Tolchester to below the Choptank River. In these regions, fine sediments are repeatedly resuspended, increasing turbidity, limiting light penetration, and inhibiting SAV growth. Much of the sand transported into the Bay is deposited in the Susquehanna Flats, while finer silts and clays remain suspended longer and settle farther downstream, contributing to sediment accumulation in these more heavily impacted areas.
4. Challenge lack of enforcement towards Bay pollution sources given that some of the largest point-sources of pollution have knowingly failed to stay below pollution limits for years.
While policies, taxes, programs, private and public funding lead to billions of dollars spent on improving the water quality of the Bay, the largest point-sources of pollution have been allowed to continue to operate without change for decades despite clear and repetitive pollution-limit violations. For example, Baltimore City’s sewage treatment and collection system is one of the largest and most concentrated sources of pollution loading to the Bay (2nd to Conowingo) and has been under a consent order since 2002 to upgrade their system. Not only has their system failed to upgrade adequately despite numerous environmental reports and media attention, but since then, the wastewater treatment plant has failed to report millions of gallons of raw sewage mixed with stormwater that has ended up in the Bay, and surpassed loads up to four times the permit limits numerous times over the years.
While it is important that all sources of pollution to the Bay be addressed, money invested into a myriad of policies as well as addressing smaller, downstream sources is wasteful spending and seems nonsensical when there has been a blatant lack of enforcement amongst the largest sources of pollution which have failed to stay below their permit limits.
5. Support targeted wastewater and septic-system improvements consistent with local planning and site conditions. Where financially feasible and aligned with local comprehensive plans, public sewer extensions should be considered to address failing septic systems. In coastal plain areas with shallow groundwater tables (less than 10 feet), the use of switchgrass in drain fields should be allowed and encouraged as a nutrient-uptake and system-performance enhancement.
Existing septic systems with drain fields at depths of 10 to 15 feet may, in some cases, be rehabilitated at a cost comparable to installing a new system under currently approved best management practices (BMPs). In addition, operation and maintenance costs may be more manageable where switchgrass-based systems are employed.
Finally, a reassessment of tier-mapping policies is warranted given their disproportionate impacts on rural counties. Available evidence does not clearly demonstrate that the regulation of septic systems, as implemented under SB 236 (2012 General Assembly Session), results in measurable improvements to Chesapeake Bay water quality, suggesting the need for further review of its effectiveness and scientific basis.
6. Prioritize cost-effective stormwater and tributary restoration strategies.
Rather than relying exclusively on costly stormwater retrofits and structural best management practices (BMPs), jurisdictions should be afforded flexibility to meet water-quality goals through less expensive and demonstrably cost-effective approaches, including tributary restoration projects. In many tributaries, fallen trees and accumulated debris contribute to increased erosion and sediment transport during storm events as flows intensify, independent of changes in impervious surface coverage.
In tidal systems, flow obstructions can also inhibit the natural movement of debris, sediments, and nutrient-laden waters into wetlands that would otherwise provide restorative functions through regular tidal exchange. Addressing these physical impediments can yield meaningful water-quality and habitat benefits at relatively low cost.
Concerns have also been raised that requirements imposed through Municipal Separate Storm Sewer System (MS4) permits mirror approaches previously advanced through National Pollutant Discharge Elimination System (NPDES) permits, without sufficient demonstration of effectiveness relative to their cost. Significant public resources may be directed toward stormwater retrofits whose performance remains uncertain, while lower-cost, practical restoration measures receive limited funding.
To avoid placing disproportionate fiscal burdens on local governments and taxpayers, stormwater and restoration funding should not rely primarily on local tax increases. Instead, funding mechanisms based on uniform, statewide revenue sources—such as the Bay Restoration Fund (“flush tax”)—would help ensure a more equitable per-capita distribution of costs while supporting effective restoration outcomes.
See relevant articles here and here
Public attention and resources should be allocated in accordance with the priorities outlined above.
These programs and expenditures are ordered to ensure that limited public and private resources dedicated to improving Chesapeake Bay water quality are directed first toward initiatives most likely to deliver meaningful, durable, and cost-effective outcomes.
FERC RELICENSING OF THE CONOWINGO DAM
Such an opportunity is provided by the Federal Energy Regulatory Commission’s (FERC) re-licensing of the Conowingo Hydroelectric Dam, which presents the most significant opportunity to save the Bay in a generation. While FERC controversially re-licensed the Conowingo Dam in 2021 with little public notice, there are ongoing elements that must be addressed to ensure that what we do and what we spend below the Dam is not wasted.
Attention must now be focused on the Conowingo WIP to ensure that plan includes action to meaningfully address the Conowingo factor by way of sediment management and dredging what is already accumulated in the reservoir in order to regain trapping capacity.
The Coalition is clamoring for the State’s recognition of the fiscal issues we’ve raised and encouraging State agencies to get serious about the impacts of FERC’s re-licensing. In that process they will be able to exercise the important tools available under federal and State law to fight for environmental protection, fish and wildlife protection, and meaningful action with respect to the 84 years of sediments accumulated above the Dam.
Sediments flushed into the Bay from the Susquehanna River and scoured from the Conowingo Dam reservoir are harmful the Bay’s health. They are also detrimental to the state’s fiscal health; hundreds of millions of tax dollars are required to maintenance dredge sediments from the Port of Baltimore, the shipping channels leading to the harbor, marinas and public access facilities. Coalition members feel that there is no logic in spending millions of dollars to remove minute amounts of nutrient or sediment loading, while very little is spent to address the largest source of loading
The Coalition’s Overall Objective
The overall objective of the Clean Chesapeake Coalition is to pursue improvement to the water quality of the Chesapeake Bay in the most prudent and fiscally responsible manner. We believe that this collective purpose is consistent with the responsibilities of Maryland citizens and reflective of the feelings of most local elected officials.
Our research, analysis and advocacy thus far is of great use and benefit to everyone concerned with a healthy Bay. There is no doubt that we have raised attention in the flaws of the Bay clean-up agenda and the disproportionate fiscal impacts on Maryland local governments (read taxpayers).
There is sufficient momentum now it seems for Marylanders to embrace the cause; support the Coalition and know that your tax dollars will be spent wisely.
