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.
Our coalition seeks to re-establish Maryland’s waters and its oyster, crab, fishing, and seafood packaging industries that were once so vital to our local economies.
What We Advocate
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. Dredge or otherwise address the 84 years of sediments
accumulated above the Conowingo Dam and other northern dams in the Susquehanna River in order to regain trapping capacity, so as to reduce the devastating impact of rapid sediment overload from scour and the pass through of clays and silts.
The Bay is sand-deprived and overloaded with nutrient laden clays and silts. The dams trap the heavier sand while allowing the lighter clays and silts to wash into the Bay. Scour from the floor of the reservoirs behind the dams adds sediments and nutrients to the water that flows through (or over) the dams during storm events.
Therefore, the character and quality of the water flowing into the reservoirs behind the dams are different than the character and quality of the water passing through the dams. The reservoirs behind the dams in the lower Susquehanna River have no remaining long-term trapping capacity. The EPA must recalibrate the Bay TMDL by adjusting for the flawed assumption of trapping as outlined 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 one of the largest sources of nutrient and sediment loading into the Bay. Scientific research conducted subsequent to the introduction of the TMDL has called into question the effectiveness of a number of agricultural BMPs promulgated in the past (e.g., no-till farming, Nutrient Management Plans (NMPs) based solely on nitrogen, NMPs on fields underlain with drain tiles, etc.). Regulators will not engage in the innovative thinking and risk-taking necessary to find solutions to root problems, leading to billions spent on de minims reductions at point sources. We advocate for farmers to have greater flexibility where doing so is likely to have minimal adverse consequences and permit, encourage, financially support and undertake verification testing of home grown solutions recommended by farmers. Propitiate what works. One size does not fit all and neither do the BMPs created by regulators.
3. Focus on oyster and SAV restoration Bay-wide, including power dredging throughout the Chesapeake Bay.
Power dredging is the only way to uncover buried shell beds and to agitate and clean the shells in order for spat to have a hard, clean surface on which they can adhere.
We wish to see a provision of funds towards watermen to introduce spat back into the power dredged beds. We advocate for research on whether sand has to be reintroduced to provide a soil that will hold the roots of SAV securely in areas where several feet of clay and silt sediments now cover the floor of the Bay. While discussion focuses on how well SAV has recovered in the Susquehanna Flats, studies show that from north of Tolchester to below the Choptank River, SAV is devastated by smothering sediments that are repeatedly agitated, clouding the water and deterring light. All the sand in the sediments flushing into the Bay is released in the Susquehanna Flats. The silts and clays remain suspended, not beginning to settle to the bottom until the devastated areas from north of Tolchester down to south of the Choptank.
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. Install public sewer extensions to connect failing septic’s, where financially feasible and consistent with local plans. Allow and encourage switch grass use in drain fields in the coastal plain geology where the water table is less than 10′ deep. Existing 10′ – 15′ septic systems could be restored for the cost of one new one under currently approved BMPs and operation/maintenance will be more affordable where switch grass is used. Reconsideration of tier mapping due to its adverse impacts on rural counties – there is no peer-reviewed science which supports the regulation of septics (by way of SB 236 in the 2012 Session of the General Assembly) as a means to measurably improve the water quality of the Bay.
6. Instead of requiring expensive stormwater retrofits and BMPs, allow goals to be met with less expensive, more cost-effective projects such as those that promote tributary restoration. Fallen trees and accumulated debris in tributaries have lead to greater erosion and sedimentation during storm events when flows increase, regardless of the increase or decrease in impervious surfaces. In tidal areas, flow impediments prevent debris and sediment and nutrient laden water in the Bay from washing into restorative wetlands as the tide rises and falls. MDE is seeking to do through Municipal Sewer Systems (MS4) permits that which it did (ENR) through National Pollutant Discharge Elimination System (NPDES) permits. Billions will be spent on unproven, ineffective stormwater retrofits while low-cost, common sense, bang-for-the-buck solutions go unfunded. Do not require local governments to increase taxes in order to fund stormwater retrofits. Funding should come through uniform state taxes such as the flush tax, keeping the per capita impact uniform.
For there to be real and lasting improvement to the water quality of the Bay, the highest priority of enforcement must be towards the largest point-sources of pollution.
Public attention and resources should be prioritized according to the list above.
The programs and expenses are prioritized so the limited public (and private) resources available to improve the water quality of the Bay are first expended on programs that will achieve the most significant and lasting results.
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.