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Aug 12

Comments Sought on the Draft Chesapeake Bay TMDL Action Plan

Posted on August 12, 2015 at 1:51 PM by OCOM Specialist

The public is invited to submit comments about the City’s draft Chesapeake Bay TMDL Action Plan by September 18; email Read more about the plan below.

What is TMDL?
Over the last few years the U.S. Environmental Protection Agency (EPA) has rolled out a new plan to clean up the Chesapeake Bay by 2028. The plan requires localities, like the City of Falls Church, to remove specific pollutants from stormwater runoff before the water enters local streams and rivers that drain into the Chesapeake Bay. The level of pollutants allowable to be discharged to the Chesapeake Bay is called a Total Maximum Daily Load (TMDL).

The Draft Plan
As part of the City’s new stormwater permit obligations, in 2015, the Department of Public Works had to develop a Chesapeake Bay TMDL Action Plan that shows how the City intends to meet the first of three milestones; a 5% reduction in nitrogen, phosphorus, suspended solids by June 30, 2018.  All of the reductions in excess of 5% can be applied to the second and third milestones of 40% by 2023 and, 100% by 2028.  A summary of the plan is provided below.

Draft Plan: Overview

  • The City must develop a Chesapeake Bay TMDL Action Plan (plan) as a component of its municipal separate storm sewer system (MS4) permit. 
  • The final plan is due to the Virginia Department of Environmental Quality (DEQ) by October 1, 2015.
  • The plan must demonstrate how the City will reduce three pollutants that are impairing the Chesapeake Bay – phosphorus, nitrogen, and sediment. 
  • The City has three five-year MS4 permit cycles to complete reductions: 5% by the end of the first cycle (June 30, 2018); a total of 40% of by the end of the second cycle (2023); and, 100% by the end of the third cycle (2028).
  • This initial plan calculates the 5% reduction and demonstrates how the City will meet those reductions.
  • Any reductions achieved above 5% will be applied to future permit cycles.
  • The City is only responsible for reductions from its regulated MS4 – which are those areas of the City that flow to a regulated stormwater outfall. 
  • With the exception of areas adjacent to two natural stream valleys (Four Mile Run and Tripps Run), the vast majority of the City’s land area is in the regulated MS4.

Draft Plan: Preventing Increases in Pollutants

  • The City must first ensure that all new development does not increase pollutants.  This is achieved by the City’s Stormwater Management Ordinance (Chapter 35, Article I “Stormwater Management” City of Falls Church Code).

Draft Plan: Achieving Pollutant Reductions

  • The 5% reduction requirement is exceeded by taking credit for past redevelopment that has occurred since July 1, 2009 and by taking credit for City-initiated projects. 
  • Redevelopment is provided credit because the City’s previous Stormwater Management Ordinance typically required a reduction from existing pollutant loadings.  Twelve redevelopment projects to-date qualify for credit.
  • City-initiated projects include the City Hall Campus and Jessie Thackery School retrofits, and the Coe Branch and Pearson Branch stream restoration projects (all completed in 2015).  

Draft Plan: Future and Potential Reductions
The City may also take credit for the following additional projects/practices and apply the credit to the next permit cycle. Credits must be documented and submitted in the City’s annual reports to DEQ.

  • Any additional redevelopment that results in a decrease in pollutants.
  • Any additional City-initiated projects.
  • Street sweeping. DEQ provides guidance on credit for street sweeping, however, while the credit could be substantial, the rules are in flux. 
  • The City’s Stormwater Management Ordinance is more stringent than state minimum standards for individual single family homes. As a result, the City may take credit for reductions beyond minimum standards.
  • Nutrient credit trading. The City owns a share of the efficiency of the Arlington Wastewater Treatment Plant and may apply that credit. The City may also purchase credit through a state-run nutrient exchange.
  • Additional credits allowed by DEQ include homeowner best management practices such as rainwater harvesting, downspout disconnection, permeable hard-scapes, tree planting, and impervious cover removal. 
Public Comment
The City’s Chesapeake Bay TMDL Action Plan is currently in draft format is available for review on the City’s website or by request to the Department of Public Works. For any questions or to submit comments, contact Jason Widstrom, P.E. at 703-248-5026 (TTY 711) or All comments must be received by close of business Friday, September 18, 2015 for inclusion into the plan before official submittal to Virginia Department of Environmental Quality.