To the editor:
The Virginia Department of Environmental Quality, the regulatory agency responsible for overseeing stream construction projects throughout the Commonwealth, no longer allows default calculations for phosphorus to be used in pollution reduction crediting.
Since late 2019, Virginia now requires all stream “restoration” projects to use sediment and phosphorus calculations based on actual soil samples collected instream locally. Phosphorus is highly concentrated in human and animal waste and fertilizers vs. phosphorus-poor stream bank soils and is probably the main nutrient of concern affecting water quality downstream.
For this and other reasons, it was recognized several years ago that natural channel design projects were not cost-effective nor were they providing the greatest pollution reduction benefits and required ecosystem improvements, or uplift. Therefore, effective July 1, 2021, the stream construction industry will be regionally phasing out this outmoded approach in favor of alternative methods for reducing pollutants.
What does all this say for transparency, integrity and accountability with the public one serves when Alexandria City staff is heard repeatedly selling their stream projects at the “now or never” price of $16,000 per pound of phosphorus removed? This steal of a deal, in fact, is based on the bogus, highly inflated figure of 1.05 lb. phosphorus per ton of sediment from soil samples collected in agricultural district streams near Harrisburg, Pennsylvania.
Stream bank soil samples expertly taken and analyzed show the actual cost per pound of phosphorus removed along the Taylor Run project footprint to be $77,000!
Virginia and Alexandria taxpayers have overfunded the three current City of Alexandria projects by many millions of dollars based largely on highly inflated calculations that bear no semblance to actual phosphorus levels.
City staff never once tried to adjust this flawed cost analysis for fairness and adherence to scientific integrity, despite knowing full well of the impending new crediting requirements and cost ineffectiveness of natural channel design. Nor did they disclose any of this information to the public at meetings and on project websites.
Such behavior is little different than a car dealer knowingly selling vehicles compromised with safety recalls yet not providing full disclosure to the buyer.
-Rod Simmons, Arlington