Comment submitted by David W. Heicher, Susquehanna River Basin Commission

10. Pages 40- 41, item C – Establish a Chesapeake Monitoring and Observing System: The second bullet indicates a need to establish stronger partnerships with ongoing federal and state monitoring programs, but makes no mention of monitoring performed by the Commission in cooperation with its member jurisdictions (New York, Pennsylvania, Maryland, and the federal government). The Commission’s interstate stream monitoring, subbasin surveys, and large river assessments provide chemical, physical, and biological data on the quality of water bodies in the Susquehanna River Basin, which provides 50 percent of the freshwater inflow to the Chesapeake Bay. All of these programs have quality assurance project plans that are approved by EPA. The data are entered into EPA’s Water Quality Exchange network and provided in the integrated report the Commission provides to EPA under Section 305(b) of the Clean Water Act.
11. Page 47, fourth bullet under “Actions Agencies will Initiate Before May 2010: We agree that measuring the amount of nitrogen, phosphorus, and sediment at sites in the watershed is needed to support state implementation plans and document progress toward meeting loading targets for the Chesapeake Bay TMDL. Additional monitoring is needed in areas targeted for focused implementation of BMPs.
continued in additional submittals