On Monday, the Commonwealth of Virginia submitted a revised Watershed Implementation Plan (WIP) to the EPA, meeting EPA’s established deadline. However, in the revised draft, Secretary of Natural Resources Doug Domenech, on behalf of Governor McDonnell, cautioned that the submission was being provided only an “initial submission” due to unforeseen and late-breaking modeling results that required additional reductions the plan’s Watewater Treatment load allocations. Secretary Domenech advised that the state would continue to work to modify the plan over the next 7 to 10 days. So while a “final” plan has been submitted, we still do not have a final, “final plan.”

However, even when a really and truly final plan is submitted, it will remain to be seen whether the state’s WIP will be enough to satisfy EPA such that it removes the threatened “backstops” that the agency stated might be imposed if the state did not do more to reduce pollution in the Chesapeake Bay.