Bacteria Levels in Shenandoah Valley Remain High, Despite Revised Pollution Standards

72 Percent of Sampling Locations in Valley Had E Coli Bacteria Above EPA Safe Swimming Recommendations in 2020

Washington, D.C. – Almost three quarters of water quality monitoring sites in Virginia’s scenic Shenandoah Valley had levels of fecal bacteria last year that were so high that EPA would consider them unsafe for swimming.

According to water quality monitoring data from the Virginia Department of Environmental Quality, 72 percent (or 18 of 25) of monitoring sites along the Shenandoah Valley and its tributaries had levels of E. coli bacteria last year above EPA’s recommendations for swimming.

However, Virginia posted no signs warning rafters, kayakers, or swimmers about health threats – as it does regularly with swimming advisories on ocean beaches and in saltwater areas. The Commonwealth also eliminated the state’s swimming advisory standard for freshwater recreation areas in October 2019 and changed its standard for “impaired” waters.

The number of waterway sites sampled for bacteria by Virginia is also declining, with an average of 70 places on waterways in the Shenandoah Valley sampled between 2015 and 2018, but only 35 in 2019 and 25 in 2020.

“Virginia should strengthen its bacteria standards and post swimming advisory signs in freshwater areas used by rafters and swimmers that are contaminated with fecal bacteria, especially now that rafting and tubing season is starting up on the Shenandoah River,” said Eric Schaeffer, Executive Director of the Environmental Integrity Project. “People might be upset by warning signs, but the signs would increase public pressure on state lawmakers to invest the funds and effort needed to reduce pollution – for example, by requiring farmers to fence their herds of cattle out of the Shenandoah River,” said Schaeffer, former Director of Civil Enforcement at EPA.

Mark Frondorf, the Shenandoah Riverkeeper, said: “The river and its users cannot afford the sleight-of-hand technique employed by authorities on water quality standards. The solution is not to lower the standards so that the public is misled into thinking the river is safe for contact, but rather to enhance the standards — and then act to resolve the impairment.”



Number of Sites Sampled

Number of Sites Where Bacteria Exceeded EPA’s Swimming Advisory Value

Percent of Sites Over EPA Swimming Advisory Value

Annual Rainfall (inches)































Water sampling data from the Virginia Department of Environmental Quality, for sites that were sampled at least twice in the last six years.  Sampling locations often change from year to year.  The threshold used in this graph is EPA’s recommended “beach action value” for swimming, which recommends states to notify the public when bacteria levels exceed 235 counts of E. coli bacteria/100 ml water. Virginia eliminated its state freshwater “beach action value” in October 2019 and changed its “impairment” value.

Agricultural runoff, including manure from the Valley’s many livestock operations and industrial scale poultry operations, is a source of contamination for 71 percent of the polluted river and stream miles in the Shenandoah Valley, according to state figures.

The Environmental Integrity Project and Shenandoah Riverkeeper released a report in 2019 that used aerial photography to document that only about 20 percent of livestock farms in Virginia’s biggest agricultural counties, Rockingham and Augusta counties in the Shenandoah Valley, had fenced their cattle out of streams and rivers.

Partly in response to that report and its own follow up study, Virginia boosted its reimbursement rates for farmers who install fencing, leading to increased sign-ups for the fencing reimbursement program last year. But many farms still lack livestock fencing.

For decades, Virginia has collected bacteria data in both fresh and saltwater areas of the state, but has only posted warning signs for swimmers on ocean and saltwater beaches. It has never issued public health advisories or posted signs in freshwater areas like the Shenandoah River, even though rafting and swimming are common in the scenic waterway.

In October 2019, Virginia revoked its “beach action value” for E. coli in freshwater areas, a trigger value that EPA recommends for issuing short-term no swimming advisories in waterways that have more than 235 counts of E. coli/100 ml of water.  Other states, including Maryland and Pennsylvania, still use this freshwater “beach action value.”

Margaret Smigo, Waterborne Hazards Program Coordinator for the Virginia Department of Health (VDH), said that her agency does not have funding or staff to conduct adequate testing in freshwater swimming areas of the state, like campgrounds along the Shenandoah River. By contrast, she said, EPA provides grants for state water quality testing along ocean beaches and in saltwater areas, like Virginia Beach, and to the state provides regular testing and raises swimming advisory signs in these saltwater areas.

Back in 2018, Smigo said her agency asked the Virginia General Assembly for about $200,000 in additional state funding to start a freshwater swimming area safety program, including by conducting more sampling and raising bacteria warning signs for swimmers on waterways that are impaired for bacteria.  But she said the state General Assembly rejected those requests for additional funding and an expanded freshwater testing program.

“In the absence of a mechanism for conducting frequent seasonal bacteria monitoring at freshwater beaches, VDH lacks the data necessary to make advisory decisions for these waters,” Smigo wrote in an email. “Due to the interest and concerns expressed by public and nonprofit groups for improving the information available on inland beach water quality, VDH has made several attempts to secure funding as recently as 2018, for the 2019-2020 state fiscal budget year.  Unfortunately, to date, such efforts have not been successful.”

Greg Bilyeu, Director of Communications Virginia Department of Environmental Quality (VDEQ), said his agency is planning to increase the frequency of its bacteria monitoring in certain, select areas where people actually swim, and will release an updated bacteria monitoring strategy this fall.   He said that the agency is trying to sample fewer sites, but targeted in areas where people actually get wet during recreation.

“The agency had to pause a high-frequency bacteria pilot study (and all other monitoring) in spring and early summer 2020 because of the COVID-19 pandemic,” Bilyeu wrote in an email. “VDEQ intends to complete the bacteria pilot study in 2021 and will share the results with the public.”

VDEQ in October 2019 also modified the standard that the state uses to determine if waterways are “impaired” for recreation, a determination that triggers requirements for long-term clean-up plans under the federal Clean Water Act. The new standard tolerates higher concentrations of E. coli bacteria (410 counts of E coli bacteria per 100 ml of water, instead of 235 counts under the old standard) and requires more frequent testing to designate a waterway as “impaired.”

VDEQ said they changed their standards in 2019 to follow updated recommended bacteria criteria published by EPA in 2012. But those 2012 EPA criteria recommended that states continue using a trigger value for issuing short-term advisories to swimmers in freshwater areas – called the “beach action value” – of 235 counts of E. coli/100 ml water.  Virginia did not follow that recommendation, and instead eliminated its state freshwater “beach action value.”

Frondorf, the Shenandoah Riverkeeper, said it is not fair that the state has a swimming advisory standard and monitoring program for Ocean beaches, like in Virginia Beach, but not in freshwater areas like the Shenandoah River. The Shenandoah Riverkeeper Swim Guide lists over 70 access points on the three major reaches of the Shenandoah River.

“It’s almost a five-hour drive for people living in the Shenandoah Valley to drive to a Virginia beach and they should not be treated like second-class citizens due to their lack of proximity to a saltwater beach,” said Frondorf.  “For many folks, the Shenandoah River is their only option to swim in the summer months.”

For more data and information on bacteria testing in the Shenandoah Valley, visit EIP’s web page on water quality in the Valley.

Additional bacteria sampling data is available from Friends of the Shenandoah River.

The Environmental Integrity Project is a 19-year-old nonprofit organization, based in Washington, D.C., and Austin, Texas, dedicated to enforcing environmental laws and strengthening policy to protect public health and the environment.

Media contacts: Tom Pelton, Environmental Integrity Project (443) 510-2574 or

Mark Frondorf, Shenandoah Riverkeeper, or (571) 969-0746