Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Protected area / relocation · United States · 2010–2026

Chesapeake Bay Program: the 2010 TMDL, the 2025 goals and results

Nature's voice · report
Over; the Congressional Research Service's own estimate from the Office of Management and Budget's annual crosscut reports; federal agencies only 5.7 billion US dollars were budgeted in my name. What was measured is below what was promised.
Did nature suffer? Not measured. Accounts differ ↓
Not on record
  • The record does not name which of my species, waters, soils or forests were harmed.
What the record lacks: 1 insufficient · 2 not measured · 3 disputed · 2 unclear See the gaps
Accounts of the harm differ
Whether the 2025 goals are on course
  • Government and regulators US Environmental Protection Agency (2026): The partnership met its watershed-wide interim target for sediment but did not meet its targets for nitrogen or phosphorus. US Environmental Protection Agency
  • Government and regulators EPA Office of Inspector General (2023): The Program is not on track to have all controls and practices in place by 2025; EPA has not led partners to new goals or deadlines. EPA Office of Inspector General
  • Communities and civil society Jon Mueller, former Chesapeake Bay Foundation vice president for litigation (2024): Pennsylvania is "dramatically off course" on its TMDL targets. Inside Climate News
  • Government and regulators Anna Killius, Chesapeake Bay Commission (2024): Described the effort as "course correction" rather than failure (as reported by Inside Climate News). Inside Climate News
Modelled versus real-world data
  • Government and regulators US Environmental Protection Agency (2026): Progress is estimated with Phase 6 modelling tools from jurisdiction-reported practices; "Discrepancies between modeled and real-world data" create communication challenges and distrust. US Environmental Protection Agency

EPA established the Chesapeake Bay pollution limit (TMDL) on 29 December 2010, with controls to be in place by 2025. EPA's 2025 assessment (13 August 2026) reports that nitrogen loads fell 14.96 percent, meeting 57 percent of the interim target, phosphorus 21.4 percent (90 percent) and sediment 7 percent (100 percent); EPA's Inspector General found in 2023 that the programme was not on track.

57 percent estimateShare of the 2025 interim nitrogen target met, 2009 to 2025
EPA 2025 Assessment, 13 August 2026: nitrogen loads reduced 14.96 percent from 297.1 million to 252.7 million pounds. Phosphorus 90 percent of its interim target and sediment 100 percent. Load figures are modelled estimates reported by the partnership.

Status As of 13 August 2026: EPA reports the sediment interim target met and the nitrogen and phosphorus targets not met; the partnership has committed to set new targets and plans by 2030.

What?
A regional restoration partnership working to a pollution limit for nitrogen, phosphorus and sediment (the Bay TMDL) set by EPA in 2010, with controls to be in place by 2025. US Environmental Protection Agency
Where?
The Chesapeake Bay and its watershed across seven jurisdictions. EPA Office of Inspector General
When?
TMDL established 29 December 2010; midpoint assessment 2017; goals due 2025; EPA assessment 13 August 2026; new targets by 2030. US Environmental Protection Agency
Who?
Gained
None on record
Lost
None on record
Harmed
None on record
Why?
To restore water quality in the Bay and its tidal rivers by reducing nitrogen, phosphorus and sediment loads. US Environmental Protection Agency
How?
Jurisdictions implement Watershed Implementation Plans and report practices; EPA oversees through an accountability framework and estimates progress with modelling tools. US Environmental Protection Agency
5 of 6 questions answered from the record · open: who

What happened

The record, in order.

The Chesapeake Bay Total Maximum Daily Load (TMDL) was established by the US Environmental Protection Agency (EPA) on 29 December 2010. EPA describes it as "a historic and comprehensive "pollution diet" to restore clean water in the Chesapeake Bay", with pollution control measures to be "in place by 2025" and practices in place by 2017 to meet "60 percent of the necessary pollution reductions". Seven jurisdictions (Delaware, the District of Columbia, Maryland, New York, Pennsylvania, Virginia and West Virginia) committed to implement it in three phases of Watershed Implementation Plans (2010, 2012 and 2019), with a midpoint assessment in 2017.

EPA's 2025 Assessment (dated 13 August 2026) wrote: "Across the watershed, between 2009 and 2025, nitrogen loads were reduced 14.96 percent from 297.1 million pounds to 252.7, meeting 57 percent of the interim nitrogen target. Phosphorus loads were reduced 21.4 percent, from 16.8 million pounds to 12.8 million pounds, meeting 90 percent of the phosphorus interim target. Sediment loads were reduced by 7 percent, from 18,830 million lbs to 17,555 million lbs, achieving 100 percent of the interim target." It wrote that the partnership "met its watershed-wide interim target for sediment but did not meet its watershed-wide interim targets for nitrogen or phosphorus". The assessment used the partnership's Phase 6 modelling tools on practices reported by jurisdictions. It listed challenges including growth in loads from population and development, agricultural intensification, the loss of Conowingo Dam trapping capacity, lag time between practices and water-quality improvement, and "Discrepancies between modeled and real-world data". The revised 2025 Watershed Agreement commits the partnership to new water quality targets and plans by 2030. In an earlier release (2 May 2024) the Chesapeake Bay Program wrote that model estimates showed nitrogen entering the Bay down 17% from 297.8 million pounds in 2009 to 247.6 million pounds in 2023.

EPA's Office of Inspector General (report 23-E-0023, 18 July 2023) found that "The Chesapeake Bay Program is not on track to have all controls and practices in place by 2025 to meet its Total Maximum Daily Load", that limits on EPA's Clean Water Act authority prevent federal actions from fully achieving the goals, and that EPA had not led partners to adopt new goals or deadlines. EPA did not concur with recommendations 1 (a new approach to nonpoint source pollution) and 3 (an assurance mechanism for jurisdictions), which the Inspector General recorded as unresolved, and concurred with recommendation 2 (new jurisdictional goals and a new deadline), with an estimated completion date of 15 January 2026. Inside Climate News reported in June 2024 that, except for West Virginia, every contributing state was failing to meet its TMDL obligations, and quoted an EPA spokesperson: "EPA has a dual role with respect to the Bay—as a partner as well as a regulator."

On money, GAO recorded in 2005 that the Bay Program received about US$3.7 billion in direct funding from 11 federal agencies, Maryland, Pennsylvania, Virginia and the District of Columbia in fiscal years 1995 to 2004, plus about US$1.9 billion in indirect funding, and found that the reporting process's lack of independence sometimes led to a more favorable picture of bay health than the data supported. The Office of Management and Budget's October 2024 spending crosscut gave federal agency totals (operating level) of US$549,131 thousand in FY 2022, US$523,808 thousand in FY 2023 and US$591,050 thousand in FY 2024, and wrote that the funding numbers are in many instances extrapolated or estimated and that there may be double-counting between state and federal tables. EPA's assessment recorded that Virginia allocated US$223 million in agricultural cost-share funding for FY 2026.

  1. 2005GAO-06-96 records about US$3.7 billion in direct funding for FY 1995-2004 and finds the Program lacks an integrated way to assess progress (28 October)
  2. 2010EPA establishes the Chesapeake Bay TMDL (29 December)
  3. 2017Midpoint assessment; 60 percent of necessary pollution reductions due by 2017
  4. 2023EPA Inspector General finds the Program not on track for 2025 (18 July); model estimates show nitrogen entering the Bay down 17% from 2009 to 2023 (Bay Program, 2 May 2024)
  5. 2024OMB spending crosscut reports FY 2024 federal operating level of US$591,050 thousand (October)
  6. 2025Revised Chesapeake Bay Watershed Agreement commits the partnership to new water quality targets by 2030; deadline for all practices to be in place
  7. 2026EPA's 2025 Assessment: nitrogen target 57 percent met, phosphorus 90 percent, sediment 100 percent (13 August)

What was said

Claims, in the words of those who made them.

“a historic and comprehensive "pollution diet" to restore clean water in the Chesapeake Bay”

“The Chesapeake Bay Program is not on track to have all controls and practices in place by 2025 to meet its Total Maximum Daily Load”

“the public cannot easily determine whether the health of the bay is improving or not”

“EPA has a dual role with respect to the Bay—as a partner as well as a regulator”

“dramatically off course”

Jon Mueller, former Chesapeake Bay Foundation vice president for litigation, on Pennsylvania · 26 June 2024 · Inside Climate News

“the basic implementation and enforcement of the Clean Water Act”

Evan Isaacson, Chesapeake Legal Alliance, on the missing piece · 26 June 2024 · Inside Climate News

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Whether the 2025 goals are on course
Government and regulators
US Environmental Protection Agency (2026)

The partnership met its watershed-wide interim target for sediment but did not meet its targets for nitrogen or phosphorus.

US Environmental Protection Agency
Government and regulators
EPA Office of Inspector General (2023)

The Program is not on track to have all controls and practices in place by 2025; EPA has not led partners to new goals or deadlines.

EPA Office of Inspector General
Communities and civil society
Jon Mueller, former Chesapeake Bay Foundation vice president for litigation (2024)

Pennsylvania is "dramatically off course" on its TMDL targets.

Inside Climate News
Government and regulators
Anna Killius, Chesapeake Bay Commission (2024)

Described the effort as "course correction" rather than failure (as reported by Inside Climate News).

Inside Climate News
Modelled versus real-world data
Government and regulators
US Environmental Protection Agency (2026)

Progress is estimated with Phase 6 modelling tools from jurisdiction-reported practices; "Discrepancies between modeled and real-world data" create communication challenges and distrust.

US Environmental Protection Agency

How it looked

What was shown, beside what was recorded.

Shown

  • The TMDL described as "a historic and comprehensive "pollution diet" to restore clean water in the Chesapeake Bay", with controls in place by 2025.
    US Environmental Protection Agency · US Environmental Protection Agency
  • The partnership described as having "made considerable progress" with "historic levels of funding dedicated to restoration", while interim nitrogen and phosphorus targets were not met.
    US Environmental Protection Agency, 2025 Assessment · US Environmental Protection Agency
  • Model estimates presented as showing nitrogen entering the Bay down 17% from 2009 to 2023.
    Chesapeake Bay Program · Chesapeake Bay Program

Recorded

  • 2009 to 2025: nitrogen loads down 14.96 percent (297.1 to 252.7 million pounds), 57 percent of the interim target; phosphorus down 21.4 percent (16.8 to 12.8 million pounds), 90 percent; sediment down 7 percent (18,830 to 17,555 million pounds), 100 percent (EPA, modelled).
  • EPA Inspector General (2023): the Program is not on track to have all controls and practices in place by 2025; EPA did not concur with recommendations 1 and 3.
  • GAO (2005): about US$3.7 billion in direct and about US$1.9 billion in indirect funding in FY 1995-2004; six recommendations to EPA, all listed as closed and implemented.
  • UMCES report card page: Chesapeake Bay health C+ and watershed health C+ in 2025.
  • No source reviewed gives monitored (rather than modelled) water-quality results for the whole Bay against the 2025 goals.

In nature's name

What was promised in nature's name, the money that moved, and what was measured.

Promised

  • “a historic and comprehensive "pollution diet" to restore clean water in the Chesapeake Bay” — US Environmental Protection Agency, on the TMDL (29 December 2010) US Environmental Protection Agency

Money moved in nature's name

WhatKindAmountPeriod
Federal agencies' operating level for Chesapeake Bay restoration, FY 2024
Federal agencies on the Federal Leadership Committee for the Chesapeake Bay
Office of Management and Budget (via Biden White House archive)
Budget$591m estimateFY 2024
Federal agencies' operating level for Chesapeake Bay restoration, FY 2023
Federal agencies on the Federal Leadership Committee for the Chesapeake Bay
Office of Management and Budget (via Biden White House archive)
Budget$524m estimateFY 2023
Federal agencies' operating level for Chesapeake Bay restoration, FY 2022
Federal agencies on the Federal Leadership Committee for the Chesapeake Bay
Office of Management and Budget (via Biden White House archive)
Budget$549m estimateFY 2022
Direct funding for the Bay Program from 11 federal agencies, Maryland, Pennsylvania, Virginia and the District of Columbia
Federal agencies and state-level governments
US Government Accountability Office
Budget$3.7bn estimateFY 1995-2004
Virginia Agricultural Cost Share programme funding in the Chesapeake Bay watershed
Commonwealth of Virginia
US Environmental Protection Agency
Budget$223mFY 2026
Total funding levels Congress provided for federal Chesapeake Bay restoration activities
US Congress (federal agencies on the Federal Leadership Committee for the Chesapeake Bay)
Congressional Research Service
Budget$5.7bn estimateFY 2014-2024

What was measured

Measured below the promise

EPA's own assessment reports modelled load reductions: nitrogen 57 percent and phosphorus 90 percent of the interim targets and sediment 100 percent, against a goal of all controls in place by 2025. EPA's Inspector General, an independent audit office within EPA, found in 2023 that the programme was not on track for 2025. The load figures are model estimates reported by the partnership and are not an independent measurement of the Bay's condition; the UMCES report card page gives C+ for 2025 without indicator detail.

Nitrogen load, 2009 to 2025
Down 14.96 percent; 57 percent of interim target
EPA 2025 Assessment; modelled US Environmental Protection Agency
Phosphorus load, 2009 to 2025
Down 21.4 percent; 90 percent of interim target
EPA 2025 Assessment; modelled US Environmental Protection Agency
Sediment load, 2009 to 2025
Down 7 percent; 100 percent of interim target
EPA 2025 Assessment; modelled US Environmental Protection Agency
UMCES report card, 2025
C+ for Bay health and for watershed health

Operation Ongoing · The 2025 Watershed Agreement commits the partnership to new water quality targets and plans by 2030. US Environmental Protection Agency

Findings on record

  • Official audit EPA Office of Inspector General (2023-07-18) · Report 23-E-0023: “not on track to have all controls and practices in place by 2025” EPA Office of Inspector General
  • Official audit US Government Accountability Office (2005-10-28) · GAO-06-96: “the public cannot easily determine whether the health of the bay is improving or not” US Government Accountability Office
  • Own admission US Environmental Protection Agency, 2025 Assessment (2026-08-13) · 2025 Assessment of the Chesapeake Bay Program partnership's progress toward the 2025 Water Quality Goal: “did not meet its watershed-wide interim targets for nitrogen or phosphorus” US Environmental Protection Agency

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: USD · Window: Mixed — see each line. Figures cover different periods and are not compared as a ratio. * Estimate built from cited figures.

Responses on record

  • US Environmental Protection Agency (2023; 2024; 13 August 2026): In its 2025 Assessment, wrote that the partnership met its sediment target and did not meet its nitrogen or phosphorus targets. To the Inspector General, EPA did not concur with recommendations 1 and 3 and concurred with recommendation 2 (completion estimated 15 January 2026). A spokesperson said in 2024: "EPA has a dual role with respect to the Bay—as a partner as well as a regulator." · US Environmental Protection Agency
  • Chesapeake Bay Program (2 May 2024): Reported in 2024 that model estimates showed nitrogen entering the Bay down 17% from 2009 to 2023. · Chesapeake Bay Program

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

No court case on record. No court has ruled on this case.

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Nitrogen load reduction, 2009 to 2025
14.96 percent (57 percent of interim target)
EPA 2025 Assessment; 297.1 to 252.7 million pounds; modelled
Phosphorus load reduction, 2009 to 2025
21.4 percent (90 percent of interim target)
EPA 2025 Assessment; 16.8 to 12.8 million pounds; modelled
Sediment load reduction, 2009 to 2025
7 percent (100 percent of interim target)
EPA 2025 Assessment; 18,830 to 17,555 million pounds; modelled
UMCES report card grade, 2025
C+ (Bay and watershed)
UMCES Ecosystem Health Report Card page

What we don't know

Undisclosed, unproven, untried: recorded as data.

Nature

  • Not measured Harm to nature: The record holds no measurement of harm to nature.
  • Disputed Whether the 2025 goals are on course
  • Disputed Modelled versus real-world data

Record

  • Insufficient Insufficient: monitored water-quality results. EPA's assessment uses modelled load reductions and lists "Discrepancies between modeled and real-world data" among the challenges.
  • Unclear None on record: a single total of federal and state spending since 2010. The OMB crosscut gives federal totals by year and states that state data may double-count federal funding.
  • Disputed Disputed: whether the goals are on course. EPA's 2025 Assessment says the partnership met its sediment target and did not meet its nitrogen or phosphorus targets; the Inspector General found the programme not on track; a Chesapeake Bay Commission representative described "course correction" rather than failure.
  • Unclear Unclear: the UMCES grade for the latest report card. The report card page shows C+ for 2025; the page gives no indicator scores or earlier grades.
  • Not measured Not measured: the effect of the 2025 Watershed Agreement's new targets, which are to be set by 2030.

Did the harm stop?

The sources reviewed do not report that nutrient and sediment loading has stopped. EPA's 2025 Assessment lists rising loads from population growth, development and agricultural intensification among the challenges, and its table footnote states that a value of 0% indicates that growth outpaces current implementation efforts, leading to an overall increase in loads.

Who paid?

Federal and state funds. GAO recorded about US$3.7 billion in direct funding in FY 1995-2004 from 11 federal agencies and four state-level governments; OMB recorded federal agency operating levels of US$549,131 thousand (FY 2022), US$523,808 thousand (FY 2023) and US$591,050 thousand (FY 2024); Virginia allocated US$223 million in agricultural cost-share funding for FY 2026.

Sources

Voices on record: — Company or project✓ Government and regulators— Courts✓ Press and investigations— Communities and civil society✓ Researchers

Researchers

  1. Chesapeake Bay report card page
    University of Maryland Center for Environmental Science (Integration and Application Network) · 2026

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Institutions

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