Mr. Justin Williams April 25, 2024
버지니아 환경품질부(DEQ)
1111 이스트 메인 스트리트, 스위트 1400
P.O. Box 1105
리치몬드, VA 23218
This comment sent by email to Justin.Williams@deq.virginia.gov
Re: Fairfax County Ordinance Chapters 116 and 118, and Petition for Establishment of a Regulation or Policy Interpreting the Definition of a Nontidal Wetland
윌리엄스 씨에게
I respectfully submit the following comments regarding the March 11, 2024 Petition to the State Water Control Board (the Board) for Establishment of a Regulation or Policy Interpreting the Definition of Nontidal Wetlands Under 9VAC25-830-40, 9VAC25-830-80, and Fairfax County Ordinance Ordinances.
The petition as I understand it is to reduce and constrict the Fairfax County Resource Protection area based on the recently decided federal Sackett case. Others have made legal arguments that Sackett should not be applied to the Fairfax RPA. I leave those arguments to legal experts.
Fairfax and the Commonwealth have well established procedures to determine what should be protected and included in the RPA. These areas are established by professionals taking into account surface water, soils, groundwater, vegetations and a variety of other factors.
While the petition does not specifically include reference to tidal wetlands, it is a small and harmful jump to apply Sacket to these important wetlands as well. The Commonwealth has a wealth of laws going back to the 1970s as well as regulation and guidelines applied by VMRC, VIMs, and local wetlands Boards to establish tidal wetlands to which Sacket should not apply.
I oppose this petition for the reasons stated above.
I am a Virginia Professional Engineer. In addition I am appointed member of the Fairfax County Environmental Advisory Committee (EQAC) and Chairman of the Fairfax County Wetlands Board (FCWB). My comments are my own individual comments and are not made as representations of positions taken by EQAC, the FCWB, or of Fairfax County Government.
진심으로,
Clyde Wilber PE
301 346 8209
cc: Mike Rolband, Director, DEQ
