In review of the Proposed Modification to 9VAC25-260-185. Criteria to protect designated uses from the impacts of nutrients and suspended sediment in the Chesapeake Bay and its tidal tributaries; I find inaccuracies in the following areas:

1.      There is an economic effect on private property owners that have Riparian right to Oyster Grounds.

2.      There is a biological need for salinity to propagate Clams and Oysters.

3.      The change in regulation addresses purity of industrialized discharges.  It does not consider the fact that pure water has a “NEGATIVE EFFECT” on the ‘SALTWATER” seafood industry.  This may be great for brook trout, but lethal for clams and other mollusks.

4.      There is a negative effect on the aquaculture economy when the Commonwealth of Virginia creates an environment is neither conducive to propagate clams or to the harvest of selfish.

Your reports are not accurate and need additional review.  Northampton and Accomack Counties are still part of the Commonwealth of Virginia.  There appears to be a complete lack of knowledge of aquaculture with regard to water quality.

Thank you.