Action | Promulgate new Nutrient Trading Certification Regulations |
Stage | Proposed |
Comment Period | Ended on 3/16/2015 |
To: Ms. Debra Harris; Va. DEQ; Richmond, Va. March 11, 2015
Re: My Comments: DEQ's Proposed- Nutrient Trading Certification Regulations
Dear Ms. Harris & Va. DEQ,
Yes, the Va. DEQ staff has worked long and hard to gain many strong points in subject, needed Regs.
Yes, some improvements appear needed; here's my offering:
1. Strengthen provisions to protect local water quality.
a) Double check-- does whole program comply with EPA's guidance regarding timing and location of trades?;
b) Double check-- do overall Regs. prohibit trades that will degrade { what adverb here?; measurably ?? } local waterways?
2. Ensure *real water quality improvements.
a) DEQ must specify that baseline conditions on farms/ ranches will include vegetated, robust-designed buffers 35' in width on pastureland, or maybe, in special contour cases along a stream, specify best-practical buffer widths up to 33% of the length of the riparian buffer (per advise of local, trained Soil & Water Conservation Board staff, Va. Extension Service staff, &/or properly certified consultant).
b) Require practical water testing to demonstrate tangible improvements to both local and downstream waters.
3. Sustain transparency.
a) Provide for meaningful public access (ex.- DEQ's website show current, essential information about the practices that will generate *trade-able credits).
b) Provide a 30-day period for the Public to offer comments &/or alternative actions.
c) Double-check: For about zero-cost, get some volunteers at each DEQ Regional Office to ask ~25+ citizens/each Region- any problems in seeing these Regs., the nutrient trading and understanding the benefits of these type of pollution trades? Even some simple focus-groups might be useful.
Its important to show overall awareness (ex.- big-picture ideas- like the Fed. ADA initiatives)- lots of citizens are not up to 65 MPH, or even 55 MPH-- on the WWW.web (and DEQ's complex web-site), especially those of us over 65!
Thank you for considering my comments. Also, thanks for your good service to our vital Commonwealth.
John B. Reeves P.E.
400 Silver Oaks Drive; Rockingham, Va. 22801-3579
(540) 433- 9358 JBR1948@Comcast.net