I am writing to you requesting that the proposed regulation amendments published as 9VAC25-260, Water Quality Standards, be removed from the fast-track adoption process and be proposed to a Notice of Intended Regulatory Action subject to full Administrative Process Act public notice and comment. Before Virginia proposes any amendments to 9VAC25-260-185 it should coordinate its proposals with and seek approval from the US EPA and the Chesapeake Executive Council as required by 33 U.S.C. 1267 (g)(1) and the Chesapeake Bay Agreement.

You use the term "alternative scientifically defensible methods" in your proposal. However, you fail to define it, which reminds me of the term "alternative facts." All jurisdictions need to participate using the same criteria. It must be transparent, open to comment, and use sound science.

Fast-track rulemaking is not the Virginia way.