This NOIRA appears incomplete and should provide additional detail. Detail on  How many species, how many counties in the state, and potential impacts to the regulated public should be included.

It is unclear what and how many new species are proposed for protections, data on each species proposed exists, and if statewide surveys have been completed for all or any of them.

In the past many of our many clients including municipalities have been the guinea pigs of new regulation and restrictions, resulting in additional time and cost to planned projects to complete surveys for newly listed imperiled, rare or candidate species.  Many of the new species listed have very little information at the state level.

 Much like new species added at the federal level, sufficient information regarding populations should exist prior to implementation.  

Do projects which have been permitted or have submitted site plans have to go back and start over, and potentially change plans that have been in the works for years?

Do farms have to survey the fields prior to working them, or converting a pasture to active agriculture? 

Many species prefer old field or cleared and maintained roadway and utility corridors.  Will utility companies be required to survey existing ROW prior to maintaining it. 

Any new listing should consider the documented need, the impact it will have on the public overall, and have documented evidence of need for protection.

This NOIRA should consider implementation strategies prior to any additional implementation of species to protected status in Virginia for this regulation.  

Surveys and data should be sufficient to add to any species to state protections list and not rely on those regulated to be the bearer of the costs of the surveys.