Agencies | Governor
Virginia Regulatory Town Hall
Department of Environmental Quality
State Water Control Board
Chesapeake Bay Preservation Area Designation and Management Regulations (formerly 4VAC50-90) [9 VAC 25 ‑ 830]
Action Amendment to incorporate additional requirements related to preservation of mature trees and replanting of trees into existing criteria.
Stage Proposed
Comment Period Ends 5/3/2021
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5/3/21  3:09 pm
Commenter: George C. Ledec, PhD

Comments on Proposed Changes - Preservation of Mature Trees in RPAs, development in RPAs

There should be no exceptions granted for any reason to the preservation of mature trees in resource protection areas.  Resource Protection Areas are areas where protection of natural resources need to be a high priority.  Granting exceptions to this should not be allowable since this compromises not only the health of our natural resources but is a serious public safety risk in that mature  trees in RPAs hold soil, prevent erosion and otherwise protect the public from the known and existing increased precipitation events occurring due to climate change.  Even a tree that is mature but less than 100 % healthy serves a critical purpose of holding soils, preventing erosion and otherwise protecting public safety.   If exceptions are allowed then portions of an RPA will be cleared of mature trees and other portions will retain mature trees.  This inconsistent management of the RPA will result in some areas at greater risk than others from the increasingly frequent damaging flooding events.  This situation can be avoided if all RPAs are managed consistently.  Therefore no exceptions should be allowed. Delegating authority for granting exceptions to localities would result in fragmented management of RPAs increasing public safety risk and possibly mis-management of natural resources.  Localities are under increasing pressure to develop all currently undeveloped lands. We have seen clear evidence that developers influence localities to develop environmentally sensitive areas inappropriately.   RPAs are highly valuable lands that should not be developed rather they should be conserved in perpetuity with mature trees intact.  In the case of unhealthy or hazard tree (must be scientifically assessed and measured for "unhealthiness") is removed from an RPA, it should be replaced at triple the dbh on the same site it was removed from.

CommentID: 97815