Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
State Water Control Board
 
chapter
Virginia Pollutant Discharge Elimination System (VPDES) Permit Regulation [9 VAC 25 ‑ 31]
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9/1/23  12:01 pm
Commenter: Hannah Long

I Do NOT Support This Petition
 

This petition was obviously created as an attack on the menhaden fishing industry, however it is clear that the widespread impact a regulation such as this would have was not evaluated. 

For example, any water brought onto a vessel (whether it is commercial or recreational) while fishing/crabbing/oystering, and then discharged back overboard, would be considered point source pollution. Live wells, pound netters bailing their fish, and spraying oysters during seeding and cleaning would all become point source pollution. Not to mention the use of chum lines during recreational fishing. That would also become point source pollution. 

The water that is discharged from the menhaden vessels is NOT bail water, it is not bilge water. It is simply seawater that was brought up with the fish, and then discharged not even 10 seconds later. This is no different than the water that gets in your boat when you reel in a fish (that ultimately gets discharged back over as well). 

This petition does much more than target the menhaden fishing industry. This will target ALL commercial fishing in Virginia, as well as ALL recreational fishing in Virginia. I do not believe that was the initial goal of this petition, but that is the reality; if you regulate one, you regulate all. 

CommentID: 220050