Behalf of Lynnhaven River Now, I am writing to share that we are opposed to this fast-tracked rule making procedure. 

In 2002, a committed group of local citizens came together to foster partnerships that would apply public and private resources to the challenge of reducing pollution in the Lynnhaven River, which is a tidal tributary to the Chesapeake Bay. That core group formed what has grown into an award-winning river restoration project with over 12,000 members called Lynnhaven River NOW or LRNow. “Now” because the work of restoring and protecting the beautiful Lynnhaven is something that we can do NOW for ourselves and for our children and grandchildren.  Back in 2002 when we were founded, only 1% of the Lynnhaven met the water quality standards to safely harvest and eat shellfish. After 20 years of restoration work, community education, stakeholder engagement, and policy advocacy, over 50% of the Lynnhaven is now safe to harvest and recreate. As an organization, we deeply understand that the path to restoring any water body, is a long and complex road that requires sound science and methodology. Progress is earned over years but can be lost quickly if we do not stay the course. Much like the Lynnhaven, the Chesapeake Bay has made great progress over the years. This progress was achieved thanks to work of the Bay programs and cooperation between states following a highly scientific blueprint provided by the Chesapeake Bay Agreement. All this hard-earned progress can be jeopardized by any hasty, nontransparent modifications to the implementation requirements for criteria specific to the Chesapeake Bay and its tidal tributaries as defined at 9 VAC 25-26-18.  Therefore, we ask the normal (not fast-track) promulgation of the Administrative Process Act be applied to this matter.  

Thank you.