Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
State Water Control Board
 
chapter
Water Quality Standards [9 VAC 25 ‑ 260]
Action Modification of Implementation Requirements for Criteria Specific to the Chesapeake Bay and Its Tidal Tributaries (9VAC25-260-185)
Stage Fast-Track
Comment Period Ended on 1/1/2025
spacer
Previous Comment     Back to List of Comments
1/1/25  9:43 am
Commenter: Stuart Overbey

Vague Language is Problematic
 

On the face of it, opening up criteria to new datasets seems like a good idea. If the only threshold those data sets have to cross is being "scientifically-defensible," however, that is problematic. Using open-ended, subjective language like this could result in the use of better datasets, and also could result in the use of datasets that are intentionally designed to be industry-friendly and to insert doubt and questions into the process, at the very least. 

Given DEQ's history of ignoring the precautionary principle (see "biosolids," for one example), it is unreasonable to expect public trust and to fast-track such a sloppy modification to important environmental rules.

Regular process and review are required, along with better, more specific language in the proposed change to ensure the criteria are enhanced and not degraded in the future.

CommentID: 229088