To Whom It May Concern:

Sierra Club Virginia Chapter joins with others in submitting comments on the proposed adoption of draft regulations stemming from amendments to the Chesapeake Bay Preservation Act that added “coastal resilience and adaptation to sea-level rise and climate change” to the consideration criteria. We believe that these regulations are significant in scope as one of the first to mandate the consideration of climate change within the Act’s criteria.

We hope that the proposed regulations will be expanded to include definitive climate change language beyond only the consideration of sea-level rise. For example, protections for Resource Protection Areas (RPAs) presently impacted and further threatened by more frequent and severe storm surge, along inland rivers and streams and in coastal areas, need clarification. We further recommend that the proposed regulations clearly stipulate expectations to uphold RPA and limit the authority of local jurisdictions to offer waivers or exceptions for development. Additionally, we ask that the regulations ensure that all definitions contained within are sufficiently explicit to ensure that localities, and specifically local government staff, have a complete understanding of their role and responsibility under the amended Act going forward. 

Above all, we urge a heightened level of attention to ensuring that these regulations contain enough specificity to ensure their effectiveness at achieving the intent of the legislative change, which is to ensure that Virginia continues to make progress combating climate change (mitigation) and protecting communities from climate impacts with an emphasis on disproportionately vulnerable populations. We hope that with the eventual adoption of these regulations, the agency will be able to assist local governments as they navigate implementation.

We appreciate all that is involved in developing these regulations and also appreciate the expertise offered to this process by our colleagues at the Southern Environmental Law Center, Chesapeake Bay Foundation, and Wetlands Watch. We hope the agency will continue to engage these organizations and stakeholders, including frontline communities, moving forward before these regulations are adopted as drafted. 

Should you have any questions regarding these comments, please direct them to Connor Kish, Legislative and Political Director, at connor.kish@sierraclub.org. 

Sincerely, 

Kate Addleson

Director

Sierra Club Virginia Chapter