Please stop this cruelty

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Please stop this heinous act.

Please stop animal cruelty!

pass all of the laws above

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Good Afternoon, I am submitting my support of the above items. I strongly feel that we need to put more time and planning on what we are doing to our animals, that are due the same respect as we all inhabits of our planet, and out planet. We only have one earth and we have not been responsible on how we treated her.

Protect Virginia's environment from Republiklans

Protection of Land, Water, Air, Soil and all animals is up to us and for future generations a must.

Please email the above mentioned bills to me.

I support HB 1029 and 311, and 323. I oppose HB 189. I have concerns about HB 314 and 491 - namely, why does being "commercially significant" exempt a non-native plant from being deemed a noxious weed? I am also concerned about HB 351. I agree that encouraging motorists to choose electric vehicles is a worthy goal, but I am concerned about the emphasis on simply transitioning to electric cars when cars and the infrastructure they require, well beyond just gasoline, are themselves the problem. It isn't just about emissions, it's about the asphalt - impervious surface that aggravates flooding and heating - required to park a car regardless of how "clean" it is. It's about the unsustainable land use patterns that even clean cars necessitate. Investing in rail, sidewalks, bike paths, and diverse zoning is a far better use of resources than simply putting more electric vehicle charging stations.

Please stop this cruelty

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Please stop this heinous act.

Please stop animal cruelty!

pass all of the laws above

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Protect Virginia's environment from Republiklans

Though the oyster industry is important and requires respect, Virginia’s waters belong to everybody. So it is crucial to achieve a sensible, fair balance between oyster cages that obstruct navigation, on one hand, and, on the other, the needs of other commercial users of the water as well as recreational users. Steven T. Corneliussen

I do not have any specific comments but am here to answer any questions on behalf of the Marine Resources Commission.

I am stating my opposition to passage of HB 189 for the following reasons: Language "allowing aquaculture by any legal means" is too broad a statement. It leave open the potential for giving away the citizens' use of VA waterways to the interests and benefit of large private enterprises with unfettered ability to construct over-the-water cages which restrict such activities as recreational uses that are an important part of Virginia's coastline. More public input needs to be done before such a sweeping open-ended bill is enacted into law. I urge you NOT to the approve this bill in its present form.

Honorable Representatives, My name is Tom Powers. I am a recreational boater, fisherman and crabber. I serve on a number of VMRC advisory Committees and was involved with some of the aquaculture regulations and code changes that were developed in the early 2000’s. I have no fundamental problem with well regulated aquaculture operations. First there are probably implications relating to city and county zoning regulations relating to businesses in residential districts that may be negatively impacted by this legislation. I am not addressing that at this point in time. I am concerned that were this legislation enacted, that the Marine Resources Commission doing any of the items listed below will lead to a lawsuit the Judge would interpret this code section to mean that if it is legal for one person that it should be legal for everyone. For example, the Judge could direct the Commission to allow by right the ability to use floating cages above any leased bottom because the have done so in a particular instance. To that end I respectively request that the patron clarify what I believe is there intent and modify the wording of the change from “including the right to propagate shellfish by whatever legal means necessary.” “this, notwithstanding regulations in 4VAC-20 in Seq, shall include the right to propagate shellfish by whatever legal means necessary" This explicitly clarify that the Commission has the ability to continue to manage the tidal habitats in Virginia. If such a change can not be made than I do not support passage of this bill. Specific examples of items which I believe are will be maintained by such a change are: (a) The legislation still allows the Commission to reject or restrict the areas when issuing a permit application under regulation 4VAC-20-1130 General Permit #4 for Temporary Protective Enclosures for Shellfish which was put in place in response to State Code Section 28.2-603.1. Temporary enclosures on leased ground. (b) The legislation still allows the Commission to reject or restrict the areas for enclosures when issuing a habitat permit permit for something like floating cage aquaculture. (c) The legislation still allows the Commission to, for example, control where someone puts 12" cages because they impede navigation to someones pier or channel which is allowed under 4VAC-20-335 Pertaining to On-Bottom Shellfish Aquaculture Activities which was on the books before 28.2-603 was enacted. Further I do not understand how it can exist as it seems to be contrary to 28.2-603 as 28.2-603 does not have any exemptions for enclosures less than 12" tall and it has more restrictions, public notice notifications, etc. that are required prior to changing a on bottom operation (no enclosures) to a cage on bottom operation. (d) Where the term "legal means necessary" does not mean that, for example, because the Commission issued a habitat permit for floating enclosures or enclosures suspended from cables, that a judge decides that this is a legal means (because someone was allowed to do it by VMRC) and now, because of this law, it is allowed by right. (e) The legislation still allows the Commission to change what are a legal activities or permit requirements for shellfish aquaculture on leased ground in the future.

I urge the committee to vote against House Bill 189 for the following reasons: 1) This legislation will impede the Virginia Marine Resources Commission’s ability to properly regulate the shellfish aquaculture industry. VMRC may wish to change aquaculture permitting requirements impacting specific aquaculture operations due to a change in environmental conditions (e.g. SAV growth), boat navigation needs or for any unforeseen reason. This legislation would prevent VMRC from enforcing these permitting changes. 2) The Commonwealth should not provide the same irrevocable legal right to an aquaculture operation that it extends to oyster ground leasing. Oyster ground leasing simply gives the owner the right to work the water bottom which does not obstruct the public from using that portion of the water for boating, fishing, crabbing, etc. An aquaculture operation places cages and other structures in the waterway. As such, the aquaculture operator essentially takes ownership of that portion of the water which precludes the public from using it. For this reason, aquaculture operators need to be held to a higher standard than the right bestowed on an owner of an oyster bottom lease. 3) It has been suggested that this legislation is intended to replicate the Right to Farm Act for shellfish aquaculture. Shellfish aquaculture is very different than agricultural farming. With farming, the farmer either owns the land they use or rents it from another landowner, and that other landowner would have control of certain issues via the specific lease agreement between the owner and farmer. The landowner has the ability to terminate the lease if desired. In the case of aquaculture, the Commonwealth (all Virginia citizens) owns the river bottom and water above. The Commonwealth should not provide aquaculture operators with a perpetual right to obstruct it with floats and cages. Please reject HB 189. C. Burke King

Please email the above mentioned bills to me.

Please stop this cruelty

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Please stop animal cruelty!

pass all of the laws above

Protect our wildlife and water resources. Restrict hunting on sundays. No snares or trapping. No animals gor research.

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Good Afternoon, I am submitting my support of the above items. I strongly feel that we need to put more time and planning on what we are doing to our animals, that are due the same respect as we all inhabits of our planet, and out planet. We only have one earth and we have not been responsible on how we treated her.

Protect Virginia's environment from Republiklans

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Support

Please stop animal cruelty!

pass all of the laws above

Protect our wildlife and water resources. Restrict hunting on sundays. No snares or trapping. No animals gor research.

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Protect Virginia's environment from Republiklans

Protection of Land, Water, Air, Soil and all animals is up to us and for future generations a must.

My name is Jacqueline Goodrum and I am a resident of Albemarle County. I comment today in my professional capacity as Conservation Policy Associate for Wild Virginia, a statewide non-profit organization seeking to protect water quality for all Virginians. I urge you to support HB393 because it aims to ensure that DEQ and the Water Board consider community interests when deciding whether or not to lower the water quality of a local waterbody. Every community—rural, suburban, or urban—should be able to have a say in what happens to their local waters. Such waters provide tremendous value for local communities, including but not limited to enhanced property values for riparian and nearby landowners as well as economic benefits from water-based recreation and tourism. However, not every community has power, influence, or even reliable internet access to be able to participate in environmental decision-making. Accordingly, HB393 seeks to ensure that DEQ and the Water Board do not overlook the interests of local communities and the impacts of lowered water quality on these communities. HB393 seeks to achieve this outcome by expressly including a socio-economic analysis requirement in the statutory text. Importantly, HB393 does not create a new, substantive duty for DEQ or the Water Board; rather, it reiterates an existing obligation. Nonetheless, I urge you to support HB393 because although DEQ and the Water Board must consider social and economic demographics during anti-degradation analysis of a high quality water under both Virginia law and the Clean Water Act, highlighting this legal requirement emphasizes the importance of this analysis to fair environmental decision-making. Thank you for considering my testimony. Jacqueline Goodrum

On behalf of the organization Appalachian Voices, and our members across Virginia, including many of your constituents, I ask you to please support HB393. This water protection bill concerns review of social and economic demographics during anti-degradation analysis of high quality water. Consideration of those demographics would prevent disproportionate impacts to overburdened populations, including rural communities as permits to discharge are reviewed. Many of those same communities where projects can occur rely on the water resources located on their property for their livelihoods, from farming to raising livestock. Reviewing potential economic impacts should be an expressed requirement for projects which could impact the high quality water resources of a community. Please support HB393. Jessica Sims, Virginia Field Coordinator, Appalachian Voices

My name is David Sligh and I am a resident of Albemarle County. I am commenting in my capacity as Conservation Director for Wild Virginia and on behalf of our members across the state. This amendment would simply ensure that the interests of local residents and communities are explicitly accounted for if the Water Board considers allowing lowering of water quality in a nearby waterbody . This is a matter of respecting the rights of people who sometimes have less power and influence, whether in rural or urban areas. Local waters are often of paramount importance to landowners and residents, for a variety of uses, property values, and peaceful enjoyment. Those values should be protected as much as possible. Under state law and the Clean Water Act the state is already required to assess whether any decrease in quality for streams of high quality is an economic or social necessity for the area that would be affected. If not the degradation can't be allowed. That assessment must logically balance the values and costs for local people against those of all other interests. The language proposed in this bill would just expressly require that logical and fair treatment. Thank you for considering my testimony. David Sligh

Delegate Keam's HB704 (2020) established the Virginia Environmental Justice Act. § 2.2-234. defines "Environment" as the natural, cultural, social, economic, and political assets or components of a community. It defines "Environmental justice" as the fair treatment and meaningful involvement of every person, regardless of race, color, national origin, income, faith, or disability, regarding the development, implementation, or enforcement of any environmental law, regulation, or policy. § 2.2-235 now states that it is the policy of the Commonwealth to promote environmental justice and ensure that it is carried out throughout the Commonwealth, with a focus on environmental justice communities and fenceline communities. HB393 is duplicative and redundant.

I ask that you please vote in support of HB393. This bill is important for protecting rural communities, who are typically the first to be targeted for projects that could impact our water quality. HB393 would offer protection and increase fairness in the regulatory process by including additional demographic consideration in water anti-degradation evaluations and aligning water and air regulatory processes. Again, especially as a resident of rural Virginia, I ask that you please vote in support of HB393. Stacy Lovelace

Comments Document

SUPPORT HB 393 Delegate Willett’s HB 393 “Water quality; consideration of economic or social development” improves the tools available to the Virginia Department of Environmental Quality and State Water Control Board to analyze impacts to communities from new or increased discharges of effluent into high quality water. Specifically, this bill: ● Introduces consideration of social and economic demographics during anti-degradation analyses by adding language to § 62.1-44.4. Control by Commonwealth as to water quality. ● Prevents further disproportionate impacts to the water resources of typically overburdened populations., including rural populations. ● Provides for analysis under the State Water Control Board’s authorities similar to what exists under the Air Pollution Control Board’s authorities at Va. Code §1307 E, appropriately aligning water permitting code with air permitting code.

Please email the above mentioned bills to me.

508 keep our history alive both the good and bad. We, our children need to be taught the truth about US history 479 removal of large and small damns improves the quality of waterways 323 local and sustainable farms are the key to the future of successful farming. Thomas Jefferson believed this 255 dogs and cats should never be used for inhumane research 206 small renewal energy projects should have been implemented decades ago. We are so behind many countries in preserving our natural resources and increasing and implementing renewable energy sources 140 African American gravesites when discovered should be restored and protected as should all of them 1330 Companion animals should be allowed in more place’s especially on public transportation like Amtrak 1301 clean energy= clean air, water, soil, food and this is a human right 1273 I would like to see hunting bears, deer, raccoons, rabbits, coyote, bobcat foxes completely eliminated. They only terrorize wildlife, there is no “sport” in that. 1247 STOP killing contests of any wildlife!!! This is barbaric 1228 Water quality needs to be of the highest standard. It’s a God-given right 1224 if storm water is managed properly we could avoid massive pollution to our rivers and streams , Bays and Oceans

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Encouraging your support on the above bills

Please stop animal cruelty!

pass all of the laws above

Protect our wildlife and water resources. Restrict hunting on sundays. No snares or trapping. No animals gor research.

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Protect Virginia's environment from Republiklans

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Please stop animal cruelty!

pass all of the laws above

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Protect Virginia's environment from Republiklans

I do not have any specific comments but am here to answer any questions on behalf of the Marine Resources Commission.

I am writing in support of HB739 as it corrects mistakes and shortcomings introduced in SB776 in regards to coastline management. Under SB776, citizens of the Commonwealth who live adjacent to streams or waterways -- including myself and my family -- could lose their yards due to erosion, from being banned from installing protective rip-rap, or from being forced to change the slope of their yards at their own expense. SB776 is an unfair and unreasonable law, which was rushed through in Spring 2020 when citizens were preoccupied with other world events. Short of its outright repeal, HB739 is a step in the right direction.

Comments Document

I am president for the Wessynton Marine Association (WMA), and represent 23 home owners who have properties within the tidal waterways of Little Hunting Creek. I submit this written testimony in support of HB739: "Shoreline improvements, existing, repair, and maintenance". The Wessynton community includes a wide diversity of environments, from its high canopy trees, with a forested path, down to our actively maintained property along tidal water. The main page of our website (https://sites.google.com/site/wessyntonmarineassociation), states the purpose for the Wessynton Marine Association. We are chartered to maintain to satisfactory working depths, the channels serving the waterfront areas. We have two canals, both dredged and navigable. We also coordinate and accomplish maintenance on the bulkheads along the waterfronts, which are owned by the WMA. Each WMA home owner owns their portion of the bulkhead. Our community has managed and maintained this property for 50 years. In 2020 we dredged over 5000 cubic yards of material out of our waterways in order to maintain that navigability, and that cost our community a little under one-half million dollars to get that done. We have very active management, and are very supportive of our waterways. Our homes were built 50 years ago, and the lack of any grandfathering of maintenance of existing waterfront structures without a permit is a big concern. During a planning commission hearing, we heard Fairfax Co. staff and legal advisors state that every change, every repair, every update to any structure along wetlands will require a permit. Our concern in that, is if each home owner must request a permit for any repair, any update, any change, they will be hesitant to submit the paperwork and take care of any needed maintenance, and the effect of this will be that our bulkheads and our waterways will end up becoming in greater disrepair simply because of the burden and the risk of coming to the Wetlands Board, the Virginia Marine Resources Commission (VMRC) and the Virginia Institute of Marine Science (VIMS). Who decides the best available science when a permit is submitted? The Fairfax Co. Wetlands Board, VMRC, and also VIMS is a new decisionmaker. They provide research, advice, guidance and studies. Within the VMRC Tidal Wetlands Guidelines updated May 2021, Section 5 Best Available Science Resources section, it states that VIMS, "is designated as the Commonwealth's science advisor on coastal and marine natural resource related issues." And then it goes on, "As such, VIMS will be the arbiter in situations in which the best available science is in question." We're beyond where Fairfax County members, as part of the Wetlands Board, where the Commissioners in serving our community and do and a very good job. With SB776 the final decision rests with an organization that doesn't live in our area, and they are the final arbiter on a decision which their deference is going to be towards that living shorelines solution. Request the VA House Agriculture Chesapeake and Natural Resource subcommittee consider the significant change that Senate Bill 776 introduced on our homeowners. The impacts on their property value, and the costs to the home-owners should they be asked to install a living shoreline. Request your support of HB 739 and help us protect the investment we have made in our community.

On behalf of the Friends of Little Hunting Creek, and as a former member of the Fairfax County Wetlands Board, I urge you to vote against HB 739. This bill is unnecessary. Proponents argue that if they have to repair a tidal shoreline structure (such as a seawall or bulkhead), current law would require them to install a living shoreline instead. In fact, current law allows property owners to repair and maintain a shoreline stabilization structure without a wetlands permit, as long as the repair does not expand the footprint and cover wetlands. This has been established practice of the Virginia Marine Resources Commission since the tidal wetlands law’s enactment in 1972 and is confirmed by a Virginia Attorney General’s opinion. There is no problem that this bill solves. Proponents have not pointed to a single case in which the situation they fear has occurred. Nor is it likely to occur. Living shorelines include various nature-based approaches (for example, placing rock sills offshore or planting vegetation to absorb the erosive force of waves). State and local permitting authorities evaluate a site’s particular conditions and the adequacy of a proposed stabilization approach for the site. Under current law, living shorelines are preferred, but not mandated. Living shoreline approaches may not be suitable for high-energy shorelines or very steep slopes, for example. If a living shoreline approach is not suitable, a property owner can use another approach. What is gained by removing local flexibility and restricting local wetlands boards’ ability to base their decisions on site conditions and sound engineering? HB 739 would prevent wetlands boards from making any decision other than to allow owners to rebuild existing structures as originally designed. The bill weakens protections for wetlands that have been in place since 1972 and eliminates safeguards for current and future property owners. It would grandfather in existing structures, including unpermitted, unnecessary, obsolete or inappropriately designed structures, and allow them to be rebuilt in perpetuity. It would allow structures to be rebuilt that will not protect against sea level rise. It would not require rebuilt structures to meet current, sound engineering standards.

HB 739 is needed to correct some unintended consequences arising from SB 776, which was passed in 2020. Our community was designed with canals and we have sea walls to ensure that soil does not slide into the waters of Little Hunting Creek. Our waterfront property is important to us. We have paid a higher price to enjoy the view of the water and opportunity to have a boat dock in our backyard. We are very concerned that the highly subjective decision process to comply with the law arising from Senate Bill 776 is highly subjective and the outcome of a permit request to retain sea walls, which is required in our association bylaws, cannot be predicted. Most waterfront yards in Wessynton have a significant slope down towards the water and if these homes were required to install a living shoreline at a slope of 10 feet for every 1 foot in elevation (as County staff said would be required in the Planning Commission meetings), the installation of a living shoreline would take up a significant part of the property, perhaps including the house. The law arising from Senate Bill 776 will have a significant impact on our community should our sea wall need maintenance or should it be damaged from a tree or other causes. We would have expected our elected official to employ a process that at least sought out input as this bill evolved. We can understand how this did not occur because the impacts of the law arising from SB 776 are unintended. Given that these impacts are unintended, we ask that House Bill 739 be adopted to address these problems. Furthermore, we believe that the denial of a permit to repair or maintain our existing sea wall would constitute a takings without compensation, which is wrong.

Comments Document

I request support for House Bill 739, which corrects unintended consequences of the law arising from Senate Bill 776 (adopted in 2020). The law arising from Senate Bill 776 fundamentally changes the permitting process so that a permit applicant request to repair or maintain an existing sea wall can not longer expect approval because this law establishes a living shoreline as the preferred alternative. Installing a living shoreline where there was a sea wall will not only be expensive, it will also take land from the yard where it is placed to accommodate the living shoreline. This law establishes a highly subjective, difficult and expensive process, especially for anyone wishing to retain their existing sea wall. Moreover, the denial of a permit to repair or maintain an existing sea wall may well be deemed to be a takings by a court. The same concerns would apply to a shoreline stabilization structure constructed by rip rap.

Please exercise your authority to support all actions promoting the preservation of our natural resources and the protection of our environment.

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Please stop animal cruelty!

pass all of the laws above

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Protect Virginia's environment from Republiklans

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Please stop animal cruelty!

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

It is our understanding that HB792 submitted by Delegate LaRock would prevent nutrient credits from being created in Clarke County (through land conversion) to be sold to offset development in northern Virginia. The creation of nutrient credits in Clarke County has resulted in over 1,800 acres being converted through this program. In a number of circumstances, this has resulted in active farmland being converted to forest so the credits could be sold to offset development occurring outside of our jurisdiction. While we don't necessarily oppose the environmental benefits of this program, our proximity to northern Virginia has made us a target for these conversion activities. We support this bill as the land use decisions made in other localities shouldn't threaten farmland in our locality.

Comments Document

Dear Chairman Bloxom and Members of the House Agriculture, Chesapeake, and Natural Resources - Agriculture Subcommittee: The undersigned organizations are grateful for the opportunity to submit written testimony in support of House Bill 899. The bill would establish a registration program, administered by the Virginia Department of Environmental Quality (DEQ), for presently-unregulated aboveground hazardous chemical storage tanks. This proposal is modeled after the registration component in Virginia’s comprehensive regulations for aboveground oil and gas tanks, which have been on the books for decades. This bill would enact the 2016 recommendations of the VDEQ, VDEM, and VDH, presented in a joint study of these tanks mandated by the Virginia General Assembly in 2015. According to the findings of the agencies and recent research by the Center for Progressive Reform (CPR), these hazardous aboveground storage tanks (ASTs) are not regulated by federal or Virginia law. This leaves state-level regulators unable to identify the quantity, size, location, hazardous chemical contents, condition, and spill prevention measures, if any, for tanks throughout the Commonwealth. Limited data suggests that the number of unregulated chemical storage tanks in the Commonwealth may fall between 2,720 and 5,405. This data gap threatens the health and safety of Virginians and their drinking water resources. According to DEQ’s Pollution Response Program database, 4,800 tank-related instances of spills, releases, improper storage, and illegal dumping were recorded between 2000 and 2020. Of these, more than 1,400 explicitly involved aboveground chemical storage tanks. That amounts to at least 230 tank-related incidents per year. HB 899 will help minimize these hazards by: ● Requiring the State Water Control Board to create a registration program for aboveground storage tanks that contain certain federally-designated hazardous substances; and impose a graduated fee schedule intended to self-fund the registration program; ● Authorizing the Board to undertake corrective action in the event of a discharge of a hazardous substance; and ● Requiring tank owners to notify certain parties in the event of a release of a regulated substance. House Bill 899 is a necessary step in strengthening environmental, health, and disaster prevention and management programs in the Commonwealth. By closing gaps in information and reporting, this bill ensures that all Virginians are better protected against the risks of spills, leaks, explosions and other incidents involving unregulated aboveground chemical storage tanks. It is well past time the Commonwealth establishes common sense regulations that protect Virginia’s communities and resources. In an effort to safeguard communities, we urge the Subcommittee to adopt a FAVORABLE report on House Bill 899. Center for Biological Diversity Center for Progressive Reform Chesapeake Climate Action Network Action Fund Environment Virginia Friends of Buckingham Friends of Dyke Marsh Friends of the Rivers of Virginia James River Association Lynnhaven River NOW Potomac Riverkeeper Network Richmond Audubon Rockbridge Area Conservation Council Sierra Club Virginia Chapter Southern Environmental Law Center Virginia Aquarium & Marine Science Center Virginia Conservation Network Virginia Health Catalyst Virginia Organizing Waterkeepers Chesapeake

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Please stop animal cruelty!

pass all of the laws above

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Protect Virginia's environment from Republiklans

Comments Document

Throughout Virginia, the public is not protected from spills and other disasters involving storage of hazardous chemicals — including toxic and flammable substances — in aboveground tanks. For decades, the U.S. Environmental Protection Agency (EPA) and most states have refused to act to protect the health and safety of workers and communities, as well as water and natural resources, from the threat of hazardous chemical tank fires, spills, and explosions. The universe of these tanks — their quantity, location, contents, and conditions — and pollution involving these unregulated facilities are largely unknown to regulators and the public because most regulators do not even require registration. In the absence of federal action, 10 states, including West Virginia and Florida, have established comprehensive programs that impose registration, inspection, and design and siting requirements to prevent releases from aboveground chemical storage facilities. Some of these state programs were enacted by lawmakers in response to catastrophic incidents, like a fatal explosion in Delaware or the Elk River leak in 2014 in West Virginia that contaminated drinking water for hundreds of thousands of residents. Several years ago, Virginia studied the issue of unregulated chemical storage and found that aboveground storage tanks pose a threat to the safety of Virginians and their drinking water. At that time, the Virginia agencies recommended action, but policymakers chose instead to wait on an EPA rule that never came. To date, neither the federal government nor Virginia state agencies have attempted to estimate the full extent of and incidents related to aboveground chemical storage tanks nationwide or in the Commonwealth. Our analysis found that the number of unregulated aboveground chemical storage tanks in the Commonwealth may fall between 2,720 and 5,405. Furthermore, our analysis of data from Virginia DEQ’s Pollution Response Program found that between 2000 and 2020, there were nearly 230 tank-related incidents in the Commonwealth each year. The number of reported incidents also appears to have increased over time, and the seven most impacted cities and counties are home to roughly a third of Virginians. While these estimates paint a troubling picture, they are likely significant underestimates of the true extent of aboveground chemical storage tanks and associated spills in Virginia. Virginia policymakers have long recognized the threat that unregulated chemical storage poses in the Commonwealth. Like Delaware and West Virginia, Virginia should enact a comprehensive program that tracks tanks, prevents spills, and makes information available to emergency planners and the public. To maximize protection from chemical disasters, policymakers should rely on lessons learned in other states and adopt measures to reduce reliance on the most toxic chemicals and put practices in place that effectively protect workers, communities, and natural resources. The first step in addressing the threats that these tanks pose is to Virginians is to enact the registration program called for by the Virginia Departments of Environmental Quality, Emergency Management, and Health. HB 899 would accomplish that task.

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Please stop animal cruelty!

pass all of the laws above

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Support HB 949 Coal Tar Sealants contain over 1,000 times more PAHs than similar asphalt-based products. The Chesapeake Bay Program has prioritized PAHs as the second most important toxic contaminant. PAHs are more likely to be present in stormwater flowing from parking lots where coal-tar sealcoats have been used. PAHs are known to cause cancer, birth defects, and mutations to aquatic life. Research has shown that PAHs accumulate in the tissues of bivalves such as oysters and native freshwater mussels. Several PAHs are also cancer-causing in humans according to the Centers for Disease Control and Prevention. Coal Tar Sealants spread mutagenic and carcinogenic chemicals onto playgrounds, businesses, and homes. Home Depot and Lowes stopped selling coal tar products because of their liability. VDOT, has not used coal tar products for many years. Please support HB949 R

Comments Document

The American Chemistry Council (ACC) is a national trade association representing chemicals and plastics manufacturers in the United States, including member companies in the state of Virginia. Our members are committed to the safety of their products and to the protection of the public health. ACC opposes HB 949, a bill that would prohibit the sale or use of pavement products with certain levels of polycyclic aromatic hydrocarbons.

Comments Document

Dear Delegates: Thank you for taking up this life-saving legislation to restrict the use of coal tar pavement sealers in the State of Virginia. My name is Tom Ennis and I helped Austin, TX pass, defend and implement the nation’s first coal tar sealer ban. I have supported many others across the US since then and I support this bill as well. This is a bill that is ripe for passage. The SCIENCE is clear. Over 26 research institutions have found that coal tar sealers are a danger to humans and the environment.1 That’s why the AMA supports the elimination of this product.2 It is also why Morgan State University found that Chesapeake Bay oysters are affected by the chemicals from this product and said, This study’s results provide evidence that PAHs entering an aquatic ecosystem from runoff from road surfaces have the potential to inhibit oyster reproduction by negatively impacting three critical processes in the early life cycle of the Eastern oyster.3 The PUBLIC needs this. The role of good government is to protect people from unscrupulous practices and this one spreads industrial-level, potent mutagenic and carcinogenic chemicals onto unsuspecting playgrounds, businesses and homes. The SUPPLY is ready. Non-toxic sealers are numerous and similar in quality and price.4 In 2007 Home Depot and Lowes stopped selling coal tar products because of their liability.5 I hope that Virginia will heed the advice of a local official: “If coal tar sealers are not good enough for the shelves of Home Depot and Lowes, then it isn’t good enough for the paved surfaces of our community.” Attached are responses to typical claims made by industry in opposition to this legislation. If I can answer any of your questions, please don’t hesitate to reach me at coaltarfreeamerica@gmail.com. Sincerely, Thomas E. Ennis, PE, LEED AP

Pertaining to HB949 | Tran | Pavement sealants; sealants containing coal tar prohibited, coal tar is among a group of compounds called polycyclic aromatic hydrocarbons or PAHs for short. There are many compounds within this group that span the range of low molecular weight compounds like gasoline to high molecular weight compounds like coal tar and they can exhibit varying toxicity to humans and other organisms. Research has shown that PAHs accumulate in the tissues of bivalves such as oysters and native freshwater mussels. They tend to be metabolized (eliminated) very slowly in these aquatic bivalve species, and thus their presence may result in altered DNA (genotoxicity) and immune system problems (immunotoxicity), among others, suggesting that PAHs are a threat to aquatic life.

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

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The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

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Comments Document

Please recommend this legislation. The harms of sealants containing more than 0.1% PAH directly relevant to this subcommittee were manifest even in the attached testimony provided December 2018 by DEQ for my representative, Delegate Wilt. Delegate Wilt replied with questions regarding whether the average Virginia waterway was above or below the probable effect concentration (PEC) in sediment for PAHs of 22.8ppm. In my opinion as an economist with expertise in statistics, a statistic that would have been more informative for Delegate Wilt would have be one derived from the subset of waterways for which PAH contamination from sealants is possible, measured at the parts of the waterway where direct effects could be expected. Consider how a road safety, rather than a stream safety, question might be approached. Deaths from merging into semis might not be a problem on the average road in Virginia, whose roads range from undeveloped alleys to interstate highways. However, widening lanes on even one interstate, like I81, might be a compelling policy if it was believed to reduce such accidents. As of this testimony, a rough count of the sources at https://coaltarfreeusa.com/bans-2/ shows 114 government bodies including 4 states have considered available data and imposed bans, with more having applied restrictions across 17 states since the first ban in 2006 following a fish kill in Austin Texas that shed new light on the harms of this product. Within eight years of the first ban, data had accumulated not just on harms but on the benefit of restrictions. https://www.usgs.gov/news/national-news-release/austin-coal-tar-sealant-ban-leads-decline-pahs#:~:text=PAHs%20are%20an%20environmental%20health,use%20of%20coal%2Dtar%20sealants. Virginia's localities need your help. In Harrisonburg, Thanh Dang, who answered my call to the city phone number for reporting toxic discharge into waterways, refused to accept my report of coal tar sealant being sprayed directly into a storm sewer within two blocks uphill from Black's Run on a rainy day because she said the city could do nothing. Ted Byrd (R) and Kai Degner (D) are recorded in 6/9/2015 City Council minutes, unable to take action: "Council Member Byrd also noted that to his understanding, the coal tar issue noted earlier is a state issue. City Attorney Brown stated he feels that it is, but would double check. Council Member Degner asked about Section 7-6-7in regards to the coal tar question and if the health department has taken a side." Businesses have watched these bans grow despite changing regulatory regimes. Alternative products which have been favored west of the Mississippi have become even more competitive since 2018. For parking lot and driveway applications, this is an end product whose least contested feature is aesthetic. Its elimination would not significantly affect other products or activities. The great benefit of this legislation is low hanging fruit. Delegate Wilt deserves credit for following through with DEQ on this issue even though they were not prepared to testify earlier in that session, preventing him from following through with his https://lis.virginia.gov/cgi-bin/legp604.exe?181+sum+HB1150. While he was not able to pass his bill, he was able to hand forward what future legislators would need. I look forward to this impactful legislation passing in a bipartisan effort with your support under the sponsorship of Delegate Tran.

I support the Humane Society of the United States' positions pertaining to your particular bill(s). I do believe HSUS adheres to and promotes the highest standards of integrity in the issues of animal issues, the environment, human concerns, et. al. I hope you can vote with that perspective in mind.

Please stop animal cruelty!

pass all of the laws above

The greatness of a nation and its MORAL PROGRESS can be judged by the way it treats its animals, its wilderness and its most vulnerable inhabitants.

Protect Virginia's environment from Republiklans