Public Comments for 02/28/2022 Agriculture Chesapeake and Natural Resources - Chesapeake Subcommittee
SB145 - Subaqueous beds; unlawful use, replacement of piers.
SB187 - Nutrient credits; DEQ to accelerate release of credits generated by stream restoration project.
SB188 - Nutrient credit stream restoration projects; use of third-party long-term stewards.
As the President of a 501c3 land trust, Broad Water Innovations, I am writing in support of SB188. Our organization holds easements and serves as the Long Term Steward of stream and wetland mitigation banks as well as stream nutrient projects. As it currently stands, the code would require a Trustee to hold endowment funds for the Long Term Stewardship of stream nutrient banks. After doing significant research, we have not found a qualifying trustee that would charge less than $2500 to $5000 a year just to hold the endowment funds. These endowments are not of significant enough size to absorb those sorts of additional fees. The result would be the ultimate depletion of these endowments over time. SB188 provides a proven solution that works in 404 banking, and that will most importantly ensure there is funding in perpetuity to protect these important lands. Tee Clarkson President, Broad Water Innovations
SB50 - De minimis subaqueous disturbances; no permit required.