If the legislation is implemented as written in the summary by Legislative Services, the establishment of a new delivery factor would only be applicable for stream restoration projects. Significant financial investment has already been made by numerous individuals in the Southern Rivers in Land Conversion Projects for the Generation of Nutrient Credits. If the bill passes as currently written, it has the potential to place individuals participating in Land Conversion Projects at a competitive disadvantage. Nutrient Bank Sponsors whom have implemented Land Conversion Projects should have the opportunity to have Land Conversion Nutrient Credits certified or recertified using the same delivery factor rate as stream restoration. The playing field should be even for both practices when implementing a delivery factor. A Technical Advisory Committee (TAC) should be convened to solicit feedback from stakeholders and interested parties to provide guidance on what is deemed the “best available scientific and technical information” to the Department of Environmental Quality and its Director. Stakeholders from various backgrounds have different “charges” depending on their “position” of the matter at hand and can provide valuable analytic feedback that may be overlooked during the development of a new delivery factor. As a resident of Virginia as well as practitioner of the Nutrient Credit trading marketplace, I think it is important that we take a science-based approach on a proposed delivery factor in the Southern Rivers to protect Virginia’s water quality as well as facilitate and foster growth and development. We also need to take into consideration the financial investment that Virginian’s as well as outside investors have made to date in Virginia’s Nutrient Trading Program and protect these investments to the maximum extent practicable and thus show why Virginia is a great place to conduct business.