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I am totally against this bill which introduces a fee for using trawl nets and drag nets for shrimp and horseshoe crab fishing within Virginia's three-mile Atlantic shoreline limit, where currently no fee is required. Unnecessary Financial Burden: Imposing a $100 fee per boat for using trawl nets and drag nets adds an unnecessary financial burden on fishermen, especially small-scale operators who might not have the financial flexibility to absorb this new cost, potentially affecting their livelihoods. Discourages Traditional Practices: This fee could discourage traditional fishing practices that have been part of the local culture and economy, pushing fishermen towards alternative, possibly less sustainable methods if they cannot afford the fee. Inequitable Access: The fee structure might create an inequity in access to these fishing methods, favoring those who can afford the fee over those who cannot, potentially leading to a skewed distribution of fishing rights. Does Not Address Environmental Concerns: While the intention might be to regulate or reduce the use of these nets, the fee does not directly address the environmental impact of trawling. A fee alone might not be sufficient to mitigate the ecological damage these methods can cause. Potential for Non-Compliance: Fishermen might be tempted to fish without obtaining the necessary permit to avoid the fee, leading to increased illegal fishing activities and complicating enforcement efforts by the Marine Resources Commission. Revenue vs. Conservation: The revenue generated from these fees might not be directed towards conservation efforts or habitat restoration, which would be necessary to offset the environmental impact of trawling, making the fee seem more like a tax than a conservation measure. Administrative Overhead: The introduction of a fee system would require additional administrative work for the Marine Resources Commission, including processing applications, managing payments, and ensuring compliance, which could divert resources from other conservation activities. Economic Impact on Local Communities: The fee could have broader economic implications, potentially reducing the income of local fishing communities, affecting related businesses, and impacting the supply of locally caught shrimp and horseshoe crabs. I strongly oppose this legislation because while it might seem like a regulatory step, it primarily serves as a financial barrier without addressing the core environmental issues, potentially leading to economic hardship, increased non-compliance, and administrative burdens, urging instead for regulations that focus on sustainability and conservation.

I support these

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Comments Document

The Congressional Sportsmen's Foundation supports House Bill 1813 as it expands access and opportunity for trout anglers in the Commonwealth and encourages the recruitment, retention, and reactivation of sportsmen and women.

I am writing to express my vigorous support for House Bill No. 1813, which establishes a Trout-Fishing Access-Site Registry and provides a tax credit for eligible landowners. As a professional fly-fishing guide, recreational fisherman and former chair of the Board of Wildlife Resources (noted for bona fides purposes and does not imply a DWR board position), this legislation would greatly enhance recreational fishing opportunities and the associated local economic benefits that come with it. I encourage you to support this crucial legislation promoting recreational fishing, enhancing community engagement with our natural resources and supporting private landowners in the Commonwealth. Your backing can help ensure the success of this initiative, making Virginia a leader in accessible and sustainable outdoor recreation. Key Benefits: 1. Increased Access to Fishing: By providing registered access sites, we can enhance recreational fishing opportunities in Virginia, benefiting trout fishing enthusiasts and promoting outdoor activities. 2. Supports local outdoor recreation economy: Small businesses like guides, outfitters, retail shops, hotels, restaurants, gas stations and many more, all benefit from anglers coming to fish in the area. Creating more opportunity is good for those businesses and the community. 3. Support for Private Landowners: The tax credit of $2,000 for eligible landowners who register their properties incentivizes collaboration between the public and private sectors, encouraging more landowners to open their land for fishing. 4. Sustainable Fishing Practices: The Board of Wildlife Resources will ensure that registered properties meet necessary criteria for trout fishing, promoting responsible fishing practices and landowner stewardship. Thank you for your attention to this vital issue. Should you need further information or wish to discuss this legislation in more detail, please don’t hesitate to contact me.

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Hello, Please require retail establishments to post clear signage designating invasive plants and educating the public on what that means. Invasive plants are a tremendous issue threatening our ecosystems. They out-compete native plants that we need in order to enjoy our land, support animals for hunting and fishing, control floods and erosion, protect infrastructure, protect our trees, and protect wildlife. I work in watershed restoration cleaning up our waterways to provide safer drinking water, protect infrastructure, protect our ability to safely hunt and fish, and protect our native songbirds, trees, flowers, and wildlife. Most of our budget is spent on invasive species removal; it costs a lot, requires the use of herbicides, requires the use of heavy equipment, and requires many years of constant maintenance in order to prevent them from coming back. They damage our ecosystems and I have seen many beautiful old trees die because of invasive English ivy, tree-of-heaven, privet, and invasive honeysuckle. Our songbirds die eating berries from invasive plants. Please pass this legislation. Additionally, please pass the legislation supporting wildlife corridors; in addition to being needed to protect wildlife, this bill would protect so many people. Deer-auto collisions cost states millions each year and injure and kill many drivers. We are also at risk of losing many of our native wildlife species as a result; animals like frogs and salamanders need to cross roadways in order to reach wetlands to breed, and cannot escape cars.

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I am totally against this bill which directs the Secretary of Natural and Historic Resources to establish a policy task force focused on the protection, restoration, creation, and planning for the persistence of tidal and nontidal wetlands in Virginia. Bureaucratic Redundancy: Creating another task force adds to the existing bureaucratic structure, potentially duplicating efforts already being addressed by various environmental agencies and existing planning frameworks like the Virginia Flood Protection Master Plan and the Virginia Coastal Resilience Master Plan. Cost and Resource Allocation: Establishing and maintaining this task force would require funding and resources, which could be better utilized in direct action for wetland conservation or restoration projects rather than in administrative and meeting costs. Slow Decision-Making: The requirement for the task force to meet at least twice annually and report findings could slow down the implementation of urgent wetland protection strategies, as the process of consensus-building and reporting might delay actionable steps. Stakeholder Overload: Including "certain relevant stakeholders" might lead to an overly broad representation, making it challenging to reach decisions efficiently due to the diverse interests involved, potentially watering down effective strategies. Focus on Reporting Over Action: The emphasis on reporting findings and recommendations by specific deadlines might result in a focus on producing documents rather than implementing on-the-ground solutions, leading to a report-heavy approach with less tangible outcomes. Potential for Policy Stagnation: With the task force's recommendations needing to be incorporated into existing plans, there's a risk of policy stagnation if these plans are already comprehensive or if there's resistance to integrating new strategies, leading to little actual change. Climate Change Overemphasis: While addressing climate change impacts is crucial, the bill's focus might overshadow other immediate threats to wetlands, like pollution or development pressures, potentially leading to a less balanced approach to wetland conservation. Lack of Local Input: The centralized approach of a state-level task force might not adequately consider local nuances or give enough weight to local conservation efforts, which are often more effective due to their grassroots nature. I strongly oppose this legislation due to concerns over bureaucratic redundancy, resource misallocation, delayed action, stakeholder complexity, focus on documentation over action, potential policy stagnation, overemphasis on climate change at the expense of other issues, and the risk of overlooking local conservation initiatives, advocating instead for direct, localized, and immediate conservation efforts.

Comments Document

Honorable David L. Bulova, Chair, and Member, Subcommittee on the Chesapeake Committee on Agriculture, Chesapeake and Natural Resources, House of Delegates, Commonwealth of Virginia In re: Public Testimony Opposed: S. Amd. Dated January 20, 2025, H. 2178 relating to: preproduction plastic Chair Bulova and Members, The American Chemistry Council (ACC) appreciates the opportunity to comment on the substitute amendment dated January 20, 2025, to H. 2178 relating to preproduction plastic. ACC urges the committee not to move forward with the legislation. The plastics industry is already taking steps to minimize and prevent plastic discharge. Operation Clean Sweep (OCS) was founded in 1991 by the Plastics Industry Association and has been jointly administered by ACC and PLASTICS since 2004. OCS is an industry-led plastic resin stewardship program that supports companies’ efforts towards achieving zero resin loss to the environment. OCS members commit to making zero plastic resin loss a priority, assess their own situation and needs, make appropriate facility and equipment upgrades, raise employee awareness, create and enforce procedures, and conduct routine inspections for continual improvement. OCS has over 130 U.S. members across the full plastics value chain (e.g., material suppliers, processors, warehouse and distribution centers, service providers, trucking companies, and railroads) who report quarterly data and participate in the mandatory, external verification programs as applicable. Federal standards would be more effective than state-specific requirements. ACC fully supports the goal of zero discharge into the environment. However, ACC opposes this proposal because it is unnecessary, vague, and would be difficult to implement. Instead, ACC supports amending the Federal Water Pollution Control Act to direct the U.S. Environmental Protection Agency to create consistent federal standards to minimize discharge. A federal approach helps ensure greater uniformity and would help prevent a fragmented landscape of state regulations. This would help ensure resources are dedicated to creating a zero-discharge system instead of navigating state-specific requirements. Again, ACC urges the committee not to move forward with the proposal in its current form. Sincerely, Adam S. Peer, Senior Director, Plastics Sustainability American Chemistry Council

Comments Document

See attachment

Comments Document

Below and attached is a comment submitted on behalf of American Bird Conservancy: Dear Committee members of the Agriculture Chesapeake and Natural Resources - Chesapeake Subcommittee, On behalf of the American Bird Conservancy (ABC), we appreciate your consideration of HB2178 and our comments regarding this legislation. ABC is a national 501(c)(3) nonprofit organization. We have offices in Marshall, VA and Washington, DC. We have 22 staff members located in Virginia. Our mission is to conserve wild birds and their habitats throughout the Americas. This includes birds and their habitats across the Commonwealth of Virginia. Plastic pollution is a pervasive problem, harming humans and wildlife. 90% of seabirds have ingested at least some form of plastic (C. Wilcox, et al., 2015). When birds ingest plastic, it can cause serious health problems, including digestive blockages, chronic inflammation, and death. Virginia is home to diverse birdlife such as swans, terns, and rails. Threatened and endangered species, such as the Red Knot, Black-capped Petrel, and Piping Plover, all depend on healthy coastal and pelagic habitats in Virginia. Plastic threatens the health of these habitats and species, warranting policy action. HB2178 is a commonsense proposal that would regulate the discharge of pre-production plastics. Stopping plastics before they enter waterways is the best way to protect birds and humans. HB2178 would accomplish this by creating a program to ensure zero discharge or release from point and nonpoint sources. Section C of HB2178 details requirements a facility would have to adopt and implement to mitigate pollution. Critically, this section would require use of continuous monitoring technology. This technology could help with enforcement and provide more data on when and where pre-production pellets are discharged. Additional best practices, such as storage, handling, and transfer guidance for plastics, detailed in section C could further protect birds and humans from plastic pollution. Thank you for considering our comments. We encourage your continued action addressing plastic pollution, which advances bird conservation and public health. Sincerely, Annie Chester Policy Director American Bird Conservancy

Plastic production is expected to triple by 2060 and without new measures in place, we can expect plastic pollution to also increase. According to an analysis of 2016 data, it is estimated that 10 trillion plastic pellets litter our oceans in a year. Once in the water, plastic pellets can also absorb toxic chemicals. These types of pollutants bioaccumulate, meaning they become more concentrated and more toxic as they move up the food chain. Plastic pellets also leach. Leachates have been shown to affect hormonal systems in both vertebrates and invertebrates which subsequently can affect reproduction, oxidative stress levels, feeding behavior, physiology as well as metabolic and immune functions. Plastic and microplastic are emerging pollutants and they are increasingly linked to public health concerns. Animals sometimes mistake plastic pellets for food, such as eggs or tadpoles. A study done in Svalbard, north of the Arctic Circle, found that 48.7 percent of the fulmars in the study had plastic pellets in their stomachs. Svalbard is far away from the plastic supply chain and highlights the far reaching consequences of plastic pellet pollution. We do not need more microplastic in our water jeopardizing our health and that of the environment. Currently, we are playing a game of whack-a-mole with citizens attempting to hold folks accountable for plastic pellet pollution. This bill is important, because it includes an actual prevention mechanism - monitoring. We support this bill and hope you will too.

Clean Fairfax hopes you will vote to advance Delegate Clark's HB 2178 bill to stop plastic pellet pollution in Virginia when it is before you this afternoon in committee. While things like plastic water bottles and plastic film and grocery bags are what we find in our streams and creeks and neighborhoods of Fairfax County--those items are relatively easy to pick up (but only WHEN they are picked up) but these little plastic pellets that MAKE water bottles and plastic bags are not. They are tiny, they easily wash into water bodies, and they are exactly what we would call litter/pollution or even hazardous waste if it was a truck overturned on the beltway spilling the oil on the way to the plastic pellet factory! This bill would require DEQ to create a set of rules and obligations for companies who transport and use these plastic pellets (aka nurdles) to ensure that said entities are responsible for keeping them from spilling and escaping into our ecosystem. We aren't able to do this for all our litter (yet, but we're working on it) but where we can, we have an obligation to do so. Thanks for your support

Clean Virginia Waterways supports Delegate Clark's HB 2178 bill to stop plastic pellet pollution in Virginia. We hope it is the will of the subcommittee to advance this important legislation. The Port of Virginia is one of the largest ports for importing and exporting plastics in the country- There are at least seven plastic production facilities operating in Virginia, and a new $34 million facility set to begin production on the Staunton River this year. The amount of plastic produced and exported from Virginia is going to increase, this has the potential to increase the amount of plastic entering Virginia’s waters. As a result, it is important to have the necessary protections in place. We know microplastics and plastic pellets are already in Virginia’s water. It’s important to take proactive measures to stop the flow of plastic into our water, not only to protect human and environmental health but also to protect Virginia’s economy. Prevention reduces the financial costs and environmental costs associated with plastic production. This bill would require DEQ to create a set of rules and obligations for companies who transport and use these plastic pellets (aka nurdles) to ensure that said entities are responsible for keeping them from spilling and escaping into our ecosystem. We aren't able to do this for all our litter and mismanaged solid waste (yet, but we're working on it) but where we can, we have an obligation to do so.

I strongly support Delegate Clark's HB 2178. Plastic Pellets represent the perfect storm of the fossil fuel / plastic industry's assault on clean air, clean water, and clean lands. The production of Plastic Pellets (nurdles) alone injects toxins into the atmosphere, while the unrestrained spilling of pellets onto our landscape and into our waterways poisons our entire ecosystem. While the longterm health effects of micro-plastics are only beginning to be understood, their presence in every organ and system in our bodies is well documented. Now is the time to act and prevent further injection of these harmful pellets into our environment. The future health of our children and grandchildren depends on your prompt action. Please vote YES on HB2178. Thank you. Very Respectfully Yours, J.F. Deppe, Citizen, Virginia Beach.

Environment Virginia supports HB2178. Plastic pellets, also called nurdles, are the building blocks of plastic manufacturing. These microplastics are made to be melted and molded into everyday plastic products, everything from milk jugs to car bumpers. At plastic factories, pellets that fall on the floor or get contaminated with dirt are sometimes washed down drains. There are at least seven facilities in Virginia that produce such plastics. Because they’re small and lightweight, plastic pellets are often spilled during transport too. Ports are another place in the supply chain that these tiny pieces of plastic end up in our environment. Once these pieces of plastic end up in our environment, they are extremely difficult to remove. They end up being mistaken for food by wildlife and become a part of our food chain. Companies shouldn’t be allowed to dump or spill plastic into our waterways. The bill stipulates zero discharge of plastic pellets in stormwater permits into water sources or land outside a facility. Importantly the bill would require measures to prevent pellet loss from any facilities that make, store, handle or transfer plastic pellets. It’s a common-sense solution to tackle an avoidable source of plastic pollution in Virginia's waterways.

• Local governments across the Commonwealth have adopted stormwater management standards that go above and beyond the state's minimum stormwater management standards. This bill would require those local governments to automatically revert to the pre-2014 standards, abandoning their 'higher standards,' resulting in worsening water quality and increasing flooding. IN ADDITION, if these local governments participate in the National Flood Insurance Program's Community Rating System, this bill reduces the flood insurance discounts for all policyholders in the community. • If passed, this bill will increase flooding in Virginia. On average, we are experiencing an 18% increase in rainfall since 2006. The data that informed the pre-2014 stormwater standards was from the 1990s. We cannot set up our communities for failure by moving backyard. The Atlas 14 update, which this state has helped finance, is within years away and will result in new stormwater standards that reflect this 18% increase. This bill moves us decades behind where we need to be. As we all know too well, flooding in Virginia causes loss of life and property. This bill will only worsen this dangerous reality. • Creating a 2-tiered system (where the Bay gets higher protections and the rest of the state doesn’t) does not make sense. Habitat, water quality, flooding risks, etc are just as important in Southern Rivers as they are elsewhere in Virginia.

Please oppose HB 2212. Do not back peddle and put in outdated regulations related to on storm water drainage. We need the best and up to date regulations and science- based for the health of the people depends on good clean drinking water. How come this weakening regulations even came up when the model for Climate Change in Central Appalachia is flooding... the likes of which we have recently seen in EKY a couple of years ago and the recent catastrophic flooding in WNC and TN with Helena. I live in SWVA and have personally and with great effort waged at least 4 rolling battles in the 1990s to keep our source of drinking water at the Flannagan Dam clean. The battles were won!! We had toxic algae bloom in the Pound River that feeds the reservoir from about 2019-2023.... We saw lax, weak enforcement from the state to get the Town Council to correct the failures of the Town of Pound's sewage treatment plant. (Our county threatened to sue and that changed everthing.) There were warning signs posted...not to get in the water. The bloom was in the Flannagan Dam too. Later it was okay to eat the fish from the reservoir but wash it with soap first. Miles of the Pound are devoid of fish and other wildlife. WOW. We have a data center that has come in nearby and more are planned along with LENOWISCO and the Gov.'s push for SMnR. Now there's talk of a land based micro reactor for Wise County that's no where else in the country. The nuclear wastes has no place to go. Is stored on site. The forever chemicals and compounds have just been discovered in Dante water from runoff from possibly a Russell County facility...they are not sure yet. People who have never raised their hands to help protect our water want to weaken current regulations---we cannot have our representatives siding with industry, corporations instead of the people and clean drinking water. There should be work to tighten down on the poisons used to grow foods instead.

I encourage you to oppose HB 2212 (O'Quinn), which would revert Virginia's stormwater management regulations to pre-2014 standards outside of the Chesapeake watershed. Much like the Chesapeake watershed, Virginia's other major watersheds contain globally significant levels of at-risk biodiversity, provide water sources for communities and agricultural production, and are increasingly at risk from development and other forms of habitat degradation. This is particularly the case for the Upper Tennessee River watershed of Southwest Virginia, where I am a resident and which contains some of North America's highest levels of at-risk freshwater biodiversity. The Clinch and Powell Rivers, in particular, are serving as critical natural assets fueling a growing tourism sector that is crucial as the region transitions away from an extractive economy. These waterways and others in Southwest Virginia are also experiencing an increased frequency and severity of floods that are putting both ecosystems and the livelihoods of human residents at risk. Protecting the aforementioned assets and ensuring that communities can develop effective long-term resiliency plans requires our stormwater regulations to be based on accurate standards built on the most current and up-to-date scientific data available. HB 2212 would roll stormwater protections back to much older, outdated standards that reflect neither the current scientific reality of effective stormwater management nor the evolving pressures that Virginia's waterways are experiencing. This bill would also create a two-tiered system of standards for the Commonwealth that would unfairly place some communities and their waterways under less-effective stormwater protections. For these reasons, I ask you to oppose this bill.

I encourage you to oppose HB 2212 (O'Quinn), which would revert Virginia's stormwater management regulations to pre-2014 standards outside of the Chesapeake watershed. Much like the Chesapeake watershed, Virginia's other major watersheds contain globally significant levels of at-risk biodiversity, provide water sources for communities and agricultural production, and are increasingly at risk from development and other forms of habitat degradation. This is particularly the case for the Upper Tennessee River watershed of Southwest Virginia, where I am a resident and which contains some of North America's highest levels of at-risk freshwater biodiversity. The Clinch and Powell Rivers, in particular, are serving as critical natural assets fueling a growing tourism sector that is crucial as the region transitions away from an extractive economy. These waterways and others in Southwest Virginia are also experiencing an increased frequency and severity of floods that are putting both ecosystems and the livelihoods of human residents at risk. Protecting the aforementioned assets and ensuring that communities can develop effective long-term resiliency plans requires our stormwater regulations to be based on accurate standards built on the most current and up-to-date scientific data available. HB 2212 would roll stormwater protections back to much older, outdated standards that reflect neither the current scientific reality of effective stormwater management nor the evolving pressures that Virginia's waterways are experiencing. This bill would also create a two-tiered system of standards for the Commonwealth that would unfairly place some communities and their waterways under less-effective stormwater protections. For these reasons, I ask you to oppose this bill.