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Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

I am a 7th generation of waterman and I am here to support VMRC in opposition to bill HB1013 and HB390. VMRC is for fishery management. I did not get an opportunity to register as a registered speaker but if one is made available to make brief comment. Thank you

I am a 7th generation of waterman and I am here to support VMRC in opposition to bill HB1013 and HB390. VMRC is for fishery management. I did not get an opportunity to register as a registered speaker but if one is made available to make brief comment. Thank you

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Public Comment on HB 390 Madam Chair, Mr. Chair, and Members of the Committee— I submit this comment to clarify the legislative record concerning House Bill 390 and to identify unresolved constitutional, statutory, and fiscal concerns that merit careful consideration prior to enactment. HB 390 establishes a Habitat Policy Oversight Committee within the Virginia Marine Resources Commission (VMRC) to advise on policies supporting coastal resilience and habitat management. Although characterized as advisory, the bill requires VMRC and its Habitat Management Division to consider committee recommendations in decision‑making, to consult the committee on updates or revisions to policy matters, and to report how committee recommendations have informed policy and program development. Virginia law evaluates governmental structures by function rather than labels. A body that is embedded in policy consultation, consideration, and integration exercises policy influence as a matter of law. Policy formation, however, remains a function reserved to the General Assembly, and any delegation of authority must be accompanied by clear standards, limiting principles, and defined scope. VMRC is not a general environmental agency. It is a legislatively created, trust‑based body charged with stewarding fisheries and subaqueous resources pursuant to defined statutory mandates. HB 390 introduces a standing policy body focused on “habitat” without providing a clear statutory definition of that term within Title 28.2 or reconciling the committee’s role with existing fishery management law and public trust obligations. The Department of Planning and Budget’s Fiscal Impact Statement further confirms that HB 390 will increase workload for VMRC and related agencies, require no fewer than three committee meetings annually, and impose fiscal effects described as indeterminate but absorbable. The statement does not evaluate cumulative workload, opportunity cost, or the effect of these new obligations on VMRC’s core statutory duties. Before advancing HB 390, the General Assembly should clearly address on the record whether the bill authorizes policy formation rather than technical advice; how “habitat” is defined and bounded within VMRC’s authority; what standards constrain discretion; and how expanded institutional obligations align with VMRC’s trust‑based mission. Members are respectfully directed to the attached PDF, which documents the statutory, constitutional, and fiscal implications of HB 390 in greater detail and is submitted to ensure the legislative record fully reflects those concerns. Thank you for the opportunity to comment. KJH. Veteran Virginian in Virginia.

Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

James River Association supports HB599. -Eastern oysters are a keystone species essential to the overall health of the Chesapeake Bay watershed and James River estuary. In addition to filtering pollutants from the water, healthy oyster populations build reefs that boost local biodiversity and strengthen fisheries. -Establishing an oyster stock assessment will give the Commonwealth an additional tool to better understand the status of oyster populations and to improve management and restoration decision making. James River Association supports HB390. -The Marine Resources Commission plays an important role in coastal habitat management, and this bill helps establish a formal committee structure to guide the consideration and evaluation of habitat management strategies. -Formalizing this committee will create an important touchpoint for decision making that promotes healthy marine habitats and supports fisheries, tourism, and recreation.

HB52 (Bloxom) Dredge materials are a valuable natural resource that is oftentimes dumped into open waters or onto overwintering crab populations. Dredge material can play a critical role in building coastal resilience and safeguarding communities. HB52 makes it the state's policy to outline uses for and utilize this material when feasible. HB348 (McLaughlin) Virginia offers rural well testing but not for PFAS. The application of toxins to lands in rural Virginia can impact our groundwater and communities. PFAS is prevalent in biosolids that have been applied on agricultural lands around the Commonwealth and presents significant public health risks. HB348 protects rural communities, provides valuable public health information, and helps the state map PFAS contamination in groundwater. HB386 (Krizek) Codifying the Chesapeake Bay Pay‑for‑Outcomes Fund positions Virginia at the forefront of innovative, results‑driven environmental policy. It rewards verified pollution reductions rather than modeled estimates, engages the private sector and non-profits, and accelerates measurable improvements in water quality. During the pilot program, Virginia received $110 million in requests for only $20 million and awarded 9 projects, removing more than 580,000 pounds of nitrogen at just $36 per pound. Codifying the fund allows us to continue identifying and investing in cost‑effective solutions -- prioritizing projects that deliver verified outcomes, prevent pollution, and promote innovation. HB389 (Askew) Climate change is driving changes in our fisheries. HB389 directs the commission to start planning for future conditions using the great research occurring at Virginia universities. Translating that research into forward looking fisheries policy ensures that the state continues to be a leader in sustainable fisheries and aquaculture. HB390 (Askew) Virginia faces permitting challenges and opportunities as the state tries to effectively combat more intense storms, sea level rise, land subsidence, habitat loss, and erosion. To meet these challenges, HB390 reinvigorates the Habitat Policy Oversight Committee within the Virginia Marine Resources Commission (VMRC). The Committee will advise VMRC and its Habitat Management Division on habitat-related policies and activities and will support the Commonwealth’s coastal resilience efforts. HB521 (Hernandez) HB521 strengthens Virginia’s wetlands protections by moving Virginia’s “no net loss” of wetlands standard into code, requiring appropriate mitigation and establishing a stakeholder group to explore mitigation options for non-vegetated tidal wetlands, an often overlooked but essential habitat type. HB521 is a tool to meet Virginia’s wetlands goals under the newly signed Chesapeake Bay Agreement. HB599 (Simonds) An oyster stock assessment would use scientific data to estimate the abundance of oysters in Virginia’s portion of the Bay, the fraction of oysters that die each year from natural causes, and the sustainable amount of oysters that can be harvested each year while ensuring a healthy population in the Bay and its tributaries. Hb599 aids scientists, restoration groups, the oyster industry, and fishery managers in focusing restoration efforts that support positive ecological and economic outcomes.

Public Comment on HB 487 – § 28.2‑1200.1(E) I oppose HB 487 as drafted, specifically § 28.2‑1200.1(E), because it is structurally incompatible with Virginia’s constitutional public‑trust framework and cannot be cured through clarification or narrowing language alone. State‑owned bottomlands are held by the Commonwealth in trust for the people, pursuant to Article XI of the Virginia Constitution and long‑settled public‑trust doctrine. Local governments possess no inherent authority or property interest in these lands; they may act only as instrumentalities of the Commonwealth and only within powers expressly delegated in a manner consistent with fiduciary trust obligations. The Virginia Marine Resources Commission (VMRC) functions not as a discretionary landowner, but as a fiduciary trustee charged with protecting public rights in navigation, fisheries, and access. Subsection E departs from this framework by providing that certain localities “shall be deemed to hold a legal property interest” in state‑owned waters, bottoms, or subsurface soils. This language does not convey title, grant a lease, or authorize an easement through VMRC’s established statutory processes. Instead, it declares a property interest into existence by legislative fiat—without trust findings, without case‑specific review, and without meaningful judicial oversight. This approach presents multiple constitutional tensions. First, it risks reordering the beneficiaries of the public trust, elevating the operational needs of particular localities over the Commonwealth’s duty to manage these resources for the benefit of the people as a whole. Second, it bypasses VMRC’s fiduciary role by substituting a categorical legislative declaration for individualized trust analysis. Third, by insulating the deemed interest from downstream scrutiny, it functionally undermines separation‑of‑powers principles. Virginia doctrine looks to function, not labels; calling an interest “necessary” for a project does not cure a structural transfer of authority. While the provision could be cured in theory, doing so would require rewriting it into something materially different: eliminating the deemed property interest; limiting localities to eligibility to apply for a time‑limited, non‑possessory easement or lease; requiring written trust‑consistency findings by VMRC; and preserving full judicial review. Those changes would restore constitutional alignment—but they would also defeat the purpose of subsection E as drafted. Accordingly, subsection E is not merely overbroad or imprecise. It is structurally incompatible with Virginia’s public‑trust framework because it attempts to manufacture a local property interest in public‑trust resources without conveyance, findings, or review. For these reasons, I respectfully oppose HB 487. — KJH/Virginian/Veteran/In the Commonwealth

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Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

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I surveyed Diamond Back Terrapins in 2011 as a volunteer. These were greatly reduced or absent near private vacation homes. The reason was mortality. These turtles live for eighty years, so every loss is a big one. They are caught in recreational pots near vacation homes. Waterman our in the Bay will not see them in their pots, but traps in the small inlets near homes are catching enough of them to reduce their numbers or eliminate them. The bycatch reduction devices only cost a couple of dollars are are easy to install. A home with only a few pots can easily install these. It would be a great benefit to these iconic Virginia creatures.

I, including many Va watermen have received tickets from Marine Police for missing license stickers or plates on gillnet, pound net, and other gear. Almost all of the time these licenses are missing because wind and waves in bad weather have removed them. In most cases we do not fish this gear every day and when we do find a license sticker or plate missing from our gear then we have to go back to the VMRC office or Marine agent to get a duplicate. Abolishing the 24 hour period just make plain sense and is completely fair. The first violation is a Class 1 misdemeanor, a second one within 12 months is a class 3....pretty harsh. If this committee is against eliminating this regulation, then gives us 10 days.

Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

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Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

HB1013 We need to vote no. This will hurt Waterman small business and consumers of blue crabs. Please vote no. HB1396. We already spend a lot of money with state and local businesses. We do not need another cost on top of what we already spend. It cost aboutv5 grand to feed dogs every year,vet bills and equipment for the care of the dogs. That is already a lot of revenue for the state and local counties.

This bill is a common-sense approach to protect a keystone species that is in serious decline due to human activities (designated as a tier 2A species of greatest conservation need under the Virginia Wildlife Action Plan). Crab pots, both those in use and lost ghost pots, are known to entrap and drown large numbers of Diamondback terrapins. The use of By-Catch Reduction Devices (BRD's) nearly eliminates the entry of Diamondback terrapins into crab pots. BRD's are low cost devices that can easily be installed on crab pots. These brackish water turtles serve to protect the health of coastal marshes which provide significant ecosystem services for Virginians. The species is also culturally connected with the many native peoples of the coastal region of Virginia. Note that most other states require BRD's on all crab pots. The approach in this bill targets the actions and cost incurred by watermen to those areas where this species resides. One suggestion to the bill would be in addition to referencing pre-made plastic orange BRD's, VIMS has instructions on how to make your own BRD's using galvanized wire. Our calculations bring the cost to under 10 cents for each homemade BRD.

I am a 7th generation of waterman and I am here to support VMRC in opposition to bill HB1013 and HB390. VMRC is for fishery management. I did not get an opportunity to register as a registered speaker but if one is made available to make brief comment. Thank you

Speaking pertaining to bill HB1013. I have been a commercial crabber for 30 years and I can not believe there is any good science to back this bill pertaining to turtle excluders on Crabpots. This will be a terrible burden on fisherman in an already struggling industry. Please before moving this forward there needs to be some more studies done. I welcome anyone who would like to ride along with me a for a day crabbing and show proof that this not the problem that it’s being portrayed to be.

I am a 7th generation of waterman and I am here to support VMRC in opposition to bill HB1013 and HB390. VMRC is for fishery management. I did not get an opportunity to register as a registered speaker but if one is made available to make brief comment. Thank you

We must do better to protect our natural surroundings. Invasive plants are costing Virginians millions of dollars each year. These bills will help stop the spread of invasive plants across the Commonwealth by allowing regulators to add plants to the Noxious Weeds List based on merit and science, by ensuring that invasive plants are not planted along our state highways, by empowering local jurisdictions to raise funds to treat and control invasive plants, and by giving state agencies flexibility to use volunteers to help control invasive plants on state lands.

My name is Rachel Rilee, and write in strong support of HB 1013. Diamondback terrapins are one of Virginia’s most iconic salt-marsh residents and a keystone species in our coastal ecosystems. But over the last fifty years, terrapin populations have collapsed by roughly 75%, and each year an estimated 80,000 terrapins drown in blue crab traps. With more than 3 million traps deployed annually and half of them lost or abandoned, this silent, unnecessary mortality is pushing the species toward an Endangered Species Act listing. Virginia’s own 2025 Wildlife Action Plan already designates terrapins as a Species of Greatest Conservation Need. The good news is that we have a proven, inexpensive solution. Bycatch Reduction Devices, also known as Turtle Excluder Devices, prevent 94% of terrapin deaths while having minimal impact on crab harvests. They cost less than a dollar, many states distribute them for free, and crabbers who use them gain access to Seafood Watch certification that can increase the value of their catch. Our neighboring states from New York to Florida have already enacted these requirements, and the science behind them comes from right here at home at the Virginia Institute of Marine Science, the nation’s leading terrapin research center. HB 1013 would require recreational traps and commercial traps in designated Terrapin protection areas to be outfitted with bycatch reduction devices. It is a simple, science-based, inexpensive solution to a problem that will cost Chesapeake Bay one of it’s most iconic residents if it is not addressed. For terrapins, the health of the bay, and the continued sustainability of our working waterfronts, I urge you to pass HB 1013.

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Diamondback Terrapin Protection Areas; Mandatory Blue Crab Gear Regulations House Bill 1013 imposes mandatory gear requirements on recreational and commercial blue crab pots based on asserted diamondback terrapin conservation concerns. The bill does so without establishing the factual predicates necessary to justify regulation of a managed fishery, and without engaging Virginia’s established fishery management framework. At its core, HB 1013 relies on an unproven premise: that blue crab pots in Virginia waters constitute a source of terrapin “bycatch.” The bill uses the term “bycatch” as a regulatory trigger without producing Virginia‑specific, peer‑reviewed Chesapeake Bay or Commonwealth waters evidence demonstrating (1) terrapin presence in the regulated areas, (2) interaction rates with crab pots, or (3) a causal relationship between crab pot use and terrapin mortality or injury in Virginia. Absent such findings, the term “bycatch” is not descriptive—it is conclusory. This raises a threshold evidentiary question that the bill leaves unanswered: Where are the existing, identified diamondback terrapin habitats in Virginia waters that justify mandatory regulation of blue crab gear? HB 1013 authorizes the creation of “protection areas” without identifying mapped, verified, or scientifically substantiated terrapin habitat within the Commonwealth. No baseline habitat data, population assessments, or Virginia‑specific impact analysis is cited. Regulation imposed without demonstrated presence, harm, or causation converts conservation policy into speculative restriction. Although framed as wildlife conservation, the bill’s operative effect is unmistakable: it regulates blue crab fishing practices. Yet HB 1013 is not presented as fishery management legislation, does not reference existing blue crab stock management plans, and does not address interstate obligations under the Atlantic States Marine Fisheries Commission. Instead, it delegates broad discretion to the Virginia Marine Resources Commission without clear statutory standards to prevent conflict with existing fishery management authority. In a Dillon Rule state, such delegation without defined limits is especially problematic. The absence of a meaningful fiscal impact analysis compounds these defects. Virginia’s blue crab fishery is a cornerstone of the Commonwealth’s seafood economy. Mandatory gear requirements impose compliance, enforcement, and economic costs that have not been quantified, justified, or weighed against demonstrated conservation benefit. Conservation regulation must rest on documented Virginia‑specific science, clear statutory authority, and established fishery management principles. Until peer‑reviewed evidence substantiates both terrapin habitat presence and a causal bycatch relationship in Virginia waters, HB 1013 fails to meet the evidentiary threshold necessary to justify mandatory blue crab gear regulation. I am in full support of Conservation, under federal-state consistency and authorities. Not in support of co-mingling to Fishery Management: a highly regulated federal-state framework that requires very specific fishery based studies to further regulate Blue Crab. Amendment to Title 28.2 is respectfully requested to be fully reviewed under Fishery Management Federal and State frameworks, by Fishery Management first. There is no Virginia Chesapeake Bay evidentiary linked causal relationship provided to warrant amendment of Title 28.2

I urge you to support this Bill. I have researched this Bill out of concerns raised by local watermen. It seems like this Bill is science-driven and will not unfairly burden any crabbers that are in areas with low turtle populations. The crab pots in high turtle population areas should definitely have excluders but perhaps there is a grant program to help pay for it. This Bill is a reasonable approach that will conserve the terrapins while not unfairly burdening the crabbers.

Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

Vote no on this bill. I will hurt the crab industry.

I strongly oppose HB1013. This bill places additional financial burdens on Virginia’s watermen by requiring them to pay out of pocket for a “problem” that is not yet supported by sufficient, conclusive research. Our watermen already operate on narrow margins, facing rising fuel costs, regulatory pressures, and unpredictable environmental conditions. Requiring them to absorb new costs without clear, evidence-based justification is unfair and harmful to their livelihoods. Additionally, HB1013 grants the Virginia Institute of Marine Science (VIMS) broad authority to determine where designated areas will be established, with limited transparency and little meaningful input from the watermen who depend on these waters to make a living. Decisions of this magnitude should not be made without robust stakeholder engagement, clear standards, and accountability. Before imposing new mandates and expenses on working watermen, the Commonwealth should ensure that the underlying issue is well-researched, clearly defined, and broadly agreed upon by independent experts and affected stakeholders. HB1013 fails to meet that standard and risks shifting the cost of uncertainty onto those least able to bear it. For these reasons, I urge legislators to reject HB1013 and instead pursue a more collaborative, science-driven approach that protects both Virginia’s marine resources and the watermen who have long been responsible stewards of them.

I strongly oppose HB 1013- this will destroy the blue crab fishery. I'm a commercial fisherman who depends on this fishery. It's 90% of my income, I've been doing this for 40 years. Im currently a member of the crab management advisory committee. We're currently addressing this in the committee and feel that we're better suited to address it than the Virginia legislature at this time. If I am required to put these excluders in my pots I will see a big decline in catch and also the size of the crabs will be smaller and less desirable to the consumer.

I strongly object to this bill. The environmental group that has been pushing these excluders at VMRC meetings to require them in commercial and/or recreational crab pots has been unsuccessful multiple times, with no scientific data to support their claim. The impact on commercial crabbing if this bill is passed would be significant. It would sharply reduce the annual catch, cost commercial crabbers significant funds to purchase excluders, and may, in fact, put some out of business. I have spoken to many crabbers, none, including myself as a Va crabber, have never seen a terrapin on the western side of the Bay. However, some crabbers on the Va eastern shore do see an occasional terrapin in their crab pots. Specifically in the creeks and shallow waters less then 6 ft. Passing this bill would significantly reduce Virginia's commercial catch and cost watermen and our crab wholesalers/retailers' significant amounts of money.

I oppose this bill due to have never had a turtle in any of my pots in the 15 years that I've been crabbing in Virginia. This will put such a cost that will put the crab prices through the roof. On top of that it will put the commercial crabbers out of business due to cost. Virginia also would loose a ton of taxes due to sales tremendous reduction in crab sales.

I oppose this bill because in the nine years I’ve been working on the water. I’ve never had an issue nor seen turtles in my crab pots

I oppose this bill because in the 9 years I’ve been working on the water I have never seen turtles in my crab pots

I highly disagree with the turtle extruder. I have been crabbing for 15 years and have never caught a turtle. I don't know anyone personally that has caught a turtle. I believe the information that has been given is very wrong. Also the cost and th decline in catch will drastically impact or lively hood. Please do not let this bill pass

I strongly oppose hb1013 99% of the crab pots in Va are set in waters that contain no turtles that could enter a crab pot. The insert proposed is so restrictive that it would eliminate the catching of the higher more valuable jimmy crabs that people love to eat. Bills like these do not solve problems but they do make certain people/companies rich while the little man struggling to survive poorer.

Strongly oppose,

I oppose House bill 1013

Oppose I love my crabs.

Strongly oppose HB 1013 as it is a major costly investment to recreational and commercial fisherman when the state has data that doesn’t show the turtles being harmed by our means of fishing

I do not support HB1013 and I’m asking the House of Delegates to oppose this bill because I believe there is a lot of misinformation about the type of pot watermen will be used for crabbing.

I love turtle they are one of my favorite creatures. But this bill will affect the lively hood of Virginia crab fishing and would destroy the life of a watermen so I oppose this bill and please vote no.

Please vote YES on this.

I am in support of this bill.

Comments Document

On behalf of the Quiyoughcohannock and Warraskoyack Indian Tribes on the Surry Side of the James River, and as the Tribal River Keeper to the Monitor Merrimac and the Chesapeake Bay. I stand in solidarity in support of HB1013 and ask you to vote YES. It will help to preserve the sea animals not intended to be collected in crab pots. Thank you, Principal Chief of the Tribes.

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I support this bill. As all of the committee members know Blue Catfish are rapidly becoming the dominant species in Va tidal waters. Watermen have found baby crabs, soft shell crabs, speckled trout, striped bass and many other things in their stomachs. In recent months a 70 lb blue catfish was caught on a trot line at the Tappahannock bridge. VIMS studies show that on average Blue Catfish eat 5 to 9% of their body weight every day. VIMS estimates that the James River alone hold 60M lbs of these fish. A calculator can show you how much of our other food fish including menhaden that they eat. Labeling Blue Catfish fillets as Chesapeake Wild Harvest certification can only help get the public to eat more. This will also help in completion with Farm Raised Catfish sales.

Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

Please stop hound hunters right to retrieve on private property. We have multiple where incidents every year where hunting dogs attack our pets on our private property causing harm, loss of life, and vet bills. Private property should remain private year around.

Vote yes on this bill

The Virginia Department of Wildlife Resources (DWR) and their biologists have been discussing the impact of blue channel catfish in our waters including the Chesapeake Bay. These fish were introduced by the department and are a non native species in these waters. I know these fish are a source of income for sport fishing guides and Charters that target the large blue catfish. However, there is merit to opening up sustainable harvests fof local restaraunts, local fish markets and aquaculture. I support the initiatives taken by the DWR. You can get copies of the public comments on the blue catfish from the DWR from earlier this year.

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Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

Opposed to these bills

I agree woth this legislation and I hope you support it as well. As a landowner I understand the importance of protecting our wetlands, watershed, Riparian Buffer Zones, Stream Management Zones and our top soil from erosion. Under the Chesapeake Bay Act, Clean Water Act etc we have taken many measures to curb pollution of our waters due to erosion, runoff and more. This measure should also be supported in an effort to adapt to lessons learned, environmental stewardship and protection of our water.

I am asking you to vote NO on HB1396!! We do not need more restrictions on hound hunting! We already have regulations that have been set forth through the years. Adding more permits to our licenses will only make it more bureaucratic and add to the expense of hunting with hounds! It seems you are determined to remove another part of our heritage in Virginia and I see NO NEED TO FURTHER RESTRICT our right to lawfully run /hunt our hounds. I respectfully ask YOU to VOTE NO on this proposal!!

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I strongly oppose the bill Hb1369

Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

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Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries

Please support HB402. It will allow small cottage foods producers to grow reach a larger consumer base, without the need to upgrade to a commercial kitchen, which is exceedingly expensive and lots of red tape for permitting. This is also a way to make it less restrictive for anyone wanting to get started with home produced uninspected foods which will support independence and community food resilience and keep revenue cycling within the local economy.

This needs to be statewide and not just for the groundwater management area. It needs to be prohibited near watersheds, Riparian Buffer Zones, Stream Management Zone, homes using wells.

I am writing on behalf of Spotsylvania County to provide brief contextual background on HB1436 / SB617 and a narrow technical issue the County is currently encountering. In Spotsylvania County, several older industrial subdivisions were originally platted with private road systems and without access easements between individual lots and the public road network. Current development within these subdivisions complies with applicable stormwater regulations and includes execution of legally binding BMP Agreements that authorize County entry to perform maintenance in the event a property owner fails to meet their obligations. However, where no access easements exist across intervening private parcels, the County lacks a clear mechanism to physically access the stormwater facility, effectively limiting its ability to exercise existing enforcement authority. Although the BMP Agreements establish the County’s right to perform maintenance, they do not create or convey access rights across third-party parcels, and the absence of statutory entry authority post-construction limits enforceability where no easement exists. Following consultation with DEQ legislative staff on January 29, 2026, the County is requesting an amendment to the original version of the bill that does not delete any existing text, but rather expressly includes maintenance and corrective actions to the first paragraph of Sec. 62.1-44.15:39 Right of Entry. The proposed language does not alter permitting requirements, bonding provisions, or inspection authority during land-disturbing activity, and is limited solely to post-construction stormwater maintenance and enforcement. This is a technical clarification and not an expansion of government power. Clear access authority helps prevent infrastructure failure, property damage, and downstream pollution impacts. Thank you for considering this technical amendment.

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Invasives should be pulled or killed by herbicide and not be permitted to be sold in nurseries