I write to register my concern that the March 11, 2024 Petition to the State Water Control Board for Establishment of a Regulation or Policy Interpreting the Definition of Nontidal Wetlands is requesting an unnecessary and damaging change to current structures and processes that are in place and relied upon for regulating RPA land in a fair and equitable manner. The court did not address, much less alter, the definition of non tidal wetlands in the referenced court case and so, as I understand, has provided no basis to require local jurisdictions to change the definition or how the CBPA informs local decision making. The CBPA framework for determining which waters and wetlands must be protected under the RPA designation is well established, locally-responsive, and iterative. Further, DEQ provides sufficient technical support to assist localities. Please deny this petition.