At a minimum I would recommend that we do not enact the technical criteria, Part II of the regulations until such time as a more in depth economic impact analysis can be performed, the BMP Clearinghouse issues are resolved and the criteria significantly modified to ensure a balance between the health of the bay and our state’s economic future. The Board and DCR should re-convene the Technical Advisory Committee (TAC) and allow all of the stakeholders to provide input and have their concerns addressed.
Sincerely,
Shawn A. Smith, P.E.