As a grassroots watershed stewardship group whose 300 members live along the Holmes/Tripps/Cameron Run RPA between the City of Falls Church, eastern Fairfax County and the City of Alexandria, the Friends of Holmes Run strongly opposes the petition to change the definition of a nontidal wetland. The CBPA was created as a regional commitment to protect our local waterways and, by extension, our communities, local and regional wildlife, fisheries and drinking water. Thanks to the foresight of a generation ago, the RPAs are still hanging on and, in an increasingly urban context, form the primary backstop for preventing hundreds of thousands of private properties and public infrastructure from flooding. The importance of RPAs within any given community cannot be overstated. For ex., a single 2,000-foot length of the upper Holmes Run RPA in east Fairfax County,  has kept two neighborhoods of low-lying properties adjoining the RPA from flooding during innumerable rainstorms as water is able  to spread out across the floodplain. From our perspective, it is best not to dicker with success.  

 

The Sackett decision left the regulatory definition of what constitutes "nontidal wetlands" unchanged, and specifically addressed a matter of federal jurisdiction. The petition to rewrite the CBPA's definition of nontidal wetlands is therefore unwarranted, and would undermine the ability of already beleaguered RPAs  to (1) perform their biological and stormwater functions as intended, and (2) be administered by local jurisdictions as authorized under the CBPA. Thank you for your attention.