To The Department of Environmental Protection
March 4, 1996
The Honorable Secretary James M. Seif
PA Department of Environmental Protection
P.O. Box 2063
Harrisburg, PA 17105-2063
Dear Secretary Seif:
The members of the Agricultural
Advisory Board would like to express their appreciation and commend
the Department of Environmental Protection for its new wetland
initiatives, as outlined by Fran Koch, Bureau of Dams, Waterways
and Wetlands, at the Boards February 21, 1996 meeting. The Board
members believe that these wetland initiatives will make it easier
for the regulated community to understand and comply with the
regulations and policies that govern wetland areas. Many of the
Department's wetland initiatives such as the creation of the Wetlands
Replacement Registry; Advance Wetland Compensation/Banking, and
the State Programmatic General Permit address many of the recommendations
made by the Board in its Wetlands Protection Resolution of October
19, 1994.
The Board did however express
concern over why the Department choose to set the small (de minimus)
wetlands impact level, which does not require replacement, at
1/20 of an acre (2,178 square feet) rather than five acres as
the Board recommended in its Wetlands Protection Resolution.
The Board members also felt that wetland qualities and values
should have more importance than wetland size in determining whether
a wetland impact should require replacement. The Board members
voted unanimously at the February 21, 1996 meeting to reaffirm
to the Department its recommendations contained in its Wetlands
Protection Resolution (copy enclosed), with emphasis on the recommendation
that the minimum size wetland impact requiring replacement be
established at five acres within the Commonwealth of Pennsylvania.
The members of the Agricultural
Advisory Board would also like to refer this recommendation to
the newly created Wetlands Management Advisory Committee to the
Department of Environmental Protection. The Board members would
also welcome the opportunity to discuss this concern with representatives
of the Department at a future Board meeting. If I may be of any
further assistance please contact me at (717) 561-7200.
Sincerely,
Robert Junk
Chairperson
Agricultural Advisory Board