Dear NHSA Members,
We presented two position letters this week and continue to monitor a number of issues.
SB-417 sponsored by Senate Martha Fuller-Clark clarifies the CSPA “no cut” or perpetual “maintenance” issue in the 50 ft Waterfront Buffer when seeking permits for impervious surfaces over 20% within 250 ft of the water. This hearing was postponed, although we had a good showing of interested parties. We will update the website once the new hearing has been scheduled.
SB-352 sponsored by Senate Martha Fuller-Clark changes the appeal process under the CSPA to the Wetlands Council and changes the appeal hearings from “non-evidentiary” to “evidentiary”. Both of these changes seem to make sense and alleviate a few procedural issues that could arise in the appeals process. We supported this bill. Click here to see the NHSA position. There may be some other issues to consider so we continue to monitor this bill.
Env-Wq 1400 Rules - The new CSPA rules public hearing was on Wednesday and there was a good turn-out. DES took time to answer questions and provide comments which is unique at a rules hearing but was well received. We had a number of members present their opinions and Paul Goodwin presented the NHSA input. Click here to see the NHSA position.
As always, we encourage you to provide input to this process. The rules comment period remains open until Jan. 28, 2008 so get your comments in soon!
We have heard from a number of you and note a few issues to consider under the proposed Env-Wq 1400 CSPA Rules:
- We believe that the State CSPA permit process should proceed before the local permit process. In speaking with a number of local officials, this seems to be their opinion also. The proposed rules require the local permit be received before submitting a CSPA permit application to NHDES. Please consider this issue and forward your thoughts on proposed rule Env-Wq 1406.11(a) .
- We do not believe there is any reason to include a “tree inventory” with permits for projects which are local only in nature, or do not include work in the 50 ft Waterfront Buffer area. This is a potentially large expense that does not provide any information that would need to be reviewed if there is no work proposed in this area. Please consider this issue and forward your thoughts on proposed rules Env-Wq 1406.08(k) and 1411.01(a).
You can forward your comments direct to NH DES: DES Rules Contact Information Page
CSPA RSA-483-B Summary of Changes effective 4/1/08.
Remember, comments must be received prior to Jan. 28, 2008.
As always, we appreciate your support and encourage you to get involved. Feel free to e-mail the Board if you have any questions or comments. Click here for E-mail and contact information.
Board of Directors
NH Shorefront Association