PWCA Comments on the Fairfax Water Authority Occoquan Reservoir Shoreline Easement Policy Update

Fairfax Water Authority is holding a public hearing for the draft changes to their Shoreline Easement Policy on Thursday, February 3, 6:30 pm at the Fairfax Water Board Room, 8570 Executive Park Avenue, Fairfax. Email written comments to ShorelinePolicy@fairfaxwater.org by February 2.

The Prince William Conservation Alliance strongly supports efforts to protect clean drinking water in the Occoquan Reservoir. The proposed changes to Fairfax Water Authority’s Shoreline Easement Policy emphasize opportunities to prevent damages, avoid costly mitigation needs and benefit all Fairfax Water Authority ratepayers.

The increased standards proposed in the update represent a positive step forward. However, we believe additional efforts to establish specific standards for restoration following disruption (willful violation) of the easement would significantly improve Fairfax Water Authority capacity to implement the policy in a fair and consistent manner.

The policy should be specific regarding both prohibited activities as well as standards for restoration where violations occur. Mitigation requirements for violations involving shoreline alteration, including filling (soil and other), surface alteration (mulch and other), and the removal of vegetation should be clearly described.

An updated policy should clearly establish minimum restoration standards that consider both the extent and long-term viability of restoration activities. In particular, the policy should include specific information on the minimum restoration standards for violations, including:

  • Removal of added fill or non compliant structures from the easement (soil, and other).
  • Stabilization of shoreline where disturbed.
  • Mulch cover removed to permit re-growth of vegetation
  • Native grasses restored, allowed to grow without mowing.
  • Replacement of removed trees with appropriate species and size, such as standards that establish a relationship between the equivalent calibers of removed trees and replacement trees.
  • Restoration of shrub (non-tree  woody plants) with comparable native woody plants
  • Scheduled Inspection of restoration sites for consistency with standards, and determination of viability for 2 years after restoration.
  • Penalties where mitigation cannot be complete.
  • Dedication of revenue from penalties for shoreline protection activities.

The Prince William Conservation Alliance supports Fairfax Water Authority efforts to preserve clean drinking water resources, protect ratepayer funds, and help ensure a sustainable future for Northern Virginia communities. Thank you for the opportunity to comment on the 2011 Update to the Fairfax Water Authority Shoreline Easement Policy.

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