The NHTOA has prepared a list of talking points for people who plan to attend any of the public hearings the New Hampshire Department of Environmental Services (NHDES) has scheduled to hear testimony on NHDES’s second draft of wetlands rules. 

The new draft rules contain both good and bad news for landowners, loggers, and foresters. It appears the NHDES heard the NHTOA’s concerns earlier this year about the first draft of wetlands rules, and the new draft is an improvement from the January draft. However, sections of the rules are still very confusing to navigate, with multiple cross-references and apparent incorrect cross-references. Moreover, the new draft rules do not improve the current wetland rules (i.e. no crossing dimensions or other standards were modified), and there are several new definitions that appear to extend the regulatory authority of the rules into other areas beyond water quality (e.g. wildlife).

At the public hearings (the schedule appears below), it will be important to emphasize that:

  • The rules need to include a separate forest management section.
  • The rules need to clarify that corduroy is not “fill.” 
  • Economic and management impacts need to be quantified.
  • Permit review timelines need to be defined.
  • Administrative burdens should not be shifted on to land managers. 

The full text of the NHTOA talking points is available here. 

We urge our members to attend one or more of the seven public hearings on the second draft that NHDES has scheduled from Dec. 3rd through the 13th.  Here are dates, times, and locations:

  • Monday, Dec. 3, 2018: NHDES Headquarters, Room 208C, 29 Hazen Drive, Concord, N.H. 2:00 – 4:00 p.m.
  • Monday, Dec. 3, 2018: NHDES Headquarters, Room 208C, 29 Hazen Drive, Concord, N.H. 6:00 – 8:00 p.m.
  • Tuesday, Dec. 4, 2018: Keene Parks and Recreation Center, 312 Washington St., Keene, N.H. 6:00 – 8:00 p.m.
  • Thursday, Dec. 6, 2018: Laconia City Hall, 45 Beacon St. East, Laconia, N.H. 6:30 – 8:30 p.m.
  • Tuesday, Dec. 11, 2018: North Country Resource Center, 629B Main St., Lancaster, N.H. 5:30 – 7:30 p.m.
  • Thursday, Dec. 13, 2018: NHDES Pease Field Office, Room A, 222 International Dr., Suite 175, Portsmouth, N.H. 2:00 – 4:00 p.m.
  • Thursday, Dec. 13, 2018: NHDES Pease Field Office, Room A, 222 International Dr., Suite 175, Portsmouth, N.H. 6:30 – 8:30 p.m.