The Shenandoah Valley Network strongly encourages DCR to adopt the proposed stormwater management regulations.  Shenandoah Valley Network is a non-profit conservation program linking community groups working on land protection, land use and transportation issues in the northern Shenandoah Valley. 

Effective 3-Year Planning Process

We applaud DCR for the three-year effort that has culminated in the proposed stormwater regulations.   This inclusive process, with representation from conservation groups, the building industry, local elected officials, and government agencies, resulted in a vastly improved stormwater management program.  We believe the proposed regulations have been properly vetted to ensure that they are achievable from both an engineering and an economic perspective.

Communities Value Clean Water

Clean water in our streams and rivers is important to communities in the Shenandoah Valley.

• The majority of Shenandoah Valley residents obtain drinking water from surface waters. Run-off from poorly-planned development makes it more expensive for localities to provide clean drinking water to citizens.
• Healthy streams and rivers are important for the quality of life of Valley residents.  Recreational activities, fish and wildlife, and public health all depend on clean water in the Valley. We do not want to see our fishing streams continue to degrade.
• Tourism is an economic driver in many Shenandoah Valley communities.  Two popular draws to the Valley-- fishing and boating—are impacted by water pollution.  
• Improved stormwater management also helps recharge our groundwater (by letting the rain soak in) and prevent destructive impacts of flooding. 
  

Urgency of Action on Stormwater

Pollution from stormwater run-off must be addressed in Virginia. As the chart below illustrates, efforts to improve water quality in streams and rivers in the Chesapeake Bay watershed since 2000 are falling short because of increased run-off from developed lands.  Agriculture has made considerable progress in reducing nutrient and sediment run-off.  Similarly, localities have achieved substantial improvements in the quality of water that is discharged from wastewater treatment facilities. However, this progress is being offset by pollution from new development.  In fact, runoff from development is the only source of water pollution that is growing; the other sources are decreasing.   

Source: 2006 Chesapeake Bay Program Office (See EPA’s 2007 Report Development Growth Outpacing Progress in Watershed Efforts to Restore the Chesapeake Bay http://www.epa.gov/oig/reports/2007/20070910-2007-P-00031.pdf)

Land development in the Shenandoah Valley has slowed considerably in the past two years. However, it is likely that development pressure and growth will return in the near future.  It is critical that strong regulations are in place to ensure that future growth does not degrade our water quality.

Well-designed Program Will Achieve Results

If adopted, we believe that the new stormwater management program will be fair, effective, and achievable.  Because localities can opt to run their own programs along with current erosion and sediment control programs, streamlined planning will occur at the local level.  The proposed fee structure will ensure that localities will not be burdened should they choose to implement a local program. Finally, the proposed regulations will ensure that stormwater control costs are predictable and consistent for developers.

Please Consider Impact on Growth Patterns

We ask DCR to ensure that the proposed regulation does not provide incentives for new development to occur in farmland and forestland.  Redevelopment and in-fill development in town and cities, with land conservation in rural areas, will ultimately provide the best outcome for clean water as well as livable communities.   Therefore, if minor changes to the proposed regulations are necessary to encourage responsible growth patterns, we request that those changes are made prior to adopting the final regulation.

Again, we applaud the three-year effort that has led to this proposed program. And we urge DCR and the Virginia Soil and Water Conservation Board to adopt the Virginia Stormwater Management Regulations. 

Kate Giese Wofford, Shenandoah Valley Network

http://www.svnva.org