As a Certified Land Disturber working for a developer and builder in the central Virginia area I have seen the run off created by new development and it can be devastating. Especially during sudden heavy rainstorms and when soil conservation methods are not in place and maintained. Having said that, I believe the proposal set forth by the DCR goes too far to fast for the community as a whole to absorb. The imposition of strict regulations will slow growth until a way around that regulation is found and then the regulation will be ignored. I would rather see stricter enforcement of the existing erosion controls. If the procedures I learned as a Certified Land Disturber are practiced, maintained and enforced with penalties strong enough to make it less expensive to maintain the to let lapse, this would stop the real problem with modern day development which is sudden run off of poorly maintain erosion control systems.

  I also believe my experience as a sportsman and waterman has given me insight to the other major problem with waste water run off and that is over fertilation of our farmlands and deforestation of our woodlands. The DCR must amend its policies to include these areas of concern along with surface water run off from our road ways and cities. A fair and balance approach is what is needed to get everyone committed to this effort.

  Please follow the HBAR recommendations to reconvene the committee and restructure these regulations to be more realistic and address the whole situation and not just one sector.