Our natural environment is our greatest resource in Virginia, and we require a larger view to protect it and ensure the long-term health of the Commonwealth.  At a time when society is shifting towards sensible, well planned, dense, walkable communities; these regulations will work counter to those tenets by uniformly instituting a set criteria whose net effect will be increased sprawl.  This will be detrimental to our future needs and will ultimately impact the environment to a greater degree.  Under these guidelines, we will need more land yielding less regardless of the developmental use, as higher density developments and urban infill projects will be burdened with much higher costs.  Hence, we will not be promoting what we need most.  In coming years when we are faced with much higher energy costs, this policy will only have set us back at great cost with little net benefit to our environment per dollar spent, greater infrastructure maintenance costs, and will have negatively impacted the economy of the Commonwealth.  I’m certain these regulations were drafted with good intentions, and I applaud those intentions.  However, good intentions are not enough to overcome nearsighted policy founded without holistic perspective for the net causes of our degradation of our environment. 

Let us now re-draft and adopt a broad, regionally planned approach to Virginia’s environmental problems that encompasses all land uses and sources of pollution in a sustainable way for the environment and our economy.  A state stormwater master plan that accounts for ultimate population bases and traffic corridors is essential to smart future growth, instead of these current draft regulations.  We’re not currently looking at the whole picture.  The environment, energy policy, water use, transportation, development, and the economy are all integrated, and we must have policy that provides a basis for real solutions to all that we face.  Even the non-quantitative Economic Impact Analysis 4 VAC 50-60 – VSMP Permit Regulations performed by the Virginia Department of Planning and Budget confirms the following:  “The costs for meeting the standard appear to be significant everywhere.  Thus, costs could be likely significantly reduced without significantly reducing total benefit by applying differential water quality criteria in watersheds across the state based on the relative water quality benefits that can be achieved.”  I contend we can do even better for the environment with a targeted, differential approach coupled with a better accounting for all land use pollution, and certainly at lower costs than associated with the proposed regulations.  Let’s craft guidelines that promote reductions in pollutant and degradation across the board, instead of encouraging a sprawling, unsustainable landscape.  If we work creatively, we can find a way to promote our values and our state’s economic future in concert.  We need to think bigger, smarter, and act more lightly on our earth.

J. Glenn Muckley, P.E.