On behalf of the Home Builders Association of Virginia, I appreciate this opportunity to comment on this new regulatory stage related to urban stormwater runoff. As stated in the NOIRA, EPA has released new data demonstrating that Virginia is within 1% of its target loads of Nitrogen, Phosphorous and Sediment. As a result adjustments are needed in the recently adopted stormwater regulation.

The recently adopted regulations were predicated on older data from EPA indicating that the Commonwealth had much further to go in order to reach the goals set out in the last round of allocations for the Chesapeake Bay.  Recognizing that the old data that lead to the creation of the entire regulation adopted on December 9th, it is the request of HBAV that this NOIRA be interpreted broadly to include detailed reveiew of all of the contents of Part II of the Stormwater Regulation.

This review should include a review of the grandfathering provisions, the off-site credit purchase programs, and the method by which stormwater is calculated, in addition reacting to the new numerical targets established by the EPA. 

Recognizing that much work has gone into this regulation, HBAV is prepared to provide as much pertinent and thorough information as needed by the Soil and Water Conservation Board to create a regulation that is both good for the environment and directs resources in the most efficient and effective manner possible.

Best regards,

Barrett Hardiman

Vice President of Regulatory Affairs