Comments on the Proposed Stormwater Regulations    July 17, 2009

I am a resident of Stafford County, and I have seen red mud in the middle of one of our roads that was so thick that a bulldozer had to clear the road to let cars use it. This was runoff from a residential building site. And even after the construction was finished, when there is rain, the pollution runoff piles up in the concrete ditches or flumes next to the site.

We have made progress in reducing pollution from two of the three major sources of pollution in our waterways-waste discharges and agricultural runoff.

In Stafford, our two sewerage treatment plants have taken on debt of over 30 million dollars to upgrade our plants to the maximum limits that current technology allows.  This is being paid for by state taxpayers through grants and by local utility ratepayers through increases in their bills.

Individual homeowners are required to pump their septic tanks every five years and to pay the bill for this.

Our Soil and Water Conservation District toils endlessly to sign farmers onto various programs.  State funding has been allocated to agricultural BMPs.  All programs require some contribution by the farmer.  It is true that participation by the agricultural community has been voluntary.  But, remember, the profit margins of farmers are far less generous than the profit margins of builders; farmers can’t pass the bill on to their cattle.

The stormwater legislation proposed by DCR is the first serious attempt to address the regulation of the third source of pollution-runoff from urban and suburban sites which has increased as development has increased throughout the Commonwealth. The EPA Chesapeake Bay Program Office estimates that almost one third of the phosphorus and sediment loads to the Bay watershed are attributed to urban and suburban sources.

ALL who produce sources of pollution must do their part to achieve Virginia’s water quality goals. They must do it EVERYWHERE, ALL THE TIME, in EVERYTHING they do.

In the interest of fair play, I ask that you review the exemption of local government and and state government. And, please require the localities to enforce the Erosion and Sedimentation laws and the Ches Bay laws.

Thank you DCR for your work on these regulations:  the time you were willing to commit, the stakeholders your were willing to assemble, the science you were willing to seek out, and the citizens’ voices you are willing to hear.

Our waters are public assets and you are the agency that we rely on to protect the public.

Rebecca Reed, 223 Butler Rd., Falmouth VA, 22405   rlreed@bigplanet.com