The James River and Virginia's streams are valuable resources, yet they are degraded due to the pollution resulting from our day-to-day activities on the land.  In particular, scientists tell us that progress reducing pollution from wastewater treatment plants and agriculture has been offset by increased pollution from our rapidly expanding urban landscapes.  Unfortunately, Virginia's existing stormwater management regulations are not up to the task of stemming this growing pollution source.

In recognition of this problem, the Commonwealth of Virginia has taken appropriate action to propose new rules that require new development to meet phosphorus pollution limits and water quantity limits (the speed and volume of runoff) that are designed to protect local streams, rivers and the Chesapeake Bay. 

These amendments are based on the latest science, have faced a thorough and open public-vetting process, and are attainable on development sites based on independent engineering analysis.  The addition of new practices in these amendments, including incentives for use of Low Impact Development techniques and the flexibility to obtain pollution reductions off site, will help ensure that compliance is not cost prohibitive or a barrier to urban redevelopment and revitalization. 

We must remember that stormwater is not just an environmental problem, it is also an economic problem, threatening Virginia's seafood and tourism industries and increasing public costs for flood control, stream restoration, and drinking water.  Many communities are facing millions of dollars to fix past problems caused by inadequately managed stormwater.  It is much less expensive to avoid problems in the first place, rather than fix them after the damage is done.

Thus, I support the Virginia Department of Conservation & Recreations' proposed amendments to Virginia's stormwater management permit regulations as a balanced and equitable approach for new development to help ensure that clean water and economic development can coexist in Virginia.

Sincerely,
 

Ed Steinbeck