• DCR has taken it upon themselves to create regulation without substantiating legislation.  This should be carefully considered by the board when implementing this or any regulatory requirements.
• The histroy of pollutant removal from stromwater that eminates from land development has a long historical background.  When the CBPA regulations were implemented in the early 1990's, the bureaucrat's contended that the 0.45 default standard would more than adequately address the runoff that was promulgated by land development of all types.(residential, commercial and industrial).  It was premised with the fact that the Commonwealth was doing more than just placing a burden on development.  It was stated that treatment plants, agricultural activities, processing plants etc. were all being charged with "cleaning up their act" in order to clean up the Bay, rivers and streams.
• It appears by this new regulation that they bureaucrats feel they were wrong in their determinations.  THEY WERE NOT WRONG!  the problem is that many of the other sanctions that were to be put in place, especially agricultural runoff, have continued with relatively small abatement.
• A microcosm of this entire situation is the upper Swift Creek drainage basin in Chesterfield County.  The 0.45 reuirement in that basin was shown to be working well.  However, this was not good enough for the spirited group of folks that wanted to have the Swift Creek Resevoir be like a pristine lake in the north woods of Canada.  Therefore a harsher standard was imposed on the residential development in the basin of 0.22 default while the o.45 default was kept for commercial and industrial projects.  Seven to eight years later, the activist groups tried to get the County fathers to make these default discharge requirements more restrictive.  Solid technical data was provided by cooler heads that showed that the Resevoir was improving in quality with the present regulations.  The point here is that once you get a foot in the door, it is very difficult to close the door but very easy to further pry it open.
• These new regulations will spawn additonal development sprawl throughour the Commonwealth.  The economic ability to develop "in-fill" parcels will be stifled. 
• Industrial users will go to other States in order to avoid this boondoggle.
• The less talked about, but just as impacting requirement for quantity control will take huge amounts of space within commercial and industrial projects.
• Best Management Practices will become an economic burden to the localities that maintain these BMP's in residential areas without providing significant additional protection to the watercourses.

The proposed changes should be rejected.  DCR needs to work toward enforcing the regulations that are on the books not create new ones.  If this is done on a Statewide basis, the development community will be doing more than their part in helping to preserve the Bay and watercourses in the Commonwealth.