|Action||Amend Parts I, II, and III of the Virginia Stormwater Management Program Permit Regulations to address water quality and quantity and local stormwater management program criteria.|
|Comment Period||Ends 8/21/2009|
Members of the Board:
I served on one of the Technical Advisory Committees that met this time last year to vet the proposed regulation changes. The regulations you have before you are substantially the same regulations that a large number of the members of our TAC agreed were not workable.
On their face, the proposed modifications to the stormwater regulations sound good. Who wouldn't want cleaner rivers and a healthier Chesapeake Bay? But in practice, the regulations discourage urban infill and redevelopment and encourage suburban sprawl. They DO NOT solve the problem. In reading through previous comments I see that you have already been provided with refrerences to the science produced by multiple esteemed research institutions and engineering firms that supports what I write, so I will not reiterate it here. But I do ask you to take note, or even a tally, of the number of engineers and other professionals who comment on the regulations. Notice that they overwhelmingly urge you to vote NO to the regulations. These are the people who understand the science behind keeping our streams clean. Please trust their well informed advice.
In reading the comments, you have probably noticed that nearly all of the comments written in support of the regulations are very general, and all they want is clean water. You will find no argument from me there. As with many things, the devil is in the details. The advocates of these regulations, by and large, do not seem to actually understand the regulations or their impacts. They simply want more regulation because they assume that the proposed regulations will fix the problem. We all want a cleaner Bay. The question is at what cost? And, even if the cost is high, shouldn't we still reduce the nutrient load contributed to the Bay in the most effective and efficient way? The proposed regulations, as written, are neither efficient nor effective. I am hopeful that you have seen the studies that clearly show that the proposed regulations will not even put a dent in the amount of nutrients that need to be removed from stormwater to meet the EPA mandate. The regulations have entirely the wrong focus. If passed as proposed, these regulations will be a terrible beaurocratic bondoggle.
There are better ways to reduce stormwater impacts on our rivers and the Bay. Please vote "NO" to the regulations as written and reconvene the TAC so that we may come up with a better, more effective plan that does much more to save the Bay than the proposed regulations would.