Virginia Regulatory Town Hall
Agency
Department of Conservation and Recreation
 
Board
Virginia Soil and Water Conservation Board
 
chapter
Stormwater Management Regulations AS 9 VAC 25-870 [4 VAC 50 ‑ 60]
Action Amendments to statewide permit fee schedule and to improve the administration and implementation of fees
Stage Proposed
Comment Period Ended on 8/21/2009
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8/20/09  10:02 am
Commenter: Douglas Brown, Downtown Properties

Comments
 

I am in favor of using the most cost effective methods available to clean phosphorus, nitrogen and sediments from Virginia waters.

Based on the DCR presentation, Agriculture contributes 46% of pollutants to our streams but the current proposals concentrate on runoff from new development.

Pollution from urban ruoff and wastewater treatment plants are responsible for just over half the problems but nutrient removal is expensive. Since these sources require new permits and have deeper pockets they are easier to target for state regulations. Tighter controls on agricultural runoff is a cheaper way to remove nutrients but farmers typically do not have the money to do so.

However, since the goal is removal of pollutants, let's get the most bang for the buck possible. It seems to me that fees on new development to pay for reducing agricultural nutrient loads is the most cost effective method.

I am also in favor of looking at a "flush tax" to reduce wastewater treatment plant pollution.

 

CommentID: 9757