The proposed water quality and water quantity requirements would be very expensive to implement.  The examples relied upon by the agency to suggest that impementation costs would only be moderate are not representative of the wide range of real world examples. Some examples that have been studied have shown stormwater costs increasing by 10 times or more.  Such costs would significantly affect Virginia's ability to remain a leader in business climate and will affect economic development efforts.  Concerns of many expert members of the Technical Advisory Committee on the cost issue and other issues relating to the science underlying the regulations have not been addressed.

Protecting the water quality of the Bay is a very worthy goal, but these regulations do little to accomplish that goal.  The regulations would apply statewide. Yet almost 1/2 of the state does not even drain into the Bay.  Another 1/4 of the state (James River and York River watersheds) drain into the lower part of the Bay where the phosphorus load has not been extreme.  The agency's own documents recognize that these two watersheds have only "slight" influence on the overall health of the Bay anfd "virtually none" on the critical upper part of the Bay  (north of the Potomac) in which the dissolved oxygen levels are of real concern.  How can one claim that these regulations are addressing the Bay's health when so much of the proposed limitation on phosphorus is an area which has almost no impact on the Bay?

If we really want to deal with the health of the Bay, these regulations need to be completely reworked so that a workable, cost-effective solution can be found that is part of an integrated and balanced approach to point source pollution, agricultural runoff, runoff from lawns, and stormwater.