Virginia Regulatory Town Hall
Department of Conservation and Recreation
Virginia Soil and Water Conservation Board
Stormwater Management Regulations AS 9 VAC 25-870 [4 VAC 50 ‑ 60]
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.
Stage Proposed
Comment Period Ended on 8/21/2009
Previous Comment     Next Comment     Back to List of Comments
8/20/09  11:58 pm
Commenter: Carolyn Oster, PE Prime Design Engineering, P.C.

Please vote NO to Part II of the proposed Virginia Stormwater Regulations


When you vote on these regulations, please vote no to Part II, which contains proposed new technical standard that will not significantly protect the Bay. These regulations will put a tremendous burden on the development community and the State.  
For example, a component of the regulation is to reduce the phosphorus thresholds from 0.45 lb/ ac/ yr to 0.28 lb/ ac/yr. To accomplish this goal, more land will be required to construct the same site under current standards. The proposed regulations will promote sprawl by encouraging development in areas where land is more abundant. It will also increase the cost of development and hinder the State’s ability to rebound from this economic recession. Regulations requiring additional and more costly stormwater management facilities not only encumber the developer, but also the local governments and citizens who would have to maintain them. The costs of mitigation versus the benefits are nominal. 
There are more effective alternatives that would protect the Chesapeake Bay such as regulating stormwater runoff from agricultural land use. The majority of urban development constructed within the past 25 years is already served by stormwater management facilities while the majority of agricultural land is currently uncontrolled. Targeting point source pollution, such as waste water treatment plants and processing plants would also be more effective.
The Chesapeake Bay is an important natural resource that needs to be protected; therefore, the Technical Advisory Committee (TAC) needs to reconvene to examine these regulations and explore more plausible alternatives. 
CommentID: 9822