Commenter:
Steven Pandish, LEED AP, William H. Gordon Associates
The complexity/unknown associated costs may be the greatest impediment to an effective program
As a citizen of the Commonwealth and as a member of the engineering community, I endorse the effort to improve water quality and recognize the need to effectively balance regulations to facilitate that goal. I also recognize, if properly applied, new regulations may further advance this goal. Conversely if the regulations result in disproportionate and unknown burdens on stakeholders with too much complexity, the over arching goal of improving water quality may be compromised. It is in this context the following is offered.
The economic analysis prepared by Virginia Tech for the Virginia Department of Conservation and Recreation in the report entitled “Economic Impact Analysis of Revisions to the Virginia Stormwater Regulation, Final Report”, dated December 31, 2008 established that the cost to the state is unreliable and that the cost could not be estimated, in part because of the complexity of the regulations.
“ ….no comprehensive cost estimate of the proposed regulatory change could be produced.” (Reference: Final Report, Page 7)
“… complexity of the application of technical requirements make estimation of total state costs unreliable.” (Reference: Final Report, Page 12-13)
“…The total incremental costs to the state of implementing additional stormwater control practices to meet the proposed regulatory changes could not be estimated at this time.” (Reference: Final Report, Page 40)
The level of complexity and currently unknown associated costs may be the greatest impediment to an effective program. These are not isolated concerns and are being expressed at all levels. The economic impact of the proposed regulations must be understood, especially in consideration of the current economic challenges in the state. It is incumbent that a deep breadth is taken, stepping back to ensure we are moving in the right direction to achieve our goals.
