The proposed amendments to Part II of Virginia’s stormwater regulations conflict with a number of areas where commercial, residential, and industrial development professionals have made progress towards building more sustainable communities, and increasing the economic development potential of our state.  I believe the technical regulations as written, will actually discourage re-development within and around existing infrastructure and encourage sprawl.  Specifically I'm concerned abuot the following regulation changes:

• The regulations call for a statewide phosphorus standard of 0.28 lb/ac/yr.  This is an across the board standard making it far more onerous to create any places of high density or imperviousness.
• The regulations call for retention standards of 1” of runoff (90% of storms) versus the current 1/2” of runoff (75%), mandating more open wet and dry ponds that are counterproductive in creating walk able places.
• The regulations allow the localities to NOT use some of the toolbox options recommended by the state, such as cisterns, green roofs, etc.  This is likely to happen because they don’t want to be directly responsible for the many thousands of BMPs that these regulations would require.
• The regulations consider any conversion of woods to parks, ball fields, yards, and open spaces, to be “managed turf”.  These managed turf areas will be deemed to be between 20-25% impervious, requiring more BMPs just for them, thus making it more expensive to develop.
• The regulations ignore that a majority of the phosphorus delivered to the Chesapeake Bay is from agricultural uses.