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
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7/7/09  1:37 pm
Commenter: Wendy Hamilton, Preserve Frederick

Stormwater Regulations


Preserve Frederick urges DCR to adopt the proposed stormwater management regulations. Preserve Frederick is a non-profit organization that works to promote compatible development that strengthens our communities, protect our natural and historic resources and preserve our rural character in Frederick County, Virginia.
Preserve Frederick admires DCR’s 3-year efforts in the proposed stormwater regulations.   This process, including diverse input from all those with vested interests, resulted in a greatly improved stormwater management programPreserve Frederick  believes these proposed regulations have been thoroughly examined to ensure achievability from both an engineering and an economic perspective.
Clean water in our streams and rivers is vitally important in Frederick County.
  • The majority of Frederick County residents obtain drinking water from surface waters. Run-off from poorly-planned development makes it more expensive for localities to provide clean drinking water to citizens.
  • Healthy streams and like Cedar Creek, Opeqoun Creek and Abrams Creek, Crooked Run, Redbud Run, Stephens Run and other tributaries are all important for ensuring the quality of life of Frederick County and Winchester residents.  Recreational activities, fish and wildlife, and public health all depend on clean water in our part of the Shenandoah Valley.  We do not want to see our waterways continue to degrade.
  • Tourism is an economic driver in all of the Shenandoah Valley. Polluted runoff impacts will cause damage to the fishing and boating industry – both important to tourism.  
  • Improved stormwater management also helps recharge our groundwater (by letting the rain soak in) and prevent destructive impacts of flooding. 

Pollution from stormwater run-off must be addressed in Virginia.  We believe agriculture has made considerable progress in reducing nutrient and sediment run-off.  Similarly, some localities have achieved improvements in the quality of water that is discharged from wastewater treatment facilities. However, this progress is being offset by pollution from new development.  In fact, runoff from development is the only source of water pollution that is growing; the other sources are decreasing.   
Due to the struggling economy, land development in the Frederick County has slowed considerably in the past two years.  But, as the economy recovers, development pressure and growth will return in the near future.  It is critical that strong regulations are in place to ensure that future growth does not degrade water quality in Frederick County  for future generations. 
If adopted, Preserve Frederick believes that the new stormwater management program will be fair, effective, and achievable.  Because localities can opt to run their own programs along with current erosion and sediment control programs, streamlined planning will occur at the local level.  The proposed fee structure will ensure that localities will not be burdened should they choose to implement a local program. Finally, the proposed regulations will ensure that stormwater control costs are predictable and consistent for developers.
Preserve Frederick asks that DCR ensures that the proposed regulations do not provide incentives for new development to occur in farmland and forestland.  Redevelopment and in-fill development in town and cities, with land conservation in rural areas, will ultimately provide the best outcome for clean water as well as livable communities.   Therefore, if minor changes to the proposed regulations are necessary to encourage responsible growth patterns, we request that those changes are made prior to adopting the final regulation.
Again, we applaud the three-year effort that has led to this proposed program. And we urge DCR and the Virginia Soil and Water Conservation Board to adopt the Virginia Stormwater Management.
Wendy Hamilton, President
Preserve Frederick
PO Box 2362
Winchester, VA22645
CommentID: 9187