The changes are a drastic departure from the existing regulations in both methodology and detail. I will limit my comments to three points:

1.       Perhaps I did not see it, but will there be any exemptions or modifications to the phosphorus removal requirements for project that discharge to combined sewers as exist in the current regulations?

2.       The proposed regulations discourage redevelopment of existing sites in urban areas. A proposed site, such as in the City of Richmond, that is currently 100% impervious and in the proposed development will be 90% impervious, is required to achieve the same phosphorus removal as a greenfield site.

3.       The recommended BMPs are an improvement over the existing BMPs in the regulations, but they need to address minor innovations in modifying the measures. For example, I tried to use bioretention with a storage pipe manifold underneath and was told by the reviewer that he “had never seen it before and wouldn’t allow it.”