My name is Steve Lawson, and as a citizen of the Commonwealth and a builder of affordable housing, I am concerned that the technical mandates in the proposed stormwater regulations would affect our ability to build housing that is affordable to Virginians.  Furthermore, this would impair the ability all Virginia businesses to compete in the global and national marketplace and endanger Virginia's reputation as one of the best places in America to do business.

When you vote on these regulations, we encourage you to vote no on Part II, which contains the proposed new technical standards, and reconvene the Technical Advisory Committee (TAC) to continue work on these requirements and consider alternative regulatory arrangements.

Pleaes consider the following:

• These regulations are the least efficient way to address pollutant removal in the bay. The cost of mitigation versus the benefits realized has been determined to be "significant" according to the Department of Planning and Budget.

• These proposed regulations will promote sprawl by requiring more land to be used to meet the same demand for commercial and industrial floorspace and residential units.

• During the recent TAC process, stakeholders were told that the technical requirements were "off limits," many stakeholders had and still have concerns that have not been adequately addressed or even addressed at all.

• During the Board's September 2008, public hearing, six of the nine TAC members who spoke asked you to hold off on Part II. There is hardly consensus on this issue.

• There are alternatives that would do more to help the Chesapeake Bay at less financial and environmental cost to Virginia. These alternatives deserve a full vetting by a reconvened TAC.

By promoting sprawl, these proposed regulations will make it much tougher build the town center and village style projects that characterize smart growth and are envisioned in state law.  Thank you for your consideration.