Proposed Virginia Stormwater Regulations (4 VAC 50-60).
Mr. Joe Maroon, Director
Department of Conservation and Recreation
203 Governor Street
Richmond, Virginia 23219
Dear Mr. Maroon:
As a regulated business owner in Virginia and a member of the building and development industry in south Hampton Roads, I appreciate the opportunity to provide my input to the Soil and Water Conservation Board on the proposed Virginia Stormwater Regulations (4 VAC 50-60). We have been the leading industry in implementing the Chesapeake Bay Preservation Act over the last 20 years by establishing acres of buffer areas and BMPs that serve to remove pollutants from stormwater before it enters the Bay.
I am greatly concerned about the proposed regulations. The new technical quality and quantity standards create an undue burden on new development and redevelopment with only minimal benefits provided to the overall environment. Since new development is less than 1 percent of the overall contribution of nutrients to the Bay, I ask that you place more resources into efficient measures that can be used address nutrient and sediment loads from Waste Water Treatment Plants, Agriculture and existing development. I urge the Department and the Soil and Water Conservation Board to find reasonable and cost effective ways to clean the Bay and firmly believe that all segments of our population must do their fair share to meet these goals.
I would also ask that the regulations include “grandfathering” or vesting provisions. I urge you to include significant protections for projects with submitted preliminary plans. This will provide assurance to developers, builders, engineers, local governments and financiers as projects move forward.
I support the concept that has been proposed by the Home Builders Association of Virginia (HBAV), which allows for the purchase of offset credits to comply with an appropriate water quality standard. I think it will create better water quality in the Bay faster and more efficiently than the proposed regulations.
I urge the Board to reject Parts I, II and II of the proposed regulations and develop a smart, comprehensive plan that makes better use of the resources available to provide a clean and safe Chesapeake Bay. Thank you again for the opportunity to comment.