|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.|
|Comment Period||Ends 8/21/2009|
I think the revised stormwater regulations are cause for great concern among not only the business community but a hugh concern for all Virginians. These proposed regulations create an undue burden on new development and redevelopment with minimal benefits to the Chesapeake Bay, these cost burdens will be transferred to the public sector as all costs of business are. I think everybody understands the need to preserve and protect the Bay, however, these proposed regulations are a concern. 1) The standards as written do not appear to regard relative costs and financial impacts to the overall economy, preliminary engineering studies show the cost will increase by 3 to 20 times, which increases the land requriements making the project economically infeasible. 2) The revisions make redevelopment more challenging & new development land intensive & expensive which promotes sprawling development that was sought to be discouraged by the House Bill 3202 in 2007. 3) Water quality improvements based on these new regulations are unknown. 4) Scientific studies indicate the largest contributors of phosphorus runoff into the Bay is agricultural. There is currently no state mandate requiring any regulation on agricultural runoff. It is irresponsible to ignore the largest contributor while imposing strict regulations on a much smaller contributor, especially considering the enormous economic toll to the whole Commonwealth.
These regulations will hinder business relocation and expansion efforts while providing little benefit to the health and prosperity of the Chesapeake Bay. Impacts of this magnitude warrant proper time, input and study by all sectors of the community. I respectfully submit that more time is needed to evaluate a series of potential solutions with true input from all sectors with scientific and economic data to support a unified cost-effective solution, and encourage you to NOT enact the stormwater regulations as they are currently written.
Brenda K. Samuel