As a citizen of Virginia, I am also deeply concerned about the Soil and Water Conservation Board’s proposed stormwater regulations. I stongly agree with others in that these unscientific, burdensome mandates will unfairly punish the commercial and residential development industry thus endangering Virginia's reputation as one of the best places in America to do business. 

 

The proposed regulations fail to address the documented major contributor to the Bay’s decline—AGRICULTURE, whether it is crops, poultry, hog, or dairy and beef cattle operations. The level of paperwork, monitoring and administration for land development is a significant component of real estate effort and pricing, yet the agricultural uses can virtually discharge fecal matter directly to a stream. These regulations place the burden on the development community to clean up the waterways after the farming community.

 

I regularly pass by farms that have livestock standing partially submerged in ponds.  Poultry manure contains large amounts of nitrogen, phosphorous, and potassium. Far larger that other agriculture and many fold more than land development. It makes no sense that the Soil and Water Conservation Board would ignore the largest, most serious polluter of the Chesapeake Bay. 

 

“While DCR data show that agricultural sources present a larger nitrogen, phosphorus and sediment runoff problem than development, the proposal offers no regulation on agricultural sources. The agribusiness community has voluntarily implemented measures to help reduce runoff pollution, but even with the voluntary measures the DCR data still show agricultural sources measuring almost three times the sediment runoff, more than twice the nitrogen runoff and almost 50 percent more phosphorus runoff than development. Therefore, the proposal should not treat the development industry as the sole cause of pollutants running into the Bay, as it does.” (Wakeland, C. Warren, HBAR Director of Government Affairs, letter dated August 10, 2009.)

 

Water quality restoration goals will not be achieved without widespread implementation of agricultural BMPs.  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.

 

I urge you vote NO on Part II of the proposed stormwater requirements and reconvene to consider a more thoughtful and effective solution.