To start, I'd like to offer my full support to the amendments for the stormwater management regulations.  It is a long time coming and a huge step in the right direction.

However, I've heard much concern about the applicability of these amendments to development on prior developed lands (20% phosphorous reduction requirement) , particularly relating to the disincentive such requirements might put on the already incredibly disincentized redevelopment and infill development process.  The eating up of greenfield sites, regardless of new standards, is going to be more detrimental to overall water quality than the reuse and improvement of existing lands.  We need to ensure that these regulations are not overbearing on brownfield/grayfield developers while at the same time recognizing the diversity of redevelopment scenarios.  I'm not convinced that an infill development on prior developed lands within a downtown-urban area should have to meet the same 20% reduction as the redevelopment of a suburban strip location where asphalt removal can account for much of the reduction in phosphorous runoff.  Some sort of sliding scale system, perhaps relating to impervious ground surface area (parking lots and sidewalks) of the predevelopment site, may fit the bill.  However, I realize its not a simple problem and thus, there is no simple solution.

Regardless, these issues within the new regulations are small details within an otherwise necessary agenda.  Mitigating or eliminating pollution from the sources is many times more efficient than cleaning downstream.  These new regulations need to be adopted for the health of Virginia now and in the future.