I am writing to express my strong support for the proposed stormwater regulation changes currently being proposed by DCR.  In my 24 years experience as a civil & environmental engineer in Virginia, I have not seen a proposed regulation that was so thoroughly and thoughtfully developed as these have been.  DCR should be commended on their open process and hands-on approach to developing and refining this critical regulation!

Although these proposed changes will not resolve the myriad of environmental problems that exist in the Chesapeake Bay, (and streams, lakes and rivers throughout Virginia), they are definitely a step in the right direction.  Based on the two design charettes and numerous informational meetings I have attended concerning the proposed Runoff Reduction Method, the new requirements will have a significant impact on the pollutant loadings from urban and suburban stormwater runoff.

I have heard comments that these regulatory changes will be too expensive and will "drive business from Virginia" (which is a comment that is made whenever ANY new regulations are proposed).  This concern is not supported by the cost impact study performed by Virginia Tech, or by actual development experience in other areas of the country that have implemented much more onerous stormwater requirements.  I just returned from a tour of urban low-impact stormwater systems in the Pacific Northwest (Portland, Seattle, Olympia) where development is thriving, even though they have much more stringent requirements for stormwater treatment that DCR is currently proposing.

I acknowledge that there will be additional capitol costs involved in implementing the proposed regulations on some sites.  However, if properly designed, many of the stormwater management practices employed will result in improved aesthetics, better site conditions, and higher property values.  The beauty of the proposed Runoff Reduction Method is the flexibility and diversity in design it allows.  This approach will encourage thoughtful, competent design and will penalize (through higher development costs) poor design, lazy engineering, and bad sites.  Isn’t that what a good regulation should do?

I urge these proposed regulatory changes be approved and put in place as soon as possible in order to keep Virginia competitive with other states (such as Maryland and North Carolina) that are moving ahead with comprehensive stormwater regulations.

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