I support the intent of this policy but think it should adjusted.

The market analysis for the proposed stormwater regulations points out that car-dependant low-density development will be incentivized over and against pedestrian-oriented high-density redevelopment by this policy. I worry that this finding is being treated as a minor bump in the way of the greater good or just a subversive tactic being employed by self-interested developers. I disagree. This is a serious matter, not only for the health of the overall watershed (not just individual sites) but carbon emissions and a host of other environmental impacts that ought to be taken into account.

There are indications that the era of sprawl, with its giant parking lots, ever-widening roadways, and large chemically-enhanced lawns, is drawing to a close. Interest in Transit-Oriented Development and finding alternatives to driving is growing. It is possible that stricter stormwater regulations will barely hurt this movement at all, but its also possible that it will nudge us over a tipping point and return us to business as usual once the economy resumes. Is this a risk we are willing to accept?

I'm dismayed that this is being treated as developers against environmentalists. We need a smart policy. Perhaps tax credits can be issued to infill redevelopment for employing BMPs. Can the regulations be written to provide stricter limits on low-density development (they are, after all, generating vehicle trips that inevitably result in need for more pavement elsewhere)? Can phosphorous levels be determined on a per-unit or per-capita basis rather than per-acre basis? There must be some creative solution out there to help stormwater management work with, rather than against, smart growth.