Virginia Regulatory Town Hall
Agency
Department of Conservation and Recreation
 
Board
Virginia Soil and Water Conservation Board
 
chapter
Stormwater Management Regulations AS 9 VAC 25-870 [4 VAC 50 ‑ 60]
Action Amendments to statewide permit fee schedule and to improve the administration and implementation of fees
Stage Proposed
Comment Period Ended on 8/21/2009
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7/29/09  2:40 pm
Commenter: Matthew Snow, LEED AP

Stormwater Fees and watershed protection
 

It can be a help to reduce our stormwater runoff along with its associated nutrient pollutants and our topsoil. The fee schedule should be well thought-out to avoid it being a similar fiasco to water/sewer municipality billing. Associate the fee directly to the stormwater runoff rate (and quality) so that efforts to remediate the core issue cause an equal reduction (up to elimination) of the stormwater fees. It will be incentive to help the situation. Let's also encourage potential improvements (where available) to existing properties. If a property could mitigate runoff from themself and an adjacent property, it would be better planning to include the both and offer a mitigation bank payback based on porximity and need rather than in some remote location like sometimes happens in wetland mitigation currently. This would encourage a 'bigger picture' approach to stormwater management instead of merely trying to shuck the additional tax burden.

In addition, do not allow this fee to be used for other matters as a revenue producing tax substitute. Stormwater specific use of stormwater specific fee/tax.

Finally, please make this fee structure inclining so that there is not a large processing fee and a tiny amount actually related to runoff. When you see what has happened to water billing it has become a disincentive to conserve. (City of Richmond fees near $50 without using a drop of water: thousands of gallons more, at pennies on the gallon) If that charge equalled actual usage and still included the same cost of infrastructure per gallon of water, it would encourage conservation without adding to our costs.

If this is a worthwhile issue to tackle (and I firmly believe that it is) we should address the root cause with more carrot and less stick. (To borrow from another public commenter)

If the ongoing inspection and upkeep (as well as public awareness) can be offered through the DCR (and others) on a limited basis without charges and penalties it would encourage behavior we now know to be beneficial to our watersheds (and therefore us all).

CommentID: 9395