Community Alliance for Preservation (CAP), based in Rockingham County, strongly encourages the adoption of Virginia’s  proposed stormwater management regulations. CAP is a nonprofit organization that works to increase citizen involvement in Rockingham County and the City of Harrisonburg in land use issues, land conservation programs and transportation planning to retain our rural heritage and build and sustain livable communities.

Farmers in Rockingham County and across the Commonwealth have been making strides to reduce the impact of agriculture on local streams and rivers. These voluntary measures, such as fencing cattle out of waterways, are having an impact.  Significant progress has been made toward reducing the nutrients and sediment that come from farms and ranches within the Chesapeake Bay Watershed.

Likewise, municipal wastewater treatment plants have been reducing their impact.   Hundreds of millions of dollars from Virginia taxpayers have gone toward improving local sewage treatment facilities.  Add that to the substantial progress that’s been made to clean-up effluent from industry, and one would think that we’re making some real strides toward cleaner streams and rivers. 

However, data from the Chesapeake Bay Program indicates that water pollution from developed properties threatens to outpace the progress that’s being made with agriculture, industry, and wastewater treatment plants. As the fastest growing source of water pollution in our region, the Commonwealth must address pollution from stormwater runoff.

The proposed regulations represent a significant improvement over the existing program.  And we support the three-year planning effort, with involvement from multiple stakeholders, which resulted in the proposed program. We understand that representatives from local government, engineers, economists, homebuilders, and researchers from Virginia Tech provided technical input to the program. 

If we want to keep water quality at existing levels as growth and population increase, pollution from stormwater runoff for new development must decrease.  If we hope to actually clean up impaired streams and rivers, pollution must decrease even more. 

In the Shenandoah Valley, polluted runoff following storms is not just an environmental problem; it’s also an economic problem, causing the loss of revenue in recreation and tourism industries, increased costs to provide clean drinking water to the public, and more intensive and damaging floods. Moreover, it is likely that the federal EPA will increase enforcement of the Clean Water Act within the Chesapeake Bay Watershed in the near future.  If we do not adequately address stormwater runoff in Virginia, more of the burden will be shifted to farms and local governments and cost us all more in the long run. Retrofitting is much more expensive than planning ahead.

The Homebuilders Association of Virginia has made what they call a “counterintuitive” counter proposal.  Though development interests were at the table as the DCR draft regulations were formulated, the Homebuilders Association now proposes to allow an increase in runoff pollution from developed sites.  In return they would contribute funds to “assist in the construction of agricultural stormwater management facilities.”  That sounds more than counterintuitive.  That sounds like shifting the burden onto the backs of farmers. 

Finally, CAP also supports a minor adjustment to the proposed regulation to ensure that it provides incentives for new development to occur in towns and cities, rather than in farms and forestland.  DCR has signaled that it is willing to make minor tweaks to the program to address this concern, and we fully support this modification.

Agriculture and local governments are making strides toward clean water, but their efforts will not be enough.  New development should do its part.  We all want to see cleaner streams and rivers, and the state’s proposed stormwater program is a much-needed step in the right direction.

Please adopt and implement this important new program.

Thank you for the opportunity to comment.

Sincerely,

Kim Sandum