|Action||Amend Parts I, II, and III of the Virginia Stormwater Management Program Permit Regulations to address water quality and quantity and local stormwater management program criteria.|
|Comment Period||Ends 8/21/2009|
I have been practicing civil engineering along the East Coast of the United States for over 32 years. While we have seen regulations which provided benefit such as erosion control enhancement and storm water detention, we are facing a proposed regulation that is being considered without understanding the cost/benefit to the environment. I have invested over 300 hours of time to evaluate the requirement and the implementation of same. In evaluating 5 case studies regarding the effects on development costs, I have determined the following:
Increased proposed regulation requirement is approx 120-125% of current regulation. (Sounds like not a big issue to overcome)
Increased costs to implement the regulations considering construction and project Performa ranges from 300-500% on commercial and urban sites to over 1000% on residential properties.
Enacting these regulations in this economy with this cost/benefit ratio is not responsible. I challenge anyone to dispute how 120-125% increase in requirement is fair and equitable to the development community who are trying to help this country rebound from the worst economic climate in my career.
These regulations are not well thought out and are being driven by environmentalists who are basing their decisions on passion and not on sound practices and good judgment.