|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|
It is clear our waters need help, the current controls on land disturbances are ineffective. I believe the proposed regulations have many strong features that will be a great benefit to local stream and Cheaspeake Bay protection. In the past, weak controls were worsened by localities granting waivers to developers for fulfilling requirements, which has caused degradation downstream. Now we are trying to come up with repairs to severly eroded stream valleys. The costs have caught up with us and it will be much less costly to avoid the problems. I am especially pleased to see encouragement for using Low Impact Development (LID) techniques, which are an important approach to avaoid runnoff. I do not agree that this will be a significant disincentive for more dense development which, done right, is a good thing. By using performance measures, the cost of a given set of controls will be divided among a greater number of property owners, so it should not be a burden. I suspect there are many other factors that have greater influence on density and decisions on development location. To the extent that maintenance and enforcement of LID features are needed, this should be addressed by making sure the fee and penalty structure are adequate. Going forward, we will need to look for ways to retrofit already developed areas, so if these controls are do not provide sufficient water quality benefits, that may the next challenge.
Thank you. Please enact these regulations.