|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|
August 13, 2009
Mr. Joseph Maroon
Virginia Department of Conservation and Recreation
203 Governor’s Street
Richmond, Virginia 23219
Dear Mr. Maroon:
I am writing to provide comments from the Greater Richmond Area Association for Commercial Real Estate (GRACRE) on the proposed amendments to Virginia’s Stormwater Management Regulations.
Our organization believes in a healthy balance of environmental, human, and economic sustainability. We believe that our continued success as a Commonwealth requires properly understanding how land use decisions impact our economy as well as our ecology. We strive to educate our members and our communities regarding best practices in the areas of sustainability, urban re-development, and growth-management to preserve the quality of life for our citizens and members. We also believe that Virginia’s position atop the pro-business rankings is at risk because of a series of regulations that hamper the ability for Virginia to grow in a sustainable way.
More specifically, the proposed amendments to Virginia’s stormwater regulations conflict with a number of areas where commercial, residential, and industrial development professionals have made progress towards building more sustainable communities. We believe the technical regulations as written, will actually discourage re-development within and around existing infrastructure and encourage sprawl. A quick summary of some of the problems are as follows:
We respectfully request that the proposed changes be rejected. We encourage the Department to more thoroughly study the regulations and propose more realistic standards to preserve water quality here in Virginia.
GRACRE Legislative Committee