|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|
Dear Madame Chair and Members of the Board,
Please accept these comments from the Virginia Chamber of Commerce regarding the proposed new Parts I, II, III and XIII of the Stormwater Regulations. On behalf of our members and our staff, I would like to express our thanks for the opportunity to comment on this proposal.
The Chamber wants to be a partner with the Commonwealth in restoring the health of the
In passing House Bill 3202 in 2007, the General Assembly and the Governor were quite clear in their desire for more compact development patterns, especially in the context of transportation planning, as evidenced by their inclusion of requirements that most localities implement Urban Development Areas (UDAs) to help accommodate future growth needs. Passage of this proposal would endanger a locality’s ability to grow in the compact fashion envisioned by the General Assembly and the Governor.
In addition to inducing sprawl, these proposed regulations take a remedy developed to solve
Although these proposed regulations fail to achieve their environmental protection goals, they succeed all too well in killing jobs and threatening
As you may know, CNBC recently rated
We would be remiss if we did not address concerns about the process itself. We have heard DCR staff and others claim that this has been one of the most open and transparent regulatory processes in
We recognize that this proposal contains several parts and acknowledge that our concerns are mainly with the technical standards. For that reason, we encourage the Board to resist the urge to adopt Part II, but to work with the industry and other stakeholders to iron out logistical concerns and move forward with Parts I, III and XIII, which set up the local programs and fee structure. In this way, you can begin to get the local programs in place within the framework of existing standards.
To address the concerns that have been raised about Part II, we encourage the Board and DCR to re-convene the Technical Advisory Committee (TAC). This would give DCR, the Board and all stakeholders an opportunity to continue work on the technical criteria and to consider alternatives like the one offered by the Home Builders Association of Virginia (HBAV). The HBAV proposal that has merits on several levels and deserves more consideration than it has gotten to this point.
With kind regards, I am
Director of Government Affairs
Virginia Chamber of Commerce