Virginia Regulatory Town Hall
Agency
Department of Conservation and Recreation
 
Board
Virginia Soil and Water Conservation Board
 
chapter
Stormwater Management Regulations AS 9 VAC 25-870 [4 VAC 50 ‑ 60]
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.
Stage Proposed
Comment Period Ended on 8/21/2009
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8/14/09  10:46 am
Commenter: Melanie Holloway, Holladay Properties, Inc.

VOTE NO ON PROPOSED VA STORMWATER MANAGEMENT PROGRAM REGULATIONS
 

Proposed Virginia Stormwater Management Program Regulations

 
My name is Melanie Holloway and as a citizen of the Commonwealth, I am very concerned that the technical mandates in the proposed stormwater regulations will not have their desired effect of reducing pollution. Also, I feel that they would affect our ability to compete in the global marketplace and endanger Virginia's reputation as one of the best places in America to do business.
                                                                
When you vote on these regulations, I encourage you to vote no on Part II, which contains the proposed new technical standards, and reconvene the Technical Advisory Committee (TAC) to continue work on these requirements and consider alternative regulatory arrangements that are based on sound science.

In making your decision, here are some things you should consider:
  • These regulations do not address pollutant removal in the bay very well. They do not address the pollutant removal in an efficient manner. The cost of mitigation versus the benefits realized has been determined to be "significant" according to the Department of Planning and Budget.
  • These regulations do not appear to be based on sound science and apply one standard across Virginia, even though there has been no scientific evidence presented to justify this approach.
  • Obviously, these proposed regulations will promote sprawl by requiring more land to be used to meet the same demand for commercial and industrial floorspace and residential units.
  • During the recent TAC process, stakeholders were told that the technical requirements, that are not based on sound science, were "off limits." Many stakeholders had and still have concerns that have not been adequately addressed or even addressed at all.
  • During the Board's September. 2008, public hearing, six of the nine TAC members who spoke asked you to hold off on Part II. There is hardly consensus on this issue.
  • There are alternatives that would do much more to help the Chesapeake Bay at less financial and environmental cost to Virginia. These alternatives deserve a full vetting by a reconvened TAC.
  • By promoting sprawl, these proposed regulations will make it much tougher build the town center and village style projects that characterize smart growth and are envisioned in state law.

Again, I urge you vote NO on Part II of the proposed stormwater requirements and reconvene the Technical Advisory Committee (TAC). Thank you for your consideration.

Sincerely,

Melanie Holloway

 

CommentID: 9542