Virginia Regulatory Town Hall
Department of Conservation and Recreation
Virginia Soil and Water Conservation Board
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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8/17/09  11:05 am
Commenter: Mark Rinaldi

Part II, Va. SWM Regulations
Do not adopt Part II of the Proposed Va. SWM regulations, as drafted.
I am a lifelong citizen of Virginia, a faithful taxpayer, sensible environmentalist, professional planner, past Chairman of a tidewater area County Economic Development Authority and the father of two young boys. I was raised on the Bay and my children are fortunate to be experiencing the same. 
Moderation and incrementalism is the key to our collective future, not the dramatic and ill-conceived regulatory approach as is currently proposed. For example, how can one with a straight face propose regulations which apply a uniform standard across Virginia’s multiple physiographic provinces, from the Coastal Plain to the Appalachian Plateau?  Even VDOT recognizes that different approaches to road-building and E&S are required across the State
A prescription for sprawl, the current regulations encourage the excessive consumption of land to manage the stormwater resulting from the growth needed to maintain Virginia as a great place to live, work and play.  Fundamental and critical elements of Smart Growth, as embraced by both the environmental community and the development community, cannot succeed if new development is required to abide by the proposed regulations
All reasonable alternatives must be fully vetted for effectiveness, timeliness, cost efficiency and overall outcome. Give the Homebuilders’ proposal a chance to prove its worthiness; nothing should be “off the table”.  In fact, now is a particularly good time, with growth and development flat, to be open to exploring the proposal from of one of Virginia’s (and the nation’s) most economically and socially important industries.
Previously appointed by the General Assembly to a Peer Review team charged with evaluating the DEQ’s approach to wetlands and water quality, it was tremendously disheartening for me to hear senior Department officials naysay viable policy alternatives because it was feared that the Staff morale would be damaged by requiring them to enforce regulatory policy that was not of their making. We cannot allow this matter and DCR to fall into the same trap. As servants of the citizens of Virginia, the Technical Advisory Committee (TAC) and supporting DCR Staff are obligated to advance through reasoned discussion and debate, all legitimate initiatives to improve water quality. We mustn’t compromise on our future water quality, but we must come together in sincere collaboration to achieve that most worthy goal. 
Vote no on Part II and immediately reconvene the TAC to explore in full the homebuilders’ and any other legitimate alternative proposals.
Mark Rinaldi
CommentID: 9672