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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8/18/09  4:56 pm
Commenter: Joseph McClellan

Pass meaningful requirements that address real problems


The stormwater regulations that are proposed will not address the clean up of the bay. If new development were to cease today, the environmental condition of the bay would still deteriorate. Reducing the allowable discharge from new development will not prevent the next sewer overflow from Lynchburg, Richmond, or Alexandria. Nor does it control the runoff from the farmlands within the Chesapeake Bay Watershed. Further regulating new development does not fix problems that were created 100 years ago with combined sewer systems or city streets that have no water quality abatement features.   
The case studies that have been done reflect little cost benefit analysis when these design standards are implemented. The minute fraction of land to be developed pales in comparison to the area that has already been disturbed without any controls. Rather than burden new development with unreachable goals, why not put reasonable goals on new development and assess the new development with fees that would be put toward a fund to fix combined sewers and provide BMP for areas that do not have any controls? 
The stormwater regulations are a back door method to attempt to control growth rather than address the problem of pollution in our waterways.    


CommentID: 9698