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
Previous Comment     Next Comment     Back to List of Comments
8/19/09  10:21 am
Commenter: Hugh Woodle, a Concerned Citizen

Proposed Stormwater Regulations

All Virginians want clean water for personal use, for rivers and for a clean environment in Chesapeake Bay.These regulations may cost Virginians much more than they get in return.  People who want these regulations that push to the limit may not fully understand the potential impact of the regulations on their daily life.

As with any change proposed by local, state or federal government there are always unintended consequences that can cause severe problems for the very people they are supposed to help.  These regulations are filled with such consequences.  These potentisal consequences are identified but they are not quantified.  A sound management decision cannot be made until such quantification is accomplished.

The document "Economic Impact Analysis" issued by Virginia Department of Planning and Budget on May 12, 2009, covers these regulations.The analysis mentions benefits to fishing and tourism-related businesses, but they are not quantified.  There are examples where cost to the public will be higher because of imposed stormwater taxes/fees, increased cost of building and operating a business (fewer new jobs?) and increased cost of new housing, but not quantified.  There are several statements "could not be estimated at this time."

The benefit/cost ratios must be positive before Virginia citizens are asked to spend financial resources on an idea, even one that sounds good, with no assurance that desired results will appear after all the changes are made.  This could be particularly damaging with the present weak economy.  There has to be a more reasonable solution to this concern.  The regulations as presented should not be enacted at this time. 

Hugh Woodle, a Concerned Citizen

CommentID: 9701