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  11:45 am
Commenter: Jeff Collins, Townes Site Engineering

Vote No to new Regulations

Several solid reasons for NOT passing these new regulations.

Bona Fides

I am a licensed Professional Engineer and Land Surveyor and President of a Civil Engineering firm in the Richmond area that has divisions that encompass site design, surveying, geological/geotechnical expertise and environmental analysis.  I have 35 years of hands on experience with the detrimental environmental impact that well intentioned but poorly thought out regulations create.

1. SPRAWL.  The regulations, as written, will encourage suburban sprawl into areas of less expensive land.  Studies have conclusively shown that compact urban or in-fill development add less pollutants to the environment than projects that spread out the same amount of users over more land area.

2. BURDEN ON LOCALITIES AND HOMEOWNER ASSOCIATIONS.  The regulations as writtne do not give sufficient methods by which the localities can implement the regulations and at the same time accept innovative or unorthodox methods for addressing the requirements.  Ultimately, the majority of localities will allow the use of "cookie cutter" solutions that cause more harm than good.  Ultimate maintenance of these acilities will be a huge financial burden to the localities.

Hoemowner Associations will also feel the burden of having to maintain facilities of which they have no understanding.  This will lead to degraded facilites that do not function as intended.

3. PLACING OF BURDEN.  The Chesapeake Bay Commission issued a report which has been tacitly validated by the TAC group that was involved in the creation of these regulations that shows that the top six contributors to the Bay pollution are waste water treatment plants and agricultural activities.  WHY IS THE HEAVIEST BURDEN FOR "CLEAN UP" BEING PLACED UNFAIRLY ON THE DEVELOPMENT COMMUNITY?  Fair and just regulations would make everyone feel more comfortable with these regulations.

4. ONE SIZE FITS ALL.  The implementation and enforcement of these regulations statewide has no bearing at all on the Chesapeake Bay condition.  Certainly Statewide up keep of our streams and rivers is important.  However, the need to impart the 0.28 default loading Statewide is not apparent.  Time and again, studies and actual sample testing have shown that the 0.45 default is more than adequate to maintain the health of streams, rivers, lakes, etc.

There are many other items that have been expanded upon in the public comments submitted.  These are only some of my personal thoughts and observations.


CommentID: 9708