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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8/19/09  5:07 pm
Commenter: Bob Brown, Urban, Ltd.

Proposed Amendments to Virginia's Stormwater Regulations
As a citizen and professional engineer registered in the Commonwealth, I am concerned that the technical mandates in the proposed stormwater regulations 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.
In making your decision, here are some things you should consider:
  • These regulations are the least efficient way to address pollutant removal in the bay. The cost of mitigation versus the benefits realized has been determined to be “significant” according to the Department of Planning and Budget.
  • These regulations apply one standard across Virginia, even though there has been no scientific evidence presented to justify this approach.
  • These proposed regulations will most certainly promote sprawl by forcing development to areas of cheaper, undeveloped land rather than smartly redeveloping within existing urban areas.
  • During the recent TAC process, stakeholders were told that the technical requirements 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 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 kindly for your consideration.

CommentID: 9727