|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.|
|Comment Period||Ends 8/21/2009|
Middle Atlantic PGA
August 20, 2009
Virginia Department of Conservation and Recreation
203 Governor Street, Suite 302
Richmond, VA 23219
RE: Proposed Revisions to Virginia Stormwater Management Program Permit Regulations
Dear Regulatory Coordinator:
Thank for the opportunity to submit our industry’s comments on the proposed regulations. The Middle Atlantic Section of the PGA represents over 600 PGA Club professionals at over 300 golf facilities in the Commonwealth. Regarding the proposals, we have two main concerns and several recommendations
One concern is the potential for the proposed changes to significantly increase the cost of constructing or reconfiguring highly managed turfgrass areas, especially golf courses. While the cost to implement management practices may vary from project to project, there will likely be additional practices or design requirements which will potentially increase the costs of construction for a facility. Additionally, we are concerned that the proposed regulations may require additional time to construct a new facility, through more consulting, engineering, architectural designs, and permitting processes. Each of these processes can add to the cost of constructing facilities. The public is crying out for more access to outdoor activities and as such, we encourage you to work with our industry to identify measures that will not result in making such venues excessively difficult and costly to design and construct.
In order to address some specific concerns that our industry has raised regarding the proposed regulations, we support these recommendations, and respectfully ask DCR implement the following:
Finally, we commend DCR for developing the Turf and Landscape Nutrient Management Certification program. This program promises to be a tremendous benefit both to the environment and to the industry. We would like for the DCR to consider the application of nutrient reduction offsets to existing turf-intensive uses that provide for nutrient management plan implementation. This would be consistent with the agricultural offset guidance already produced and would provide an easier quantification method for urban programs that desire to implement more comprehensive approaches to overall nutrient reduction.
Thank you again for this opportunity to provide comments on the proposed regulations. We look forward to continuing to work with the agency to identify mechanisms to address the concerns and recommendations outlined in our comments.
Middle Atlantic PGA
1 PGA Drive
Stafford, VA 22554