Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Conservation and Recreation
 
Board
Virginia Soil and Water Conservation Board
 
chapter
Stormwater Management Regulations RENUMBERED 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 Ends 8/21/2009
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8/21/09  8:41 am
Commenter: J. Mark Sowers

No, these regs won't do the job. The farmers will make millions with the new plan that works.
 

 

DO NOT pass the new regulations. Under the new plan the farmers will make millions of dollars and the bay will be cleaner.
 
 
There is no scientific justification for the new regulations. In addition, this program will damage economic development and do very little if anything to help the bay. It will also cost the state a fortune in the implementation of the regulations while taking vital funds from essential services.  
 
Here is the simple math;
 
Area of the bay watershed
65,000,000 acres
 
Area in cultivation
20,000,000 acres
 
Area developed 16%
10,400,000 acres
 
Fertilizers
Lbs of Fertilizer each year on cultivated land
3000 lbs corn
750 lbs wheat
650 lbs beans
2,200 lbs average per year
 
2,200 X 20,000,000 = 44 Billion lbs
 
At a 25% runoff
 
11 Billion lbs of fertilizer in the bay each year from cultivation
 
Add livestock and sewage sludge and double that number.
 
22 billion lbs per year from Agriculture
 
Herbicides
 
Average of 500 gallons per acre per year
 
500X 20,000,000= 10 billion gallons per year
 
10% runoff = 1 billion gallons of herbicide each year into the bay.
 
 
A 1984 report on the effect of herbicides on eelgrass stated that 100 parts per billion killed 50% of eelgrass. The amount of herbicide running into the bay each year is enough to contaminate a column of water the size of the bay 65,000 feet high, each year.              This issue has not been investigated.  There is no weed in the bay.
 
Development
 
At 16% impervious or .45
 
10,400,000 X .45 = 4.68 million lbs
 
In summary;
 
Agriculture
Today
 
22 billion lbs
 (equivalent to paving the entire US 4 times over and draining it into the bay)
 
1 billion lbs of herbicides.
(enough to contaminate a column of water the size of the bay to the space station, yet no studies.)
 
Development
 
Today
4.68 million lbs
 
 
Full build out
 29 million lbs
 
AG, 22 billion - Development 4.5 million
 
Agriculture puts over 4700 times the phosphorus in the bay than development. Lets put the money were it does the most good.
 
 
THE ANSWER IS SIMPLE, HAVE THE FARMERS BUILD BMPS AND SELL THE CREDITS TO THE DEVELOPERS. THE FARMERS WILL MAKE MILLIONS AND THE BAY WILL BE CLEANER.
 
Mark Sowers
CommentID: 9828