|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|
While I am writing as a citizen, I am associated with various organizations in Charlottesville, Virginia, including being the Vice Chairman for Economic Vitality of the Charlottesville Regional Chamber of Commerce, which have expressed serious concerns about the proposed stormwater runoff regulations. I am not an engineer and, therefore, rely upon those who have some engineering background regarding the technical aspects of these regulations. However, I do have the background to understand the breadth of the impact of the regulations. Applying these regulations essentially to all construction, including redevelopment, without addressing the source of most of the runoff which is to be controlled, imposes unreasonable burdens upon all development, including construction and renovation of state and municipal buildings. Any regulations need to address the originating sources and should not impose all responsibility upon development and redevelopment, sources which provide a modest amount of the chemicals of concern. This burden will virtually eliminate economic progress in the Commonwealth and, thus, is not the least bit desireable. Further, as I understand some of the engineering information, to the extent there may continue to be development, such will occur in ways which will increase the areas, such as lawns, etc., which would provide substantial sources of the chemicals intended to be controlled. In short, the regulations will probably have the unintended consequnce of exacerbating the very problem they are intended to correct.