General:

How have these new regulations been considered with the fact that they are increasing costs to developers, new and existing homeowners and municipalities, in conjunction with significantly impeding, if not reversing, the economic recovery that the country and state appear to be entering?

Why are these new regulations being applied to the entire state of Virginia in order to address concerns of the Chesapeake Bay when only 60% of Virginia is in the Chesapeake Bay Watershed? 

Are other states draining to the Chesapeake Bay enacting similar new regulations?  If not, is Virginia being held back while developers go to these other states which are more 'developer friendly'?

Do the new pond regulations inhibit the attractiveness of the ponds to geese, which pollute the ponds with their waste and negate the benefit of the pollutant removal?

Technical:

Definition: "stable" with respect to channels:  who makes the determination if the channel is stable or not? This seems to be a highly subjective issue and will create contention between reviewers, designers, and owners.

"unstable" - same comment about "stable"

Total phosphorous load of new developments shall not exceed 0.28 pounds per acre per year - this is severely inhibiting new development as it equates to approximately 10% impervious area. On a half acre house site for example, a homeowner could not even put up a 2000 square foot building footprint and a driveway.

Compliance with water quality shall be determined with the Virginia Runoff Reduction Method - Most engineers have not used this method yet in design, nor have reviewers used it as a basis for their review.  Is DCR going to set up education seminars to teach this method?

Also, the runoff coefficient for new pavement/impervious area in the runoff reduction method is 0.95.  This seems irrational.  VDOT and the rational method use 0.90.  If 0.90 is not accurate, then all of the accepted drainage systems would be over capacity and flooding in a 10 year storm.  This is not the case.

In the runoff reduction method, forested conditions have a c factor of 0.02-0.05.  If this is applied, and Qd*RVd must be less than or equal to Qpd*RVpd, this is an almost impossible situation to develop any existing forested site, which is a majority of new development.  This would impede the economic recovery mentioned above as development would significantly decrease. 

Water Quantity: Are pipes and culvert systems to be designed with the rational method or SCS/TR55?  Many drainage areas are less than one acre and the TR55 method is not compatible with small areas.  However, the entire site is to be analyzed with TR55.  The rational method and TR55 give significantly different flow numbers.  This will cause a discrepancy in the flow numbers coming from pipes versus the whole site analysis and will be a point of contention between reviewers and designers.  How will this issue be addressed?  

'stormwater harvesting is encouraged for the purposes of landscape irrigation systems, fire protection systems,...' - this will create many mosquito nesting areas.  How is this being addressed? 

'construction of stormwater management impoundment structures or facilities within tidal or non tidal wetland and perennial streams is not recommended'.  The same statement applies to the 100 year floodplain.  - 'is not recommended' is not the same as 'is not allowed' and is open to different interpretations by reviewers and designers.  How will this be addressed? 

4VAC50-60-93B 'individual lots or planned phases of developments shall not be considered separate land disturbing activities....' - does this statement apply to individual commercial site plans, such as a convenience store on a 1 acre lot?