Virginia Regulatory Town Hall View Comments

Department of Conservation and Recreation

Virginia Soil and Water Conservation Board

Stormwater Management Regulations AS 9 VAC 25-870 [4 VAC 50 ‑ 60]

Action	Amendments to statewide permit fee schedule and to improve the administration and implementation of fees
Stage	Proposed
Comment Period	Ended on 8/21/2009

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8/21/09 11:51 am

Commenter: Karen W. Forget, Lynnhaven River NOW

Vote Yes on the Amendments to the Stormwater Management Regulations

Lynnhaven River NOW

1608 Pleasure House Road, Suite 108

Virginia Beach, VA23455

August 20, 2009

The Regulatory Coordinator

VirginiaDepartment of Conservation and Recreation

203 Governor Street, Suite 302

Richmond, VA23119

RE: Proposed Amendments to Parts I, II, III, and XIII of the Virginia Stormwater Management Program Permit Regulations.

To Whom It May Concern:

I am writing on behalf of the Board and 3,000 members of LynnhavenRiverNOW to voice our support for the proposed amendments to Parts I, II, II, and XIII of the Virginia Stormwater Management Program Permit Regulations. The new regulations are designed to reduce stormwater runoff from rooftops, driveways and parking lots that contribute significant amounts of pollutants to our waters.

Our watershed is more than 95% developed, 64 square miles, home to 230,000 people and approximately 40% of the land area is covered with impervious surface. 83% of our stormwater goes directly back into our surface water. Only 17% has any pretreatment, twenty years after the passage of the Chesapeake Bay Act.

Stormwater is, by far, the primary way that pollutants, nitrogen, phosphorus, sediments, bacteria and toxins, enter the LynnhavenRiver. LynnhavenRiverNOW has a very active public education program addressing fertilizer and bacteria inputs. Nevertheless, our only opportunity to significantly reduce pollutants, restore water quality in our river and protect the quality of life and the health of our citizens is through higher storm water standards. Our scenario is repeated in urban and suburban waterways throughout Virginia and in the Chesapeake Bay.

LynnhavenRiverNOW fully supports the proposed changes to the stormwater regulations. While we realize that some of these provisions will not be easy, we know that we have the expertise to meet these standards, both quantity and quality, through low impact development (LID) practices and that this is absolutely necessary to protect our water.

In Virginia Beach, we know from experience that restoration work is much more difficult and more expensive than preventing pollution and degradation. We are paying today for mistakes made in the past. We cannot continue to make those same mistakes. We cannot continue to contribute to the problem. Gains made in other areas, agriculture and sewage treatment facilities are being offset by increases in damaging urban and suburban stormwater runoff.

Also, please keep in mind when you hear the dire predictions of the builders and developers that when the Chesapeake Bay Act was passed, the development community told us it would strangle economic growth and development. Clearly, it didn’t. Today, Virginia is considered a top state for business, ranked #1 by Forbes as the best state in which to do business.

We commend DCR for the thorough and comprehensive work that went into the development of these proposals. We urge you to pass the new regulations and deliver it to Governor Kaine before the end of the year.

If we are committed to restoring and protecting our valuable rivers and the Chesapeake Bay, we must take this important step forward.

Sincerely,

Karen W. Forget

Executive Director

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