Virginia Regulatory Town Hall
Department of Conservation and Recreation
Virginia Soil and Water Conservation Board
Stormwater Management Regulations 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 Ended on 8/21/2009
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8/21/09  2:11 pm
Commenter: Jonathan Fairbanks, PE Fairbanks & Franklin

Vote NO to Part II of the Stormwater Management Regulations
As an licensed professional engineer in Virginia and resident of the Fredericksburg area, I strongly urge you to vote no to Part II of the proposed regulations.  Reducing the phosphorus discharge threshold from 0.45 lb/ac to 0.28 lb/ac will have a limited benefit to water quality, while significantly increasing development costs.  The proposed phosphorus removal thresholds will increase the amount of land required for stormwater management.  This translates into reduced development density and increased development costs, which would have a detrimental impact on the economy as a whole.
Like most residents of Virginia, I am strongly in favor of reducing pollution in the State's streams/rivers and the Chesapeake Bay;  however, the proposed regulations will not be effective because they rely on new development or redevelopment to achieve this goal.  A more effective approach toward improving water quality would target uncontrolled agricultural runoff.  I encourage you to evaluate sensible, cost-effective alternatives to the proposed stormwater management regulations and vote no to Part II.
CommentID: 9869