As a lifelong resident of Virginia, I appreciate the overall intent of the regulations, to maintain/improve the quality of streams, rivers and the bay

As a professional that has worked in the site development, owner of an engineering firm and developer of several thousand residential lots, I am very opposed to the proposed regulations as they are current written.

Based on almost 30 years of experience, I believe that thesse regulations will tremendously impact the Virginina economy and take a State that has been historically business friendly, to one that is virtually impossible to work within.

It would appear that in addition to the economic impact to most every segment of the economy, these regulations will directly cause "sprawl"  at a greater rate, at a time when every jurisdiction is struggling to deal with current infrastructure issues and find ways to reduce "sprawl" in future developments.  It is also a misconception that "some" of the costs may be passed on to consumers.  All "expenses" necessary to create any product will be passed on by businesses of every type, retail, professional service and construction.  The cost of doing business in Virginia will go up.

Documents shown by the DCR during public hearings show new development as a relatively small percentage slice of the "pie" which is already being treated at a fairly significant rate.  Their would appear to be some much larger slices of the pie where regulations generally in line with current new development would produce a much greater benefit at a significantly reduced cost to the commonwealth and its citizens.

If cleaning up the environment is really the issue, why can't  finding ways to treat existing untreated development become a priority area since it is such a large percentage of the problem.  Something as simple as a tax credit to encourgae existing site owners to add BMP's such as a "Filterra" adjacent to existing storm structures.  This type of BMP can be retrofitted at most existing sites.  I could install two of these "BMP's" that would treat our entire existing office site at 65% removal,  improving water quality significantly more, at much less cost to everyone (regulatory agencies, businesses, and homeowners) than the proposed incremental increase to new developoment over the current regulations

With these regulations, if there is no new developoment, there is no improvement to existing conditions.  Only with redevelopment is there any improvement.

In summary, I think these regulations will have a tremendous impact to the Commonwealth's economy, reputation as a business friendly state, cause sprawl and not have much if any additional impact to improving water quality from the current regulations. 

If the Environment is really the issue, the percentage largest portions of the graphic presented by the DCR goes totally untreated.  These other unregulated areas, can provide the biggest "improvement" to water quality if properly encouraged by the state.

I respectfully request that you do not approve the regulations as written, at the very least send Part 2 back to the TAC, and step back to see where the most benefit for the dollar can be achieved for all Virginians, both public and private.

Sincerely,

Gregory N. Koontz, P.E., L.S.