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  4:26 pm
Commenter: Michael Pellis, AIA, LEED AP

stormwater regs need more time to get it right
I am a licensed architect, LEED accredited professional and have been involved in implementing cost effective environmentally responsible development solutions in the Richmond region. While I support and commend DCR for moving towards more stringent quality and quantity storm management requirements – I do feel compelled to express some concerns for the technical portions in part II. The proposed regulations need to be refined to minimize the unintended consequences of promoting sprawl by potentially making it prohibitively expensive to redevelop land in urban and especially suburban areas. Much of this has been outlined in detail from many of the various stakeholder comments and I will not attempt to repeat them here. I simply would like to offer up a suggestion that seems to be overlooked in the current proposed regulations – that is the largest contributor to phosphorus contamination in the Chesapeake watershed by an exponential magnitude is in agricultural business. The proposed regulations do nothing to counter the real problem and unfortunately will also have an adverse effect on economic growth both in the residential and commercial building sectors. I urge you to please take more time to evaluate the laws and regulations through the filter of getting the largest bang for our dollars spent. In doing so, you will need to start with the largest contributors to the problem and come up with cost-effective, implementable strategies that will both mitigate the problems while promoting economic growth in the process. The current proposal will do neither of these.
Thank you for your consideration,
Michael Pellis, AIA, LEED AP
Achitect | Associate


CommentID: 9898