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  4:58 pm
Commenter: Ivan Wu

Reject Part 2 (Tech Criteria) of the Stormwater Regs

The proposed amendments (specifically Part 2 Tech Criteria) of Virginia's Stormwater Management Regulations are counter productive to smart growth and re-development and actually encourage sprawl.  That said, they should be rejected.

Clean water and a clean environment is a goal that everyone desires.  The balance is to develop and regulate responsibly.  From reviewing the documents, I don't believe that all the facts are have been thoroughly evaluated that prove the cost versus benefit is warranted.  Designing to a 0.28 lb/ac/year phosphorus is extremely difficult and in some cases cost prohibitive to obtain.  The economic impacts from the proposed regulations would be devastating.

Respectfully submitted.



CommentID: 9906