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.