I am writing on behalf of the Virginia Association for Commercial Real Estate (VACRE) to provide comments on the proposed guidance document for streamlined plan review GM22-2011 that was published in the Virginia Register of Regulations on August 1, 2022

VACRE represents Northern Virginia, Hampton Roads and Richmond area commercial and industrial developers who have teamed with other professionals from the urban crescent of Virginia to serve as the voice of the commercial and industrial development community in Virginia.  NAIOP Northern Virginia, the Hampton Roads Association for Commercial Real Estate (HRACRE) and the Greater Richmond Association for Commercial Real Estate (GRACRE) comprise the three member chapters of VACRE.  There are about 800 member companies and more than 2000 individuals in VACRE’s three member chapters.  Many of the companies comprising VACRE’s chapters have offices and are creating jobs and promoting Virginia’s economic development in two or all three of the regions of Virginia that VACRE represents. 

The cost and complexity of compliance with Virginia’s stormwater management requirements makes this program one of the most challenging for the owners and developers of most any private or public development.  While the Department of Environmental Quality has done a good job implementing this program that they inherited from the Department of Conservation around 2014, delays in permit processing have been a source of frustration for many.  Because delays can often result from inadequate submissions from applicants, as well as complex and piecemeal guidance from the agency, the proposed checklist and process for streamlined plan review process for applicants with projects in localities where DEQ conducts the plan review (i.e., “opt-out” localities) will be allow both private and public projects to be completed more quickly, at reduced cost and with less unexpected delays.

The proposed streamlined process not only will increase the efficiency of the permitting process and institute business-like tracking of permit applications during processing, but they will increase environmental protection with performance standards and other requirements that are required to be met to get permits processed within a fixed timeframe.

VACRE strongly supports this proposed guidance.  Our members greatly appreciate the transformational work DEQ staff is doing on Virginia’s stormwater and erosion control programs under the leadership of its Director Mike Rolband through issuance of this and other proposed guidance as well as through other process and regulatory improvements underway. 

Thank you for consideration of these comments. 

Sincerely,

Philip F. Abraham

Legislative Counsel

Virginia Association for Commercial Real Estate