I am writing to wholeheartedly support DCR’s proposed regulation 4 VAC5-15. 

As a businessperson and professional whose livelihood is directly impacted by the health of the Shenandoah River, I have watched for more than two decades as the water quality of this and nearly all rivers in the Commonwealth has deteriorated.

Our current and economically devastating river-wide fish kill has is being attributed to the poor water quality caused by nitrates and phosphates derived primarily from agricultural runoff.  There are few golf courses and urban runoff areas in this rural area of the South Fork of the Shenandoah River.  The culmination of the failure of voluntary practices to curtail pollution is visible with this fish kill.  4 VAC5-15 promises to begin to correct these failures.

After decades of failed voluntary efforts – recall the “Nutrient Reduction Strategy 2000” program – it is time to regulate.  Decades of failure require a stronger approach to achieve the needed long and short-term improvement in water quality.

On the South Fork of the Shenandoah River voluntary Best Management Practices (BMP’s) has not solved nutrient loading, bank degradation and other ill effects caused by  lack of regulation and enforcement on the agriculture community that dominates the Shenandoah’s watershed.   It is time for all – especially our friends in the agriculture community – to take the long view to stop pollution. All interest groups view change and regulation through the lens of their singular perspective, which is often myopic and now driven.  Having healthy water is good business and good for business.

As a businessperson in a highly priced, competitive and non-subsidized market where price increases may spell ruin, I fully understand the intrusive nature and additional cost this regulation might engender; interest groups always call it burden.  I prefer to call it investment.

One of the underlying assumptions in economics is that participants make rational decisions based not on the past but on current viable information. Additionally, in our system, those who cannot compete either become more efficient or fail. All businesses have hardships.  All businesses under American Capitalism are constantly faced with increasing costs. Typically, these costs are passed on to consumers. It is simply the price of doing business. I do not believe I have ever heard any major retailer whining about the cost of doing business. The prices simply go up.  Increasing costs (gasoline is an example we can all relate to) is a business constant.    

This regulation is a good starting point.  In order to protect our river and the ability of agriculture, golf courses and other rural based businesses to continue to succeed in the long term, I am willing to invest in the future by passing on to my customer base the additional burden that Regulation 4 VAC5-15 might create.  This will allow everyone to invest in the future. It is the American Way!

Regards,

Trace Noel