First, I want to state that protection of our environment as part of land disturbing activities, is and should be the number one priority.  However, during these difficult economic times, when both the public and private sector are forced to move forward with less money, some of the proposed changes make very little financial sense and represent a burden that is not necessary.

Having dealt with SWPPP’s in my role as a land development manager I was surprised by the amount of regulation, with little or no enforcement from the State/DCR.  As a matter of fact we found it difficult to even get DCR to recognize that they had received our permit submissions, let alone receive a letter issuing a letter acknowledging permit coverage.  One proposed change will require issuance of the coverage letter, not just submission of the statement.  Let’s not hold up the few development opportunities anticipated, in the near future, and thus delay future anticipated tax revenues, for the additional time that it will take the already overburdened DCR staff to issue the coverage letter. 

Additionally, the proposed new regulations will require a public posting of the SWPPP by the operator twice monthly.  Who is going to enforce?  We have never even seen an inspector on any site covered by a SWPPP.  Why make this requirement when there is not even enough inspectors to enforce what is already in place.  Also, why should the operator be required to show up twice a month, when we all know that no one is going to show up to review the SWPPP, let’s not waste anyone’s valuable time.

Let’s protect the environment, but keep the requirements as they stand and not add burden to both the state and the operator.