Action | Amendments to statewide permit fee schedule and to improve the administration and implementation of fees |
Stage | Proposed |
Comment Period | Ended on 8/21/2009 |
I am writing on behalf of the Rappahannock River Basin Commission to offer comments on the proposed regulations. Generally, the Commission supports the implementation of the revisions to the regulations since improved management of stormwater is essential to the success of the Bay Program, but we feel compelled to express some concerns. We echo the concern raised by several commenters that the proposed regulations need to be refined to minimize the unintended consequences of promoting sprawl by potentially making it prohibitively expensive to redevelop land in urban and especially suburban areas. Virginia land use policy has been evolving over the past several years with the goal of promoting more compact development. We ask that you review the proposed regulations to ensure that we have consistent policies and implementation. Efforts to incentivize redevelopment and the opportunity to improve the quality of stormwater runoff from sites that currently have little or no stormwater management should be encouraged. The refinement of offsite alternatives may aid in addressing this issue. Opportunities for private funds to be invested in offsetting land conservation-related BMPs should also be encouraged.
(submitted by Eldon James, RRBC Staff)