Nov 05, 2010
Comments on WIP to enable Virginia to comply with the EPA-TMDL due by Nov. 8
05 Nov 2010
Posted by VAR
The EPA has required Virginia and all of the Bay states to submit a Watershed Implementation Plan (WIP) to them, describing how the state will lower its discharges of nitrogen, phosphorous and sediment into the Chesapeake Bay and its tributaries. The WIP covers the next 15 years, and will require reductions from the agriculture, urban runoff, wastewater, on-site septic and forest source sectors. Virginia must submit a Phase II WIP on November 29.
The members of VAR have a small window of time to comment on the Phase I Virginia WIP or Virginia’s pollution diet for the Bay and its waters. Comments must be submitted by THIS MONDAY, November 8. It is very important for VAR members to comment on the Virginia WIP.
After months of development meetings on the Phase I WIP, a very late change in the Phase I Virginia WIP was made that will significantly impact your and your clients’ properties in Virginia. YOU ONLY HAVE UNTIL NOVEMBER 8 TO SUBMIT COMMENTS. PLEASE SUBMIT YOUR COMMENTS TODAY.
To help you send a comment letter, following please find comment letters prepared for you to express our (your) concerns with the Phase I Virginia WIP. Please select one a sample comment letter below and copy and paste it into a short email. Thank you for your time and attention to this matter.
Email your comment letter to VABAYTMDL@dcr.virginia.gov. Make your inside address in your email to: Mr. Russ Perkinson, Assistant Division Director for Nonpoint Source Programs, Virginia Department of Conservation and Recreation. Make sure to end your email comment letter with your name and company name.
Comment Letter 1.
Dear Mr. Perkinson:
It is my understanding some late changes that were made in the Phase I Virginia WIP were designed to allow the urban runoff sector to acquire credits from the waste water sector through a new Nutrient Trading Exchange (NTE). I do not believe the Commonwealth has the ability to create a cost efficient, orderly, and effective NTE between these two source sectors.
My sector, the urban runoff sector would need to acquire permanent or perpetual NTE credits for the permanent roads and other permanent impervious surface it creates. Unfortunately, I do “NOT” believe the wastewater sector would or could provide us with permanent credits, without permanently sacrificing future capacity in their service areas. In addition, I fear some localities or their wastewater operators will use the denial of the use of NTE credits, as a “no growth” tool.
I recommend that the Sector Allocations in the SAG WIP be adopted by the Commonwealth. They are much more equitable to all sectors.
Comment Letter 2.
Dear Mr. Perkinson:
The Phase I Virginia WIP requires new redevelopment projects to reduce the phosphorous and associated nitrogen and sediment discharges by an arbitrary 20%. Perhaps even more if a determination is made that the reductions from redevelopment are not being met.
I am concerned that such a high standard will retard the much desired redevelopment of the older cities and older suburbs and, once again, encourage sprawl into the nearby undeveloped areas of the Commonwealth. The first and most important principle of “Smart Growth” is to reutilize existing infrastructure in the older cities and older suburbs that are deteriorating quickly in many parts of the Commonwealth. I am an advocate for “Smart Growth” and I believe state and local incentives should be enhanced to encourage such redevelopment. Cost prohibitive barriers for redevelopment like this, should not be erected by the Phase I Virginia WIP.
I recommend a more modest stormwater reduction requirement for redevelopment projects in Virginia that may impact the Bay.