Looking at the state's pending storm water regulations ("Storm over storm water," Jan. 25) from the professional engineering community side of this issue, we are not opposed to taking on the unique challenges of the new storm water regulations for benefit of the environment. We are considerably concerned, however, about the confusion and further delays enforcement of these new regulations will cause in the permitting process, a process that is already muddled with backups and unresponsiveness, due in part to lack of personnel on the regulatory side and in part to the lack of decision making.
The new regulations give room for a very subjective judgment call -- the "maximum extent practicable." Does that include economic considerations, existing site conditions, land use restrictions, maintenance requirements, long-term survivability, localized vs. overall measures of environmental benefit? Furthermore, multiple submittal phases are also being required for regulatory review during the design process. To make these new regulations work, the regulatory side should be held to a reasonable timetable for issuing review comments and responses to the engineers, and just as importantly, should receive adequate funding to do so!
We fear the worst -- permitting of a redevelopment project costing the owner as much as and taking as long as the project's design and construction. And in the case of a state or city project, that means even more taxpayer money spent, not just developer money.
Paul N., Baltimore