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2018 Approved Legislative Program, Policy Positions
NEW – SOLAR ENERGY FACILITIES
The City opposes any legislation that reduces the authority of a local government to regulate the siting or development of solar energy facilities. In addition, the City opposes the diminishment of local tax authority over solar energy facilities.
NEW – CELL TOWERS
Oppose legislation to reduce local zoning authority and public input in the siting of new wireless support structures. Oppose limiting applicable permit fees to an arbitrary rate in statute that doesn’t reflect the actual costs and planning staff time; and oppose legislation that limits local control over its own public rights of way and public property to benefit one industry.
NEW - SMOKE AND CARBON MONOXIDE DETECTORS
The City supports the Virginia Housing Commission proposed updates, with edits, to the smoke detector and carbon monoxide detector statute. The proposal more accurately reflects current technology and terminology regarding smoke alarms. The legislation clarifies responsibilities of landlords and tenants regarding the requirement for, and maintenance of, smoke alarms and carbon monoxide detectors. It further requires smoke alarms for hearing impaired citizens and smoke alarms in assisted living facilities, adult day care centers, nursing homes and facilities regardless of when the structure was built.
IMPACT FEES/CONDITIONAL ZONING/RECORDATION FEE
The City recommends that the General Assembly enact laws to broaden and simplify impact fee authority to allow the assessment of the fees for all public infrastructure, including school construction costs, caused by growth. Impact fees should be based on public facilities construction costs and fees should be locality-specific.
The City does not support the loss of authority to accept cash proffers for residential rezoning. A bifurcated system could be considered where cash proffers are used for rezoning applications and impact fees for by-right development. Any change must not shift the burden of paying for new infrastructure to existing citizens through increased real estate taxes.
The City opposes any reduction of local authority to manage such functions as land use, zoning, conditional use permits, etc. Local governments must retain current authority to use conditional zoning rules in the State Code to balance the financial impact created by residential development and to facilitate well-planned communities that are compatible with nearby developments.
The City supports legislation that would aid local revitalization/redevelopment efforts such as, but not limited to, additional funding for demolition of abandoned structures, statutory presumption of abandonment, authority to enter and abate derelict buildings, and expanded authority concerning spot blight abatement.
VIRGINIA HOUSING TRUST FUND
The City supports continued state funding for the Virginia Housing Trust Fund. The City also supports providing for a portion of the Fund to be used to provide matching funds to localities that have established local housing funds, and grants to be made from the Fund to support innovative housing projects and low and moderate income housing projects that are located in areas experiencing extreme shortages of such housing.
FUNDING FOR OPEN SPACE CONSERVATION
The City of Chesapeake desires to protect its open space, agricultural lands and industries, natural resources, including its drinking water supply watershed, natural habitats, and historic sites. Conserving these resources is critical to Virginia’s economy and establishing a balance between the conservation of open space/natural resource lands and residential and/or commercial development is essential to quality of life and fiscal health. The City supports the efforts to establish a dedicated funding source for open space conservation, to include agricultural lands.
MOTOR VEHICLE TITLE LOANS, PAYDAY LOANS, AND OPEN-END CREDIT PLANS
The City urges the passage of legislation to enact a market based interest rate cap for consumer loans made in the Commonwealth of Virginia in order to protect citizens from the high interest rates that are presently allowed. The City also supports a reversal of the legislation that was adopted in 2011. The 2011 amendment allowed title loan issuers to advance loans secured by out of state vehicles.
Mental Health, Developmental Disabilities and Substance Abuse Services - The City of Chesapeake supports the following behavioral healthcare requests:
NEW – SYSTEM TRANSFORMATION, EXCELLENCE AND PERFORMANCE IN VIRGINIA (STEP-VA)
STEP – VA
was developed to address: Accountability, Access, Quality, and Consistency across all CSBs to work toward excellence in behavioral healthcare and ultimately a healthy Virginia. STEP-VA services are intended to foster wellness among individuals and prevent crises before they arise. The result would be fewer admissions to state and private hospitals, decreased emergency room visits, and reduced involvement of individuals with behavioral health needs in the criminal justice system.
The potential impact of the STEP program not being funded for Chesapeake would be approximately $270,000 annually. This is the amount Department of Behavioral Health and Developmental Services (DBHDS) will allocate to us for staffing, etc. for the future. This does not include the primary care screening portion. The amount is yet to be determined, but it would be the cost of two LPN's or one RN, or about $86,000 or $67,000, respectively.
The core services and supports in STEP-VA are now mandated in the Code of Virginia but have not been fully funded. In order to meet the code mandated timeline for implementation of all the services and supports, the General Assembly needs to provide full funding in the 2018 – 2020 biennial budgets.
The City of Chesapeake desires funding in this biennium for these 10 services (Screening, Assessment and Diagnosis (including Risk Assessment), Crisis Services (including 24 hour mobile), Crisis Intervention and Stabilization, Targeted Case Management, Outpatient Mental Health and Substance Abuse, Psycho-social Rehabilitation, Peer and Family Support, Care for Members of the Armed Forces and veterans, Primary Care Screening and Monitoring, and Patient Centered Treatment Planning) in the STEP – VA model. The 2017 General Assembly mandated that Same Day Access (SDA) and Primary Care Screening (PCS) come on board by 2019 and the remaining eight services are mandated to come on board by 2021.
The City urges, at a minimum, funding will be required for the Community Services Boards still waiting to implement Same Day Access and for all of the Community Services Boards to implement Primary Care Screening.
Increase the reimbursement rate for Medicaid Early Intervention Case Management to its data-determined adequacy: Early Intervention Services result in special education cost savings and provide an increased quality of life for the child and his/her family.
The City of Chesapeake desires an increase the Medicaid Early Intervention case management reimbursement rate. This increase is necessary because the current monthly rate does not cover the expenses of providing this critical service, which ensures eligible children and families receive service coordination that is appropriate to the needs of infants, toddlers and their families. We currently receive $132.00 per case per month, while intellectual disability case management is paid at $326.50 per month.
Reduce the I/DD Waiver Waiting List: Currently, over 11,000 people with developmental disabilities are on a waiting list for community-based services. Virginia’s DD Waivers have been redesigned to provide increased access to community supports. Using the Family and Individual Supports Waiver, Virginia can serve 50% of the individuals on the DD Waiver waiting list for a quarter of the cost of existing DD waiver programs. Receiving a Waiver slot will enable an individual who needs developmental services and supports to live a life that is fully integrated in the community.
The City of Chesapeake desires a reduction in the waiting list for DD Waivers by funding 800 additional Family and Individual Supports (FIS) Waivers and 250 Community Living (CL) Waivers. Chesapeake currently has 342 individuals (on all three (3) levels) on the Developmental Disability Waiting list.
CHILDREN’S SERVICES ACT (CSA) - UPDATED
Department of Medical Assistance Services (DMAS) recently announced regulatory changes to the process by which children are placed in Residential Treatment Facilities. Under the new process, which will begin December 1 of this year, admission for all Medicaid-funded placements for residential treatment will be coordinated by an Independent Assessment, Certification and Coordination Team (IACCT).
This proposal represents a significant change and local Children’s Services Act (CSA) coordinators across the State have raised many questions about how this process would work, including concerns about the required deadlines for the IACCT to complete an assessment and the role of the physician member of the IACCT.
At this time, the City can neither support nor oppose the concept of transferring the state pool funding for students with disability in private day educational programs to VDOE because there needs to be more study and analysis on the following areas:
- What factors are driving costs and placements in private special education day schools?
- What is the current capacity of Chesapeake Public Schools to handle this responsibility (knowledge, personnel, programmatic/physical infrastructure = cost/time analysis)?
- What are the positives of the current system (outcome data / cost analysis of private day schools compared to public schools providing these services)?
- If funding is moved out of CSA and reallocated under a new formula through VDOE, it is likely that only a fixed amount will be transferred, rather than the current sum-sufficient allocation under CSA. If costs to serve children increased, would the state’s contribution be limited? Would the locality be obligated to make-up the difference? (This could be a potential be a large financial risk).
- If funding remains in CSA what tools are put in place to help control these costs?
A work group’s report is due November 1, 2017.
LIABILITY OF TEACHER RETIREMENT PLAN
The unfunded liability associated with the teacher retirement plan should be a shared responsibility of the state and local government. In that local public school systems, in accordance with government accounting standards (GASB) are a “component unit” of the locality for purposes of financial reporting. VML supports legislation that would provide for the Virginia Department of Education to pay its share of retirement costs directly to the Virginia Retirement System in order to facilitate the sharing of these liabilities.
TIDEWATER COMMUNITY COLLEGE – CHESAPEAKE CAMPUS
Tidewater Community College, with 45,000 students, serves South Hampton Roads, where the shortage of skilled workers to fill STEM jobs is above average compared to other MSAs in the U.S. According to the Brookings Institution, the region was ranked No. 1 in the share of jobs requiring education on Science, Technology, Engineering and Mathematics, and Health Care (STEM/H) skills and sub-bachelor’s level of education.
Consistent with TCC’s campus master plans and its role in developing the STEM/H workforce:
- TCC’s top legislative priority is full funding for construction of a Science and Engineering Building on the Chesapeake Campus. These funds will be used for the construction of a 76,000 square foot Science and Engineering Building with classrooms and labs for Chemistry, Biology, Natural Sciences, Geology, and Physics. In addition, the new facility will provide much-needed space for the campus’ Engineering and Engineering Technologies programs. This facility directly addresses the need for STEM credentials. These programs are currently housed in antiquated labs in the 35-year old Pass Building and in temporary modular buildings.
The City opposes any amendments to limit the scope of Pretrial Services, as well as supports the continued funding of Pretrial Services in the Commonwealth.
HUMAN SERVICES - UPDATED
For years the state has consistently underfunded its share of administrative costs (including personnel and technology) for programs administered on its behalf by local departments of social services. The state agency has now decided to make local agencies solely liable for federal financial penalties resulting from federal audits of the system. Federal law does not require passing this cost onto localities; it is the state’s choice to do so. If the state is concerned with improved performance and accountability, it must fully acknowledge and fulfill its responsibility in this partnership by properly funding, staffing, equipping, and supporting the local offices that render services on its behalf.
The City urges the state to provide additional funding for transit services and client advocacy training. We support the state’s efforts to open an interactive “portal” for clients to review their resources, apply for and change appointments and access services from their home. The Chesapeake Social Services Division has concerns with the barriers to human service providers sharing redundant customer information, which the customer has authorized to be shared. We request that the state remove electronic barriers to the sharing of this information. Along these lines, it is requested that the state continue to find ways to reduce the paperwork requirements, simplify program requirements and integrate requirements between state systems. The City also supports the Department of Juvenile Justice increasing the Block Grant Funding to 50% of the Chesapeake Juvenile Services (Detention Home) operating budget. Consideration for continued funding of the Community Corrections Program (CCP) as an essential component of re-entry for Juvenile Detention.
Any legislation or regulatory action having a fiscal impact on local governments should also be accompanied with state appropriations adequate to cover the full cost of such mandates.
LOCAL REPRESENTATION ON LEGISLATIVE STUDIES IMPACTING LOCAL GOVERNMENTS
Local government representatives should be included on any “blue ribbon” commission or other body established by the state that has as its purpose changes to local revenue authority or governance.
LOCAL TAXING AUTHORITY
The General Assembly should not cap, remove or restrict any revenue sources, taxing authority or user fees available to localities. The erosion of local revenue sources reduces local flexibility, increases local government’s reliance on the real property tax and jeopardizes local bond ratings. If the state does eliminate or restrict local revenue sources, it should replace those revenues lost to the localities. The loss to localities includes not only current revenues being derived from the revenue source, but also potential increases in revenues due to growth or rate increases.
STATE AID TO LOCALITIES
State aid to localities assists in providing services at the local level, many of which are mandated. The state and localities are in partnership in providing these services to their citizens and localities should not be expected to take on a greater and greater share of the funding responsibility. The City opposes cuts in state assistance programs such as, but not limited to, full funding of State Aid to Local Public Libraries, HB 599 funding for localities with police departments, extension services, local offices on youth, Virginia Juvenile Community Crime Control Act (VJCCCA) funds and services for senior citizens. The City also opposes any further reduction to the car tax reimbursement to local governments.
ECONOMIC DEVELOPMENT INVESTMENT PROGRAMS
The City supports State funding for such programs as the Virginia Jobs Investment Program and the Governor’s Opportunity Fund. The City also supports changes to the State’s economic development incentives program to provide increased flexibility to provide assistance to a wider range of companies, especially smaller and mid-sized projects. Further, the City supports the creation and implementation of new economic development incentives programs that are based on “best practices” of Virginia’s competitor states.
VIRGINIA ENTERPRISE ZONE PROGRAM
The City of Chesapeake’s Enterprise Zone program was recognized as one of the most successful in the Commonwealth of Virginia. It was a vital component to the City’s ability to bring business and job growth to the City’s South Norfolk community. The program designation expired in 2005, and the reapplication process was placed on hold by the Virginia Department of Housing and Community Development while changes to the statewide program were being considered by the 2005 Virginia General Assembly. These program changes were highly significant, and removed the City’s eligibility to participate in the Enterprise Zone program.
The City supports a revision of the state’s Enterprise Zone program to provide additional funding and to revert back to the original eligibility criteria, whereby Enterprise Zone designations were granted based on the demographics and economics of specific neighborhoods, and not the City as a whole.
FUNDING FOR CONSTITUTIONAL OFFICES
The City of Chesapeake urges the state to fund the additional positions for the Offices of Clerk of the Circuit Court, Sheriff, Commonwealth’s Attorney, City Treasurer and Commissioner of the Revenue, that its own staffing standards indicate are needed, and which more accurately reflect the actual workloads and requirements of these offices.
NEW - STATEWIDE TRANSIT CAPITAL FUNDING
The City supports funding to replace state bond funding for transit capital/state of good repair that will be exhausted in FY 2019. This funding is primarily for bus replacement, support vehicles, computer systems, and related transit support. Hampton Roads localities would need to identify an additional $12 million annually to meet basic state of good repair for existing buses if historical state funding were not continued.
The General Assembly (HB 1359) established the Transit Capital Project Revenue Advisory Board in 2016 to examine state transit capital funding needs and identify potential solutions to meet these needs. Highlights of the board’s findings include the following:
Bond funding that was approved in 2007, primarily for transit state of good repair, will decline in FY 2018 and be completely exhausted at the end of FY 2019. With the end of this funding, there is a projected revenue shortfall averaging $130 million annually over the next ten years starting in FY 2020. This funding is just to maintain historical levels of investment 80% of funds are typically used to meet basic state of good repair, like purchasing buses, and the remaining 20% for minor enhancements and some expansion.
Virginia needs steady and reliable revenues dedicated to the statewide transit state of good repair program. A combination of statewide and regional sources could be considered but use of any regional funds should be only for transit needs that improve service across the region.
NEW – REGIONAL TRANSIT FUNDING
The City supports dedicated regional funding to support public transit in Hampton Roads without a reduction in funding for other transportation modes. New regional funding will enable the region to develop a fully integrated and inter-connected regional transit system by:
• Fixing what’s broken or missing in the current system;
• Making targeted improvements that more effectively connect major employment, retail, education, medical, and tourism destinations across city boundaries resulting in a true regional transit system;
• Including new oversight, prioritization, and accountability provisions.
Hampton Roads is a global gateway for commerce that is vitally important to Virginia’s economy. Transit plays an important role regionally, supporting more than 20,300 jobs and $538 million annually in employment income, as well as $89 million in consumer spending across Hampton Roads. The lack of a regional funding structure has resulted in a system of localized transit routes rather than a fully integrated and optimized regional transit system. A metropolitan area of 1.7 million people must have a truly regional transit system if it is to grow and compete in the global marketplace.
HIGHWAY FUNDING - UPDATED
The City appreciates the General Assembly’s efforts to meet the demand for construction and maintenance of highways, bridges, railroad overpasses and other critical components of transportation safety and commerce. The City supports continued funding for the State of Good Repair program, bridge construction, and bridge maintenance and operations, especially for moveable bridges. The City further requests the State to retain the Revenue Sharing Program.
With passenger rail service now running through Chesapeake and freight-rail activities on the rise, the need for grade separated highway-rail crossings is critical to ensure emergency access to the ever increasing industrial areas along the Elizabeth River, as well as highly populated residential areas. The City and the Norfolk-Portsmouth Beltline Railroad jointly funded the design of the Freeman Avenue overpass and are seeking construction funding through various state and federal programs. Further, the City is currently designing the 22nd Street Bridge which serves as a crossing of the Norfolk-Southern Railroad. Additional funding is needed to design and construct overpasses at major crossings such as Freeman Avenue and Portlock Road.
The City strongly opposes any proposal to reduce annual road maintenance payments to the 83 Virginia local governments that own and maintain their own streets.
REGIONAL GAS TAX FLOOR
The City supports an amendment to Virginia Code § 58.1-2295 which would establish a protective floor price for the 2.1 percent (2.1%) regional wholesale price per gallon gas tax much as was done for the statewide fuels tax in §58.1-2217. Such a floor concept is essential to provide a more stable, dedicated revenue source needed for long-term financing of regional projects in Hampton Roads and Northern Virginia. It is estimated that such a floor would raise approximately $20 million or more per year for the Hampton Roads region.
NEW – SOLICITATION
The City supports legislative initiatives that would lawfully restrict solicitors and other persons from standing on public right-of-way, including medians, where doing so is likely to create a public safety hazard. The City recognizes the need to balance public safety with First Amendment rights of free speech and believes that an acceptable narrowly drawn compromise is possible given the compelling governmental interest in ensuring the safety of motorists and pedestrians alike.
Support the animal cruelty legislative initiative adopted by Virginia Beach to amend Section 3.2-6570 to allow persons who severely abuse companion animals to be charged with a Class 6 felony, regardless of whether the animal survives or whether the defendant has been previously convicted of the same crime within the past 5 years. Currently, animal cruelty arises to a Class 6 felony only if the animal dies or there are other aggravating circumstances; otherwise it is limited to a Class 1 misdemeanor. A Class 6 felony is punishable by 1-5 years in prison and/or a fine of up to $2500. It is the “lowest” class of felony.
URBAN AREAS SECURITY INITIATIVE (UASI) - UPDATED
The UASI designation for the Hampton Roads region was restored in 2017. The HRPDC requests assistance from our state and federal partners to increase the level of UASI funding provided to the Hampton Roads region.
SAFETY BELT REQUIREMENT
An amendment to Section 46.2-1094 of the Code of Virginia is necessary to protect the lives and wellbeing of citizens of the Commonwealth and others traveling on the roadways within Virginia. Currently, Virginia Code Section 46.2-1094 requires persons who are at least 16 years of age and riding in the front seat of a motor vehicle to wear a safety belt; however, law-enforcement officers are prohibited from enforcing this section, unless they have cause to stop or arrest the driver of the vehicle for some other violation. Wearing seatbelts has proven to save lives. To make this code section more effective in saving lives, law-enforcement officers need to be authorized to enforce Virginia Code Section 46.2-1094, without first being required to find that another law has been violated.
The City supports the introduction of legislation that addresses the issue of distracted driving.
NEW – DEEPENING AND WIDENING OF HAMPTON ROADS HARBOR CHANNELS
Virginia is among a small number of U.S. East Coast ports that can currently handle ultra-large container vessels and is in the best position to attract first-in, last-out services that require the deepest channels. The deepening and widening of Virginia’s channel to 55 feet is critical to the Commonwealth’s ability to attract the first-in and last-out services over other East Coast ports ensuring speed to market for importers and exporters. These services will play a critical role in business development, job creation and generation of tax revenue throughout the Commonwealth of Virginia. In addition to fostering more business and increasing safety, accommodating larger vessels also offers the ability to move cargo more inexpensively and with fewer emissions, reducing the impact on the environment. The City of Chesapeake supports the Commonwealth’s investment of resources to deepen and widen the Port of Virginia.
COAL COMBUSTION BY-PRODUCTS - UPDATED
In order to ensure against accidental discharge and contamination of groundwater, any coal combustion residuals (“CCR”) should be removed to a permitted, lined landfill meeting Federal criteria for this class of waste. Removal of CCR and closure of CCR landfills and surface impoundments, including inactive surface impoundments, should be in compliance with governing Chesapeake ordinances, State and Federal law, as well as applicable State and Federal criteria, and the EPA’s Final Rule for the Disposal of Coal Combustion Residuals from Electric Utilities (“CCR Final Rule”). The closure and post-closure of any CCR landfill or surface impoundment, including inactive surface impoundments, should also be in compliance with any conditional use permit issued by the City of Chesapeake.
GROUNDWATER MANAGEMENT & GROUNDWATER INJECTION PROJECTS UPDATE BASED ON STUDY - UPDATED
The Eastern Virginia Management Advisory Committee spent two years developing, revising, and implementing a management strategy for ground water in the Eastern Virginia Groundwater Management Area and submitted the results of its examination and recommendations to the General Assembly in a report dated July, 2017. The City of Chesapeake supports the Committee recommendations within this report in general, and strongly supports the following:
- Recommendation # 1: The Commonwealth support Hampton Roads Sanitation District’s SWIFT and similar projects, including aquifer storage, recovery, and recharge.
- Recommendation # 2: The Commonwealth promote the development of the list of alternative water sources and solutions included in the report.
- Recommendation # 3: Lengthening the maximum groundwater permit term to fifteen years by changing the statutory language in Virginia Code Section 62.1-266(C).
- Recommendation # 5: General Assembly create incentives for local governments and well owners to connect to the public surface water systems when reasonably available, with credits to localities to help lower connection fees or to provide low cost financing.
- Recommendation # 6: General Assembly require new non-agricultural irrigation wells only from unconfined aquifers in the EVGMA where available and adequate.
- Recommendation # 9: General Assembly authorize DEQ to develop and implement a groundwater banking system.
- Recommendation # 10: General Assembly direct DEQ with a timeline and resources to create a framework in consultation with stakeholders for an EVGMA groundwater trading program to be submitted to the General Assembly.
- Recommendation # 11: General Assembly provide funding to ensure a robust groundwater management program due to the importance of groundwater resources in Eastern Virginia and the unsustainable rate of demand on the resource. Chesapeake believes DEQ activities listed in the report should all be funded.
- Recommendation # 12: General Assembly fund the essential operation costs of DEQ to successfully manage the groundwater resources, first through General Fund Appropriations, and second, if absolutely necessary, through a reasonable flat fee applied only to households and businesses in the EVGMA. If a fee is applied, the funding provided by the fee shall not result in any reduction of the general funds appropriated.
Uranium mining, milling, and disposal of generated wastes pose health and environmental concerns for Virginians. If uranium mining activities are permitted in Virginia, the City is concerned that radiation and other pollutants from mill tailings may occur and water supplies may be contaminated. Therefore, the City opposes uranium mining in Virginia, and opposes the elimination of the existing legislative moratorium on the mining and milling of uranium in Virginia. Further, the Commonwealth is requested to vigorously oppose federal court actions to overturn the moratorium on uranium mining.
SOLID WASTE OR OTHER SURCHARGES
The City opposes the imposition of a state fee or surcharge on water, sewer, or any other local government service.
STORMWATER LOCAL ASSISTANCE FUND (SLAF) - UPDATED
The City is requesting the Governor and General Assembly allocate $50 million in the fiscal year 2019 budget to the Stormwater Local Assistance Fund (SLAF), which will allow localities throughout the Commonwealth to implement urban stormwater management practices as described in Virginia’s Watershed Implementation Plan. These funds will also assist localities to meet costly state and federal stormwater permit requirements. The City is grateful to the General Assembly for creating the Stormwater Local Assistance Fund (SLAF) and appropriating $20 million in FY2017 for the fund. The purpose of the fund is to provide matching grants to local governments implementing best management practices that cost effectively reduce pollutants in stormwater runoff. The City of Chesapeake was fortunate to be awarded $1.25 million in FY2014 for the Washington Manor Outfall project in the Deep Creek area of the City; $412,000 in FY2015 for a wetlands bench project on Yadkin Road ($74,500) and the 22nd Street wet pond ($337,500); and $1.7 million in FY2017 for the New Mill Regional BMP ($1,022,975) and the Meads Court Regional BMP ($684,228).
NUTRIENT ALLOCATIONS CURRENTLY ASSIGNED TO EXISTING MUNICIPAL WASTEWATER TREATMENT PLANTS - UPDATED
The City of Chesapeake opposes legislation which would restrict or limit nutrient and sediment trading between sectors as currently allowed, including between MS4 (Stormwater), Wastewater, and Agriculture. In order to meet the goals set out in the Chesapeake Bay TMDL, localities need all available cost-effective options to reduce nutrient and sediment loads, as well as regulatory certainty for planning and funding.
The implications are that this concept is a serious threat to localities, especially in the Chesapeake Bay watershed. Adverse consequences could include:
- Disruption of major recent local wastewater treatment investments made to comply with the Chesapeake Bay TMDL over the past 5-10 years;
- Stranding of existing constructed treatment capacity and associated loss of capacity of local growth and economic development;
- New, extremely stringent, and costly treatment over and above EPA Chesapeake Bay TMDL levels;
- Disruption of existing or planning nutrient trades between or among wastewater facilities and or municipal separate storm sewer systems;
- A precedent for potentially taking away water supply (withdrawal capacity) from existing water suppliers to transfer to new facilities where the source is already fully allocated.
Posted Online: Jan. 30, 2018