Regulatory Comment Letters

September 27, 2017
SWEMA's Response  to "Proposed Use of Structural Stormwater BMPs In Alexandria."

The Stormwater Equipment Manufacturer’s Association (SWEMA) represents a diverse group of stormwater solutions providers as well as supporting associate and professional members. Due to the diverse perspective and expertise of its membership, SWEMA is uniquely qualified to provide a professional prospective on the “Proposed Use of Structural Stormwater BMPs in Alexandria” document that is currently being considered for implementation within the jurisdiction of Alexandria, Virginia.

SWEMA believes that all Stormwater BMPs, manufactured treatment devices and generic green infrastructure BMPs, have appropriate and suitable applications. To remove one sector of BMPs limits a designer’s ability to provide sound engineering solutions to solve complex environmental conditions. In the past, the City of Alexandria has been one of the most innovative jurisdictions in the country by promoting the use of sand filters and various underground stormwater devices. We commend the City of Alexandria for its unique history with respect to advancing stormwater management (SWM) both regionally and nationally. . .  PDF of the entire letter

 
SWEMA's Response to United States EPA and the Department of the Army, Docket ID EPA-HQ-OW-2017-0203

The Stormwater Equipment Manufacturer’s Association (SWEMA) strongly supports the maintenance of the Waters of the United States Rule and definition as promulgated by the Environmental Protection Agency (EPA) and the Department of the Army in 2015 and rejects the recodification of pre-existing rules as proposed in Docket ID EPA-HQ-OW-2017-0203. . . PDF of the entire letter

 
September 8, 2017
SWEMA Responds to Virginia Department of Environmental Quality (VADEQ) on proposed updates to the Virginia Clearinghouse Relative to MTDs.

We appreciate the opportunity to provide feedback to the Virginia Department of Environmental Quality (VADEQ) on proposed updates to the Virginia BMP Clearinghouse relative to manufactured stormwater treatment devices (MTDs). SWEMA’s membership has a number of concerns about the current state of the BMP Clearinghouse as it relates to manufactured solutions. We respectfully offer the following comments for consideration. . . PDF of the entire letter

 

May 15, 2017
SWEMA's comments on Office of Water: Feedback on Reducing Regulatory Burden, Docket ID No. EP-HQ-OA-2017-0190.

The Stormwater Equipment Manufacturer’s Association (SWEMA) strongly supports the maintenance and advancement of national stormwater regulations under the clean water programs of the Environmental Protection Agency (EPA) as well as the continued funding of the EPA. . . PDF of the entire letter