Regulatory Comment Letters

September 30, 2020
Letter to Florida Department of Environmental Protection

SWEMA encouraged Florida DEP to build a state-wide, stormwater BMP evaluation program should includes an understandable and consistent process for the evaluation of new BMPs and encourage acceptance of those that meet or exceed applicable performance standards so as to drive new innovations within stormwater management. PDF of the letter

March 23, 2020
Letter to Virginia's Governor Ralph Northam

SWEMA encouraged the Governor to sign the HB882 bill. PDF of the letter

 
February 27, 2020
SWEMA Reviewed and Provided Comment on the Minnesota MTD Research Enhanced Filtration Credit

Minnesota drafted a document on MTD enhanced filtration credit. SWEMA was able to provide comments and get clarification on various points in the draft document. PDF of the letter

 
January 27, 2020
SWEMA Comments on Virginia legislature House Bill HB882

Virginia's legislator will be voting on House Bill 882 pertaining to stormwater. SWEMA provided comments on this pending legislation. PDF of the letter

 

August 9, 2019
SWEMA Submitted Comments on EPA's Chapter 3 - Best Management Practices for Reducing Trash in Stormwater

This document lists BMPs commonly used to address trash/gross solids, both structural and nonstructural. This includes information on cost and efficacy along with highlighted applications.  PDF of the letter

 

June 10, 2019
SWEMA provides input into the Virginia's Department of Environmental Quality's Guidance Memo

Virginia DEQ has drafted a document Interim Use of Stormwater Manufactured Treatment Devices (MTDs) Technical Criteria, Part IIB Water Quality Design Requirements. SWEMA members provided comments on this draft covering,allowance for multiple pathways for approval of MTDs, increase percent total phosphorus (TP) removal, request a transition period from the interim guidance to the proposed guidance, and  hydraulic loading rates. PDF of the entire letter.

 
January 31, 2019
SWEMA Submitted Comments on Proposed Changes to NJDEP Stormwater Regulations

The Stormwater Equipment Manufacturers Association (SWEMA) strongly supports stormwater management strategies and regulations that incorporate advances in stormwater science, encourage innovation, and successfully protect and restore receiving waters at an affordable cost for our communities.  The changes to New Jersey stormwater regulation proposed by the New Jersey Department of Environmental Protection (NJDEP) will not promote these objectives. SWEMA members offered information on the proposed changes. PDF of the entire letter.

 

January  16, 2018
SWEMA's Response to City of Indianapolis Update to the Applicable Standards for the Evaluation and Acceptance of Manufactured Stormwater Treatment Devices

The Stormwater Equipment Manufacturer’s Association (SWEMA) understands that the City of Indianapolis is currently in the process of updating the applicable standards for the evaluation and acceptance of manufactured stormwater treatment devices.  Additionally, it is our understanding that once updates to the applicable criteria have been completed, all of the technologies currently approved by the City must be retested in full compliance with the updated criteria.  PDF of the entire letter

 
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