Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
State Water Control Board
 
Guidance Document Change: This guidance document has been developed to assist the public and the development community in determining the policies and procedures, which apply to land development in the Commonwealth of Virginia where DEQ serves as the Virginia Stormwater Management Program (VSMP) authority and/or the Virginia Erosion & Sediment Control Program (VESCP) authority. It contains information primarily concerned with the design guidelines for Erosion & Sediment Control Plans and Stormwater Management Plans.
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8/31/22  3:24 pm
Commenter: Jonathan Matheny, MWAA

Guidance Memo No. 22-2012
 
  1. General:  Request inclusion of language clarifying exemptions and exceptions to Erosion & Sediment Control (ESC) and Stormwater Management (SWM) Law/Regulations.  Specifically, as they relate to “routine maintenance” under ESC vs “routine maintenance” under the Virginia SWM regulations; design for linear development projects related to stormwater management; and long-term maintenance agreements.

 

  1. Chapter 2.000, Erosion and Sediment Control:  Recommend including text describing why only 8 of the 39 VESCH Chapter 3 – State Minimum Standards and Specifications are discussed in this section. 

 

  1. Sections 3.302.1, B., 2 and 3.302.2, B., 2. - Define “un-attenuated” and confirm concurrence with 9VAC25-870-66, B. 4., Limits of Analysis.

 

  1. Sections 3.303.1, C. and 2; 3.303.2, B., 2. - Define “un-attenuated” and confirm concurrence with 9VAC25-870-66, C. 3., Limits of Analysis.

 

  1. Section 3.305, SHEET FLOW – General comments
    1. 9VAC25-870-66 criteria for non-erosive flows is the 2-year 24-hour storm event.  The 10-year 24-hour storm event is referenced throughout this section to determine non-erosive flow velocities from sheet flow.  Request revision to the reflect the 2-year 24-hour storm event consistent with other sections of 870-66.
    2. Please define “environmental features” as referenced in this section (e.g., 3.305.1, 4., B.). 

 

  1. Sections 3.305.1, B., 3. and 3.305.2, D.:  Using a 1% slope, this equation results in a sheet flow length for a wooded area of 12.5 ft.  In certain instances, this short of a flow length would require design/installation of a stormwater conveyance system to divert flow, resulting in additional impact to forest/open space.  Suggest revising these sections to account for significantly short sheet flows in dense grass, brush, and wooded areas. 

 

  1. Section 3.307, D. – Please clarify why a drainage easement is required for sheet flow. Example: How would a linear development project comply with this requirement?

 

  1. Section 4.302: Linear Projects are defined here, however, Guidance Memo No. 15-2003 is not referenced.  Suggest referencing the Linear Project guidance memo in this section.

 

 

  1. Section 5.301, D. and 5.302 D – Please provide additional information that supports adjusting HSG by one factor. 
CommentID: 127474