The Virginia Agribusiness Council is thankful for the opportunity to provide public comments regarding the Department's Guidance Memo No. 22-2012, Stormwater Management and Erosion & Sediment Control Design Guide. The Council appreciates the Department's clarification regarding solar project compliance with Virginia's Stormwater Management Program (VSMP). VAC continues to support proper mitigation of solar projects to reduce nutrient loads into the Chesapeake Bay, and we support all sectors playing an equal role in achieving our Bay goals. 

 

Furthermore, we appreciate the Department developing and publishing for comment this guidance document, which includes updates that pertain to solar installation projects, as referenced and explained in Director Rolband's April 14, 2022 memo. The Council believes including these projects in the program and the requirement of appropriate practices compliant with VSMP and in line with the Chesapeake Bay Program Model will allow the Commonwealth to receive credit for compliance for associated nutrient load reductions. This will increase the likelihood that Virginia is able to comply with its requirements under the Phase III Watershed Implementation Plan (WIP).

 

Once again, we appreciate the Department's attention to this matter and look forward to continuing discussion about solar site mitigation specifically in the HB 206 Regulatory Advisory Panel and also engaging further on stormwater requirements in general.

 

Thank you,

Brad Copenhaver, Meadowview Strategies, LLC 

on behalf of the Virginia Agribusiness Council