1)      It is the City’s request that municipalities that are already regulated under the Department of Conservation (DCR) MS4 storm water program be exempt from this regulation. This would be effectively layering the regulatory process, which is not beneficial and would only result in additional paperwork and permitting costs that are unnecessary for cities/counties in the Commonwealth.

2)      The City would request an exemption for jurisdictions within the Commonwealth that own, maintain, and operate their own water supply reservoirs for drinking water purposes. These water supplies have historically been responsible for treating aquatic weeds and algae for water quality control purposes for the control of organics entering the Water Treatment facility. These Water Treatment Plant’s (WTPs) are permitted and regulated by the Virginia Department of Health (VDH) and as such should not fall under a separate VPDES permit.

3)      Currently, the City is monitoring and reporting under the Department of Environmental Quality (DEQ) Individual VPDES permit for discharges that occur at an outfall into Broad Run. Since the Algaecide applied at the Lake is housed on the Water Plant property, this chemical is reported in our current VPDES permit as a method of algae removal from our Lake

4)      The City requests an exemption for municipalities currently under water quality monitoring programs to maintain water quality issues as they arise. The City’s main water supply, Lake Manassas, has been continuously monitored for various water quality indicators through the Occoquan Watershed Monitoring Laboratory (OWML) through Virginia Tech., since the 1970’s. Additional monitoring and testing is redundant.