Greetings,

In the coming year, my community will see a major new condo development go up next to one of our city parks in Chesapeake, Virginia.  This development will be on the headwaters of the Indian River, an impaired waterway.  As such, I have increased interest on aspects of the Construction General Permit.  After discussing this revised document with contacts at the Chesapeake Bay Foundation, I wish to commend the agencies for several positive aspects of the new permit including the continued requirement for the developer to meet all applicable water quality standards, continuing to require the SWPPP to be avaialble for public review, and required the use of pollution credits to be well documented.

Two area where the document could be improved include 

1) the Inspection Schedule - the current requirement for development by impaired waterways is for every 4 days OR every 5 days and within 1 day of a stormevent; except if it happens over a long weekend when the next business day may be 4 or 5 days away.  If there is a storm event, we really should require inspection with 24 hours; yes that may mean doing an inspection on a non-business day, but we really don't want damaged mitigation systems to go unfixed, especially if more rain is forecast.  Let's tighten this up!

2) Sediment runoff is a major concern.  I do not think it would be unreasonable to require the site operator to monitor turbidity in the runoff from the construction sites and take proactive steps to eliminate sediment runoff in alignment with their SWPPP.

Thank you for your consideration

Rogard Ross

3800 Rivercrest Pl, Chesapeake, VA 23325