Virginia Regulatory Town Hall
Department of Environmental Quality
State Water Control Board
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12/5/23  11:49 am
Commenter: Alice Frei

General VPDES Permit for Discharges of Stormwater from Construction Activities (9VAC25-880)

I ask you to reject the renewal request for permit General VPDES Permit for Discharges of Stormwater from Construction Activites (9VAC25-880). 

Proper studies have not been done to meet the burden of proof that this permit protects Virginia waterways. Data shows that our waterways are becoming more and more polluted This permit is not legal since data has not been analyzed and the permits assumption that 'all is well' is not valid.

My name is Alice Frei. I am a volunteer with Rivanna Conservation Alliance (RCA). RCA has been monitoring streams and rivers in the Rivanna Watershed for 20 plus years. The Department of Environmental Quality collects data form specially trained RCA personnel and uses that data to determine stream health. I have been a monitor for 6 years. Over that time I have observer the Rivanna Watershed become more and more polluted.

Fine sediment runoff is one of the main caused of stream impairment. Sediment (including fertilizers and litter) can enter the water through agriculture use, urban runoff and construction sites. Fine sediment washes downstream covering water, rocks and stream bottoms. This fine sediment clogs the breathing apparatuses of organisms in the stream and effectively 'kills' stream life.

In 2015 there were 23 Rivanna Watershed Streams considered by DEQ to be impaired.

In 2022 there were 36 Rivanna Watershed Streams considered by DEQ to be impaired.

This is an increase of impairment of almost 40 %.

2015-2017 23
2016-2018 30
2018-2020 40
2020-2022 36*

*Construction in Virginia was reduced in 2020 due to Covid 19.

Local news has reported the continued deterioration of our streams.

Where is this sediment coming from? Predominately agriculture and construction sites. Poor farming practices are definitely a source of sediment. However, in Virginia, farmland use has markedly decreased over the past 20 years, while construction has markedly increased.

Since other sources of sediment have not changed or have decreased one must consider the source is, to some degree, construction site runoff.

The situation now is failure based on data.

I ask you to please reject this permit.

Thank you for your time reading this. I hope you will consider rejecting this permit and writing one that will protect our waters.


Alice Frei.

I can be reached at



CommentID: 220725