Virginia Regulatory Town Hall View Comments

Department of Environmental Quality

State Water Control Board

Guidance Document Change: This guidance document provides for: 1) a streamlined stormwater management (SWM) plan review process in instances where DEQ is the Virginia Stormwater Management Program (VSMP) authority and 2) a streamlined erosion and sediment control (ESC) plan review process where DEQ is the Virginia Erosion and Sediment Control Program (VESCP) authority when the following conditions are met: • The SWM and/or ESC plan is prepared by a professional engineer licensed to engage in practice in the Commonwealth under Chapter 4 of Title 54.1 of the Code of Virginia, • The SWM and/or ESC Plan is pre-reviewed and signed by a person who holds an active certificate as a Dual Combined Administrator for ESC and SWM, and • A completed Plan Submission Checklist is submitted with the SWM and/or ESC Plan on the cover sheet.

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8/31/22 6:17 pm

Commenter: Martha Moore, Virginia Farm Bureau Federation

Guidance Memo No. 22-2012 and No. 22-2011

The Virginia Farm Bureau Federation (VFBF) appreciates the opportunity to submit comments to the Department of Environmental Quality on the Stormwater Management and Erosion Sediment Control Design Guide, No.22-2012.

Virginia Farm Bureau is the Commonwealth’s largest general farm organization, representing more than 33,000 farmers of nearly every type of crop and livestock across Virginia. Farm Bureau and its members have worked together to build a sustainable future of safe and abundant food, fiber, and renewable fuel for the United States and the world.

VFBF appreciates the Department’s work to clarify solar projects’ compliance with Virginia’s Stormwater Management Program. We supported DEQ’s March 29, 2022 technical memorandum implementing a stronger post-development stormwater management policy for solar projects. Farm Bureau supports proper mitigation of the impacts of solar projects to reduce nutrient loads to the Chesapeake Bay. This organization has long supported all sectors should work towards achieving our Chesapeake Bay goals.

We believe evaluating the solar panels as unconnected impervious areas aligns with how these areas are assessed in the Chesapeake Bay Program Model. This will allow Virginia to take credit for compliance and increase the likelihood of our complying with the Third Phase of the Commonwealth’s Watershed Implementation Plan (WIP).

We recognize that this guidance is complimentary to Guidance Memo No. 22-2011. In that plan information, we appreciate requiring the plan to identify prime farmland in the Land Cover Tabulation. We would hope that this step would help the developer of the solar facility to avoid locating these facilities and panels on prime farmland or minimizing the impact to such areas.

The Virginia Farm Bureau Federation respectfully submits these comments and appreciates the Administration’s attention to this issue and look forward to continuing to work on mitigation efforts on-site of renewable energy projects during the planned Regulatory Advisory Panel as designed in HB 206.

Martha Moore

Senior Vice President Governmental Relations

Virginia Farm Bureau Federation

CommentID: 127486