Virginia Regulatory Town Hall
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  9:55 pm
Commenter: Jared Webb, PE, Appalachian Power Company

Appalachian Power Comments on Draft Guidance Memo 22-2011

Appalachian Power Company (APCO) is an Annual Standards and Specifications (AS&S) holder for our electric and communication linear projects, and also have projects that are non-linear within localities where the DEQ is the Virginia Stormwater Management Permit (VSMP) Authority.  We agree with the need for a streamlined plan review process and are in favor of the model framework that DEQ is putting forward.  APCO understands the guidance memo does not apply to AS&S projects but believes DEQ could see the same improvements to review time and staff workload by allowing AS&S holders to approve project variances under Guidance Memo 15-2003 as part of the streamlined process.


APCO has engineering standards that set cover sheet templates for our projects and we ask the DEQ to allow the plan submittal checklist to be included as a General Notes plan sheet or included in a narrative report accompanying the plan set submittal.


APCO has heard from our consultants that there is a concern over the language within Section C regarding audits or compliance inspection results including actions to revoke certifications or engage DPOR is some enforcement action.  These concerns come from past comments received during plan review cycles that may be due to regional differences or changes in interpretation of regulations over time by DEQ.  We believe that the plan review checklist and streamlined process will focus attention of the certified plan reviewer to the regulatory requirements and that sound engineering judgement should be a focus of any audit or inspection.  APCO wants to make sure that our consultants are not jeopardizing their livelihoods or professional licensure over interpretations of the regulations and instead specifically held to the regulations as written and requirements within the General Permit.

We appreciate the opportunity to review and comment on this document.


Jared Webb, PE

CommentID: 128489