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.

Sincerely,


Jared Webb, PE