| Action | Amend and Reissue the General Permit for Discharges of Stormwater from Construction Activities |
| Stage | Proposed |
| Comment Period | Ended on 6/7/2013 |
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Attn: State Soil and Water Conservation Board
Comments on Virginia Stormwater Management Program (VSMP) Permit Regulations (4VAC50-60)
Friends of Accotink Creek (accotink.org) encourages you to reinstitute the public availability of Stormwater Pollution Prevention Plans (SWPPP) in the Construction General Permit.
Friends of Accotink Creek is an all-volunteer local environmental group dedicated to protecting and restoring the Accotink watershed. We lead trash cleanups, invasive removals, and educational activities. Thousands of citizens have worked with us over the years to improve the Accotink watershed community.
Construction-related erosion and sediment control issues are one of the many challenges that the Accotink watershed faces. Friends of Accotink Creek works with non-profits, local government agencies, and developers to monitor, document, and report construction-related erosion and sediment control issues, in order to reduce sediment contamination and degradation of the watershed. We often encounter E&SC issues that have not been properly addressed. Public access to the SWPPPs is an important resource in addressing this issue.
The officers of the Commonwealth, while providing critical technical review, cannot perfectly monitor compliance of all construction sites with filed SWPPPs. Concerned citizen's groups and members of the public have a legitimate role in ensuring that erosion and sediment controls and stormwater management measures incorporated into a SWPPP are implemented and maintained in accordance with the plan. We urge that the proposed regulation be changed to reflect this role:
1. Operators with day-to-day operational control over SWPPP implementation shall have a copy of the SWPPP available at a central location on-site for use by those identified as having responsibilities under the SWPPP or concerned members of the public whenever they are on the construction site. The documents shall also be posted and indexed online.
Thank you for your consideration in this matter,
Kris Unger / Primary Conservator, Friends of Accotink Creek