Thank you for allowing us the opportunity to comment on the proposed guidance document: Virginia’s Nonpoint Source Implementation Best Management Practice Guidelines – FY 2020. We believe that by working together, we can continue to improve water quality in Virginia, the Chesapeake Bay, and beyond. We want to comment on the reference to Urban BMPs in Table 2 on page 5.

We believe that the references to the Virginia Stormwater BMP Clearinghouse could lead to confusion. We believe that this guideline document is intended to allow all approved practices (1-17) currently listed on the Stormwater BMP Clearinghouse. We don’t believe that this guideline actually excluded Manufactured Treatment Devices (MTDs), or should be excluded, from this program because, in some cases, proprietary MTDs are the only practical option to treat stormwater in urban and ultra-urban areas.

Since we have already heard some confusion on this issue, we humbly request that page 3 include a comment that all practices on the Virginia Stormwater BMP Clearinghouse are eligible unless expressly excluded.

Thank you again,

Jared MacKenzie

Regional Regulatory Manager - East