Loudoun Water appreciates the time and efforts of the Virginia Department of Health (VDH) in consolidating the project review project and permit procedures. This effort offers a cohesive approach and effectively outlines various activities. 

With respect to the Project Review & Permit Procedures Manual, Loudoun Water has the following comments:

Chapter 9. Section 9.1 Storage Capacity. Equalizing storage may vary greatly depending on water production facilities ability to operate at variable rates.  The required storage volume has been a system by system decision based upon supply reliability, redundancy of connections, water quality concerns and variability in demands and therefore, 0.5 *maximum day demand may be too much or too little storage.  Loudoun Water suggests changing the wording to average day demand, as a guidance. 

Chapter 10. Section 10.1 Storage Design Exceptions.  Please clarify minimum requirement 4. Model extended period simulation of MDD with fire flow added during the peak hour;.  Is the intent to model fire flow at peak hour demands?  This deviates from what has typically been requested for storage evaluation in the past.

Loudoun Water appreciates the opportunity to review and comment on the proposed guidance. 

Please contact me at 571-291-7745 or jedwards@loudounwater.org if you seek any additional information.

Sincerely,

Jessica Edwards-Brandt

Director, Water Operations 

Loudoun Water