Virginia Regulatory Town Hall
Agency
Department of Conservation and Recreation
 
Board
Virginia Soil and Water Conservation Board
 
chapter
Stormwater Management Regulations AS 9 VAC 25-870 [4 VAC 50 ‑ 60]
Action Amend the General Permit for Discharges of Stormwater from Construction Activities found in Part XIV of the Virginia Stormwater Management Permit Program Regulations and its associated definitions found in Part I of those Regulations.
Stage Proposed
Comment Period Ended on 12/26/2008
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12/4/08  8:03 am
Commenter: John Burke / Gay and Neel, Incorporated

Technology Based BMP Table 1 Does not include 65% P removal bioretention BMP
 

Table 3.11-1 in section 3.11 of the stormwater handbook (bioretention) explicitly shows two target P removal efficiencies based on whether the bioretention BMP is designed for 1xWQV or 2xWQV. Table 1 in section 4VAC50-60-1184. Water quality. does not show bioretention as a viable technology based BMP for the 66% -100% impervious cover range. Infiltration and extended detention BMPs are included in multiple technology based cover ranges based on varying design criteria and the "multiple" of the WQV treated. It seems that the 2xWQV bioretention design should be included as a 65% removal option.

CommentID: 6529