The Virginia Association of Soil & Water Conservation Districts (VASWCD) is pleased to offer comments on DEQ's Guidance Memo No. 22-2012- Stormwater Management and Erosion & Sediment Control Design Guide. The VASWCD is a private nonprofit association of 47 Soil and Water Conservation Districts in Virginia. The VASWCD's voting members are all elected and appointed directors. SWCDs were established in the 1930's as political subdivisions of the state in response to the pressing need for conservation of our natural resources in the Commonwealth. The mission of the VASWCD is to provide and promote leadership in the conservation of natural resources through stewardship and education programs. 

Specifically, with respect to Chapter 5.500 of the document, VASWCD recently adopted policy at its annual meeting in December 2022 that speaks to the environmental impact of utility scale solar development in the Commonwealth. The policy calls on the General Assembly to amend the Virginia Clean Economy Act (VCEA) to remove any incentives to convert forest and prime agricultural lands into solar industrial facilities, but instead provides incentives for such solar facilities to be developed on brownfields and on existing residential and commercial structures, where they can contribute to greenhouse gas emission reduction without impairing environmental quality in the Commonwealth. 

Consistent with that policy, we urge DEQ in the Guidance Memo to:

• Ensure that there are no unmitigated water quality impacts of utility scale solar development on the Chesapeake Bay Watershed or southern rivers of the Commonwealth.
• Make the effective date of the Guidance Memo as soon as practical and preferably before the currently proposed date of December 31, 2024. 
• Ensure that the Guidance Memo reflects special sensitivity to the need to protect prime farmland and forested areas from any on-site or offsite impacts of utility scale solar development. 
• Encourage utility scale solar development on brownfields, and on existing residential and commercial structures such as building roofs and parking lots.