Virginia Regulatory Town Hall
Agency
Department of Conservation and Recreation
 
Board
Virginia Soil and Water Conservation Board
 
chapter
Impounding Structure Regulations [4 VAC 50 ‑ 20]
Action Amend provisions of Virginia’s Impounding Structure Regulations to enhance the Dam Safety Program and to improve public safety.
Stage Proposed
Comment Period Ended on 10/19/2007
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10/16/07  2:25 pm
Commenter: David Campbell, P.E., Schnabel Engineering

Comments on Proposed Impounding Structure Regulations
 

I had the opportunity to attend the public hearing on October 10th at the Henrico County Government Complex.  The public comment presented that evening was quite compelling in regards to personal experiences during the August 1969 flood in Nelson County, Virginia (Hurricane Camille).  That testimony tangibly evidenced the reality of rainfalls approximating probable maximum events and provided a compelling and visceral authenticity to the havoc and destruction that can result from such an event.  Unfortunately, because of the horror and severity of that experience, the speaker draws the conclusion that nothing can be done to lessen the ravages of an extreme storm event. 

 

It is true that in the midst of an event of this magnitude, available latitude for action will be quite limited and the clarity of emergency responders in making spot judgments will be considerably compromised.  However, this merely points to the need for and benefits of planning and preparedness with regards to these events.  The concentrated flood wave from a dam failure would be additive to the already extreme flood conditions that would prevail.  Dam failures can indeed worsen the consequences of extreme flood events.  Where the failure of an impounding structure due to inadequate spillway capacity can be shown to significantly increase the severity and/or extent of flood impacts, the provision of sufficient spillway capacity for passing a probable maximum flood will ultimately prevent injuries and the loss of additional lives, and prevent significant additional damages to property.  If the extent of additional flooding resulting from a dam failure can be shown to be small for extreme flood events, then the Department has provided a process whereby lesser spillway flood passage criteria can be applied (proposed incremental damage assessment: 4VAC50-20-52). 

 

With regard to emergency response, the speaker implied that, in the face of such extreme events, preparedness activities are of little to no value.  Preparedness is a sacred foundation principle for the military, for police, for fire fighters and for emergency responders of all types.  The presence of an emergency response document, together with a commitment to undertaking drills and exercises, is not sufficient to prevent or mitigate disaster.  However, preparedness in knowing available options and opportunities in advance and having simulated extreme events will, by definition, make critical knowledge more readily available, enhance communications, define action plans to be implemented in the absence of available communications, and improve decision making and decision support under stressful, rapid-response conditions.  Prepared owners and responders do indeed derive purposeful benefits, even under extreme circumstances.

 

CommentID: 510