On behalf of the Chesapeake Bay Foundation (CBF) please accept this letter as formal comment regarding the Notice of Intended Regulatory Action for the Virginia Pollutant Discharge Elimination System General Permit for Sewage Discharges less than or equal to 1,000 gallons per day [9 VAC 25 -110].  CBF believes amending and reissuing of the general permit represents an opportunity to improve the state’s capacity to meet the pollution reduction requirements of the Chesapeake Bay Total Maximum Daily Load (TMDL) and protect our aquatic resources.  Currently the general permit contains no monitoring requirements or discharge limitations for nitrogen or phosphorous.  CBF believes that implementing monitoring requirements and discharge limitations for these parameters would improve the state’s quantification of nutrient loads and present an opportunity for further nutrient reductions to help comply with the Chesapeake Bay TMDL. 

CBF respectfully requests to be included on the Technical Advisory Committee for the development of these regulations.  CBF is uniquely positioned to provide technical advice on these proposed regulations as our organization has engaged for many years in regulatory matters concerning water quality of the Bay and Virginia rivers.  CBF would be represented by Dr. Joe Wood of CBF’s Richmond Office who has over five years’ experience working on water quality, nutrient loading and point source discharges.  CBF very much appreciates the opportunity to provide these comments.  We hope our comments will be beneficial to the process of amending and reissuing the general permit.  If you have any questions regarding these comments, please feel free to contact me at (804) 780-1392 or jwood@cbf.org.    

Sincerely,

Joseph D. Wood

Virginia Staff Scientist

cc:         Ann Jennings, Virginia Executive Director, CBF

             Peggy Sanner, Virginia Senior Attorney and Assistant Director, CBF

             Chris Moore, Virginia Senior Scientist, CBF