There is already too much muddy sediment in many of the streams and rivers of the Shenandoah Valley.  In some places the bottom of the streams are choked with silty sediments that smother the benthic life, spoil the fishing, get easily stirred up and make fishing and boating access more difficult.  The excessive nitrogen and phosphorus that comes with the storm water run-off causes algae blooms, and causes conditions that favor overgrowth of bacteria that are harmful to both people and aquatic life. 

Storm water run-off contributes a substantial amount of pollution to our waterways.  In the karst (limestone) geology of the Shenandoah Valley where surface waters and ground waters frequently mix, polluted storm water can easily impact ground water.  Because a large portion of the population depends on ground water for their drinking water, it is extremely important that storm water be kept as clean as possible.

I have seen too many instances of muddy soil sediments running off from construction sites in Page County and other nearby jurisdictions.  Therefore I ask that the Commonwealth of Virginia do more to protect streams that are already ‘impaired’ from the additional damage caused by sediment running off from construction sites.

Please add requirements to this General Permit for Discharges of Stormwater from Construction Activities to require full and effective implementation of the Erosion and Sediment Control Plan as a primary condition for continuation of the Stormwater General Permit.  Please strengthen the enforcement of Erosion and Sediment Control Regulations and make violations of E&S Regs. a serious violation of the Stormwater Permit.  Please add a provision to the regulations that would require suspension of work other than erosion and sediment control activities, from the time that an erosion and sediment control violation occurs until the erosion and sediment control measures are re-established and any sediment that had left the site have been cleaned up.  The present regulations do not have enough serious consequences for violations.  Without the addition of more serious consequences, it will not be possible to fully enforce the improved regulations.

It is very important that Virginia take action now to make substantial improvements to the Stormwater Permit regulations now so that our streams do not get even more impaired than they are already and to protect ground water in areas with karst (limestone) geology.

Thank you for the opportunity to comment.

Charles Newton

Shenandoah Valley Soil & Water Conservation District, Director

cnewt1@yahoo.com