To DCR and Distinguished Members of the Virginia Soil and Water Conservation Board,

Thank for all of your efforts in developing Regulations which attempt to address nutrient pollution generated by stormwater from development.  Having seen several of the public comments, I'm going to concentrate on some technical ones:

• The definition for "Small Construction Activity" in 4VAC50-60-10 needs to be refined to coordinate with the CBPA Act.  Add to the end of the second sentence of the definition for "Small Construction Activity" to read "Small construction activity also includes the disturbance of less than one acre of total land area that is part of a larger common plan of development or sale if the larger common plan will ultimately disturb equal to or greater than one and less the five acres, or within jurisdictions designated as subject to the Chesapeake Bay Preservation Area Designation and Managment Regulations equal to or greater than 2,500 square feet and less than five acres.
• To accurately reflect the capabilities of the stormwater management practices the Land Cover Guidance for the Impervious Cover paragraph of the Virginia Runoff Reduction Spreadsheet should be revised to state Since Green Roofs do not reduce pollutant load and Constructed Wetlands and Wet Ponds do not provide runoff reduction, include these areas as impervious in the Pollutant Load Calculations but pervious in the Channel and Flood Protection Calculations.  Pervious pavement can handle up to 10-year design storm flows and, therefore, should be included as pervious areas.

Thank you.