The Thomas Jefferson Soil and Water Conservation District (TJSWCD) would like to commend DCR for their efforts to amend the Virginia Stormwater Management Program (VSMP) Permit Regulations.  As the process moves forward, we hope that DCR will recognize the importance of local administration of the program, and will provide the necessary incentives to ensure that “non-Tidewater” and “non-MS4” localities choose to request delegation of the program.  (This may require that greater than 70% of the stormwater permit fees remain with the locality.)  If localities do not request delegation, Soil and Water Conservation Districts should be offered the opportunity to administer the program on DCR’s behalf.  Local administration of the program (either by the locality or by Soil and Water Conservation Districts) will maximize efficiencies and will allow essential coordination with other established local procedures within the development process. 

The TJSWCD also urges DCR to ensure that, regardless of where the program administration lies, review of Stormwater Pollution Prevention Plans (SWPPPs) prior to the issuance of permits, is a required element of the program.

Additionally, to avoid confusion and the need to meet multiple requirements intended for the same effect (protection of downstream properties and waterways from increases in volume, velocity and peak flow rate of stormwater runoff), a project that complies with the new Stormwater Regulations should be deemed to meet the requirements for Minimum Standard #19 of the Virginia Erosion and Sediment Control Regulations, 4VAC50-30-40. 

Education and information about the VSMP will be an integral part of achieving compliance.  The TJSWCD therefore urges DCR to provide regularly scheduled technical workshops to engineers, review and inspection authorities, the development community, and localities, about the administrative and technical requirements of the program.

Thank you for the opportunity to comment on the upcoming amendments.