Agencies | Governor
Virginia Regulatory Town Hall
Department of Conservation and Recreation
Virginia Soil and Water Conservation Board
Stormwater Management Regulations RENUMBERED AS 9 VAC 25-870 [4 VAC 50 ‑ 60]
Action Establish water quality criteria for new development activities within the Chesapeake Bay Watershed
Comment Period Ends 2/3/2010
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2/3/10  1:28 pm
Commenter: David Warriner, PE

Problems with the regulations

Two issues that occur during the design/review phase of plans involving runoff. There is verbiage in the regulations associated with maintaining pre-developed runoff volume. Almost all developments are going to increase volume and peak rates. Controlling peak rates is relatively simple, it's just a matter of the appropriate detention design. Volume is another matter. Infiltration works well in some parts of the state, but in others either the clay content or Karst make infiltration unfeasible. This leaves reuse as the other option. Most developers do not want to get into double plumbing to utilize gray water for flushing. It also adds pumps that would have maintenance issues and the problem with power outages affecting the ability of graywater plumbing working in a building. The other alternative is irrigation. Many developments do not want or need irrigation. This leaves a quandry on what to do with the increased volume.

The second issue is the adequate channel criteria. Many sites drain to wetlands. These wetlands have little if any channels in them. Creating a channel is considered an impact by USACOE and DEQ. There needs to be an alternative design allowed to discharge into wetlands. My experience is that every regulator has a different opinion on what constitutes an adequate conversion from man made improvements, (storm pipe or ditch) into the wetlands.




CommentID: 11266