I question the definition of "Physically interconnected" especially as it applies to Counties.  VDOT maintains all roadway drainage systems and they are interconnected to the Counties systems throunghout.  Is that the intent of the definition?

Under Sec. I B 8 and 10 reference is made to stormwater discharges in gallons.  Stormwater is usually measured in cubic feet per second as a flow, is it intended to then convert flow to volume?

Under Section II A it states that our program plan must have a public comment period prior to submittal.  Since the program plan is required by state and federal laws, what is the purpose of public comment on it.  We are already required by law to hold public comment for ordinance changes and make the program available for public view.  It seems like another unnecessary step to go through.

Under Section II B 3 reference is made to the EPA guidance manual.  Is it appropriate to list this specifically in the regulations.  If the document changes, do the regulations need to be changed.  Other documents are referenced elsewhere. 

Section II B 3 b. again references physically intereconnected systems for mapping.  Does this mean we must include VDOT systems in our mapping?  Is DCR going to require them to provide this information to localities?   (It seems to say that in g.)

I also noticed the word plant instead of plan (line 1304) in Section II B 4 a. (2)

I have another concern with regard to the time period expected to implement these changes.  It has taken us 5 years to get to this point, with the additions of the TMDL and monitoring requirements, as well as mapping and inspection of all outfalls, it may be unrealistic to expect these in a short period of time.  Especially as budgets and programs are planned in jurisdictions.