As an active environmentalist who is very familiar with the negative impacts of inadequate sediment control structures over the years in Virginia, I strongly encourage Virginia to strengthen sediment control standards and construction oversight, in adherence to the EPA's Clean Water Act. I have witnessed, documented, and reported numerous sediment control failures at construction sites that have resulted in heavy dumps of silt and sediment in downstream creeks and streams. I am an avid hiker and kayaker, and I see the negative effects of construction site run-off, increased sedimentation and impermeable surfaces in Virginia's watersheds.

Sediment control structures are a trivial component of most construction projects. Actual adherence to Virginia's legal standards would significantly reduce the number of construction-related contmination events. Raising the bar would increase project costs by an insignificant fraction of a percentage, but would significantly reduce the number of contamination events, as well as their severity.

There is no practical way to remove sediment from a stream, once it's been washed off a construction site. There is apparently no rational incentive for construction companies to build sediment control structures any stronger than Virginia's minimal requirements. Given the significant downstream costs of construction-based sediment contamination in Virginia watersheds, and the reluctance of construction companies to go beyond Virginia's standards, I believe that it is incumbent on Virginia to raise her standards, in order to ensure adequate protection of her watersheds. This can be done at minimal cost. 

At present, the state is carrying the expense of construction-based sediment contamination events, in the form of degraded watercourse and increased erosion, the related negative impacts on downstream fisheries and the degraded health of the Cheseapeake Bay. Given the increased frequency of what once were five and ten year storms, the current standards are inadequate. They serve as a trivial and short-term subsidy of construction projects, that result in serious, and long-term costs. This is not good economics.

I support the Shenandoah & Potomac Riverkeeper's recommended changes to the Construction General Permit, including making SWPP's available to the public. This is a minimum standard of communication with the citizens of Virginia, who are affected by pollution and degradation of the natural places and watersheds entrusted to the state. I encourage Virginia to set a higher standard for environmental protection, and to resist following the short-term and self-interested advice of companies more concerned about profit than Virginia's long-term well-being.

Thanks for your time, Kris Unger