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HRPDC Submits Comments on DEQ Study of the Effective Use of Stormwater BMPs in Areas with a Seasonal High Water Table

HRPDC Submits Comments on DEQ Study of the Effective Use of Stormwater BMPs in Areas with a Seasonal High Water Table

In response to 2015 Virginia General Assembly House Joint Resolution Number 587 (https://legiscan.com/VA/text/HJR587/id/1194258), the Department of Environmental Quality (DEQ) is evaluating the existing design specifications for best management practices (BMPs) listed on the Virginia Stormwater BMP Clearinghouse to allow the effective use of these BMPs in areas with a seasonal high groundwater table.   The existing design specifications often require a minimum separation distance of two feet between the stormwater practice and the water table to allow for infiltration and to protect the groundwater.  In coastal areas like ours, two feet of separation is often not achievable.  

DEQ is required to submit reports of their findings and recommendations to the General Assembly.    A draft of the second report (http://www.deq.virginia.gov/Portals/0/DEQ/Water/StormwaterManagement/Groundwater_2016.12.7_DRAFT.pdf?ver=2016-12-07-082314-3500) was released on December 6, 2016, and DEQ held a public meeting on December 9, 2016 to solicit stakeholder input.  The public comment period closed on December 16, 2016. 

Floating wetlands
Floating Wetlands
Urban Stream
Urban Stream

The Hampton Roads Planning District Commission submitted comments in person at the public meeting and later in a memo.   HRPDC recommends expanding the list of BMPs included in the BMP Clearinghouse.  We suggest adding the urban stormwater BMPs that have been approved by the Chesapeake Bay Program (CBP), such as urban stream restoration, floating treatment wetlands, urban filter strips, shoreline management, and urban tree canopy expansion, etc.  These BMPs have been through a rigorous CBP Expert Panel process.  Many of the multiple separate storm sewer systems (MS4s) that experience a seasonal high water table are located in the Chesapeake Bay watershed and are taking advantage of these newly approved BMPs as they work towards meeting the Chesapeake Bay Total Maximum Daily Load. Currently, only the MS4s can use the CBP-approved BMPs for phosphorous removal credit.  These options should be extended to the development community. 

In addition to expanding the number of stormwater management tools available, HRPDC also recommended that:  1) the regulations and the BMP Clearinghouse allow flexibility in BMP selection and 2) a clear process be established for seeking DEQ approval of innovative BMPs.  This would allow private developers to take advantage of the newest technologies in stormwater management. 

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