General Permit for West Virginia NPDES Construction Stormwater

The General Permit for NPDES Construction Stormwater General Permit No. WV0115924 is currently open for public comment. This permit is essential for protecting water resources in the region. This permit is put out to public comment every five years, and then for five years it covers all construction that doesn’t need its own permit. This is a prime opportunity to ask the DEP to add protections for construction in karst areas. The current draft is a direct copy of the last permit. This is despite the Environmental Quality Board (EQB) suggesting in its final order for 20-04-EQB (Jefferson County Foundation’s appeal of Rockwool’s Stormwater Construction General Permit) that the WVDEP provide better guidance on Karst Mitigation Plans.

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Public Comments GENERAL WV/NPDES WATER POLLUTION CONTROL PERMIT STORMWATER ASSOCIATED WITH CONSTRUCTION ACTIVITIES WV/NPDES PERMIT NO. WV0115924

First Name

Last Name

Dear Director Katheryn Emery, Division of Water and Waste Management:

I am writing to urge you to make modifications to the draft Construction Stormwater General Permit NO. WV0115924 to better protect water quality in areas with karst topography before issuing the permit.

1.	Please require Enhanced BMPs in all Karst topography regardless of the Tier of the receiving water.

2.	Under section II.I.2.C please better defined the “Karst Mitigation Plan.” Please require that a preliminary and detailed site investigation be done to inform the individual site Karst Mitigation Plan as outlined in CSN TECHNICAL BULLETIN No. 1 STORMWATER DESIGN GUIDELINES FOR KARST TERRAIN IN THE CHESAPEAKE BAY WATERSHED VERSION 2.0, and that mitigation is based on the information in CSN TECHNICAL BULLETIN No. 1 STORMWATER DESIGN GUIDELINES FOR KARST TERRAIN IN THE CHESAPEAKE BAY WATERSHED VERSION 2.0 and Appendix C Stormwater Management Design in Karst Areas of the West Virginia Stormwater Management and Design Guidance Manual West Virginia Department of Environmental Protection November 2012.

3.	Pease require that only preferred and adequate practices as defined in the CSN TECHNICAL BULLETIN No. 1 STORMWATER DESIGN GUIDELINES FOR KARST TERRAIN IN THE CHESAPEAKE BAY WATERSHED VERSION 2.0 be used in stormwater management in Karst.

4.	Under section “III.B.2.e. Requirements for self-inspections” please add provisions for all areas with karst topography that ensure that all new sinkholes are identified, reported, and remediated in a timely manner and any unpermitted discharge to a new or existing sinkholes is identified, reported, and remediated in a timely manner.

I respectfully request that you make these changes before issuing this General Permit.

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