HomeMy WebLinkAboutWPO202000002 Review Comments WPO VSMP 2020-04-10COUNTY OF ALBEMARLE
Department of Community Development
401 McIntire Road, Room 227
Charlottesville, Virginia 22902-4596
Phone (434) 296-5832 Fax (434) 972-4126
VSMP Permit Plan Review
Project title:
VSMP Plan for Horseshoe Farm
Project file number:
WP02020-00002
Plan preparer:
Shimp Engineering, 912 E. High St. Charlottesville, VA 22902
Justin M. Shimp; justin(&shimp-en ing eerin,g corn
Owner or rep.:
Horseshoe CV LLC, P.O. Box 69, Richmond, VA 23218 fiorlandi(a4riverg com ]
Plan received date:
2 Jan 2020
(Rev. 1)
28 Feb 2020
Date of comments:
30 Jan 2020
(Rev. 1)
10 Apr 2020
Reviewer:
John Anderson
County Code section 17-410 and Virginia Code §62.1-44.15:34 requires the VSMP authority to act on any
VSMP permit by issuing a project approval or denial. This project is denied for reasons listed below. The
VSMP application content requirements can be found in County Code section 17-401.
A. Stormwater Pollution Prevention Plan (SWPPP) — Required, although a Linear Project. Please
submit using county template.
The SWPPP content requirements can be found in County Code section 17-405. A SWPPP must contain
(1) a PPP, (2) an ESCP, (3) a SWMP, and (4) any TMDL measures necessary. This SWPPP is
disapproved, and the reasons are provided in the comments below.
1. No SWPPP; please submit using county template. (Rev. 1) Partially addressed. As follow-up:
a. Sec. 1, Registration Statement, Sec. I.A. -Provide tel.# for James Jones, Manager.
b. Sec. 4-5, ESC-SWM plans: Update once comments addressed.
c. Sec. 6A: Provide SWPPP Exhibit that shows locations of:
i. Rain gauge location
ii. Concrete washout location, if any
iii. Solid waste dumpster location, if any
iv. On -site fuel storage location, if any
v. Portable sanitary facility locatio
d. Sec. 6.E.: TBD is a placeholder. Identify named individual responsible for pollution prevention
practices as a pre -requisite to receiving a Grading Permit.
e. Sec. 8, TBD is a placeholder, which is fine. Identify named individual responsible for SWPPP
inspections as a pre -requisite to receiving a Grading Permit
2. Please ref. Horseshoe Farm VSMP /WP02020-00002 on SWPPP cover. (Rev. 1) Partially addressed.
Please include file # WP02020-00002 on SWPPP cover.
B. Stormwater Management Plan (SWMP)
VSMP Regulation 9VAC25-870-108 requires the VSMP authority to approve or disapprove a SWMP. This
plan is approved pending resolution of bridge proposal; items 5.-6., and SWPPP /PPP Exhibit approval.
The stormwater management plan content requirements can be found in County Code section 17-403.
1. Project proposes a network of mountain bike trails through woods. This several mile network of trails is
eligible to be reviewed as a linear project under DEQ Guidance Memo No. 15-2003, Apr 23, 2015 /link:
https://www.deq.vir,ginia.gov/portals/O/DEQ/Water/Guidance/152003.pdf. Under this DEQ policy guidance,
SWM quality /quantity requirements are presumed to be met, provided specific conditions are met.
Engineering Review Comments
Page 2 of 5
Please include the following, verbatim, on title sheet. (Rev. 1) Addressed.
STORMWATER MANAGEMENT CONSIDERATIONS:
-THE PROJECT DOES NOT SIGNIFICANTLY ALTER THE PREDEVELOPMENT RUNOFF CHARACTERISTICS OF THE LAND SURFACE AFTER THE
COMPLETION OF CONSTRUCTION AND FINAL STABILIZATION;
-THE PROJECT IS MANAGED SO THAT LESS THAN ONE (1) ACRE OF LAND DISTURBANCE OCCURS ON A DAILY BASIS;
-THE DISTURBED LAND WHERE WORK HAS BEEN COMPLETED IS ADEQUATELY STABILIZED ON A DAILY BASIS;
-THE ENVIRONMENT IS PROTECTED FROM EROSION AND SEDIMENTATION DAMAGE ASSOCIATED WITH THE LAND -DISTURBING ACTIVITY;
-THE OWNER AND/OR CONSTRUCTION ACTIVITY OPERATOR DESIGNS, INSTALLS, IMPLEMENTS, AND MAINTAINS POLLUTION PREVENTION MEASURES
TO:
-MINIMIZE THE DISCHARGE OF POLLUTANTS FROM EOUIPMENT AND VEHICLE WASHING, WHEEL WASH WATER, AND OTHER WASH WATERS;
-MINIMIZE THE EXPOSURE OF BUILDING MATERIALS, BUILDING PRODUCTS, CONSTRUCTION WASTES, TRASH, LANDSCAPE
MATERIALS, FERTILIZERS, PESTICIDES, HERBICIDES, DETERGENTS, SANITARY WASTE, AND OTHER MATERIALS PRESENT ON -SITE TO
PRECIPITATION AND TO STORMWATER;
-MINIMIZE THE DISCHARGE OF POLLUTANTS FROM SPILLS AND LEAKS AND IMPLEMENT CHEMICAL SPILL AND LEAK PREVENTION AND R
ESPONSE PROCEDURES;
-PROHIBIT THE DISCHARGE OF WASTEWATER FROM THE WASHOUT OF CONCRETE;
-PROHIBIT THE DISCHARGE OF WASTEWATER FROM THE WASHOUT AND CLEANOUT OF STUCCO, PAINT, FORM RELEASE OILS, CURING
COMPOUNDS, AND OTHER CONSTRUCTION MATERIALS; AND
-PROHIBIT THE DISCHARGE OF FUELS, OILS, OR OTHER POLLUTANTS USED IN VEHICLE AND EQUIPMENT OPERATION AND
MAINTENANCE.
2. Proposed bike network is extensive. Show potential points of equipment entry into wooded untraveled and
undisturbed areas. Provide paved construction entrance at each entry point from a paved surface (inspector
may require a stone construction entrance, but plan must preserve paved construction entrance option).
(Rev. 1) Withdrawn. Applicant response (2/28/20): `This project provides three access entrances and
disturbance will not use heavy equipment. Paved construction entrance is excessive prevention for
intensity of disturbance. Vehicles are limited to ATV and side by sides.' Engineering accepts this
response.
3. Submit Floodplain Development Permit Application (FDP) for proposed activity within limits of mapped
(FEMA) floodplain. Ref. 18-30.3.12. Link to FDP application:
http://www.albemarle.org/upload/images/forms center/departments/Community Development/forms/Engi
neering_and _WPO_ Forms/Floodplain _Development _Permit.pdf (Rev. 1) Partially addressed. As -
follow -up: Ref, email to Shimp Engineering: April 10, 2020 9:44 AM (4 FDP Application comments).
4. County plan approval does not affect or supersede requirement to coordinate this project with an array of
state /federal agencies; for example: DEQ, VMRC, VDHR (heritage sites), DCR (heritage resources —
insects /plants), VDGIF /USFWS (species), or USACE (Waters of the U.S. /wetlands). Please coordinate
potential project impacts and additional permit requirements with relevant review agencies. (Rev. 1)
Comment persists. Applicant response: `Acknowledged.'
5. C4: For the moment, proposed bridge crossing of S. Fork Rivanna River cannot be approved. For approval,
coordinate Zoning and Floodplain Administrator approval, demonstrating that crossing is acceptable to
Zoning, and that design of proposed crossing meets standards listed at 18-30.3.13 through 30.3.15. (Rev. 1)
Comment persists. Applicant response: `Acknowledged, bridge no longer proposed on this plan.' Also,
ref. April 10, 2020 9:44 AM email to Applicant [FDP NSMP discussed].
6. If stream crossing of S. Fork Rivanna River persists as a design feature, provide additional plan /profile
detail required to evaluate FDP Application. `No Rise' in base flood elevation is a primary review
consideration. (Rev. 1) Comment persists. Applicant response: `Acknowledged, bridge no longer
proposed on this plan.' Also, ref. April 10, 2020 9:44 AM email to Applicant [FDP NSMP discussed].
7. While 17-603.C. lists bicycle paths as a type of structure, improvement, or activity authorized in a stream
buffer, stream buffer impacts must be offset 2: 1. To the extent proposed trail impacts stream buffer,
propose Mitigation Plan (sheet) that outlines efforts to minimize stream buffer impacts, and proposes offset
mitigation. Please ref. Table B, p. 95 of document titled Riparian Buffers Modification and Mitigation
Manual, listed at: htips://www.deq.virainia.>4ov/Portals/0/DEQ/\Vatgr/Publications/RiparianBufferManual.pdf (Rev.
1) Withdrawn. Review error. Applicant response: `According to the reference of the Albemarle County
Code Sec. 17-603: (Types of structures, improvements and activities authorized in a stream buffer) Sec. C:
(Water -dependent facilities and miscellaneous uses) mitigation is not required for passive recreation access,
such as pedestrian trails and bicycle paths.' An accurate statement, Engineering regrets any confusion.
C. Erosion and Sediment Control Plan (ESOP)
Virginia Code §62.1-44.15:55 requires the VESCP authority to approve or disapprove an ESCP. This plan
Engineering Review Comments
Page 3 of 5
is disapproved for reason listed at item 1., below. The erosion control plan content requirements can be
found in County Code section 17-402.
C2
1. Provide a text note that defines by location and description points of equipment access required to construct
the trail network, whether from a public right-of-way, via Ex. access road only (internal to parcel), or via a
combination of the two. (Rev. 1) May persist. Applicant response: `A text note is provided that defines the
locations for points of access to the trail network.' As follow-up: Reviewer cannot locate this note. If on
C2, please provide Note type /note number. If not located on sheet C2, please provide sheet number.
2. Describe Ex. access road (dirt, stone, fire road, etc.) (Rev. 1) Addressed.
3. If trees are to be removed from parcel interior (this is not a logging operation, per se), describe effect
/minimize impact of tree removal on natural resources, especially aquatic /riverine /wetland resources.
(Rev. 1) Addressed. Applicant response: `Trail network will be constructed with minimal vegetation
removal. This has been noted on the plans.'
C3 — (Rev. 1) C3 comments addressed.
4. Revise S. Fork Rivanna River label (sheet, lower -left) to read Mechums River (ref. GIS).
5. Label Moormans River.
6. Label Horseshoe Bend Road.
7. Label Free Union Road, Rt. 601.
C3-C8
8. Clearly label all points of access, whether from paved public roads, private streets, or Ex. access road; that
is, point/s at which track equipment enters wooded terrain. Provide adequate construction entrances at a
reasonable number of points to undertake this work. Entrances not shown are not approved with this plan.
(Rev. 1) Addressed.
9. Show and label critical slopes. (Rev. 1) Addressed. Note: Since bicycle trail network does not require a
site plan (see 18-4.2.3), trails may traverse critical slopes subject to VSMP /WPO plan requirements and
plan approval.
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Coordinate with Albemarle County, CDD/ Zoning -Planning, regarding potential intensification of use in a
rural area (bike trail may qualify as accessory use to residential use). Please coordinate. Point of contact:
Engineering Review Comments
Page 4 of 5
Scott Clark /Planning Division ( sclarkna,albemarle.org ). (Rev. 1) Comment persists. Applicant response:
`Acknowledged.'
C4-C8 — (Rev. 1) C4 — C8 comments addressed.
11. On each sheet, provide an identical typical 1" = 10' scale drawing that clarifies that LOD is a narrow strip <
20' or similar width required to construct the trail. LOD is somewhat ambiguous since shown as a double
dashed line. Albemarle hopes to avoid any confusion or mistaken view that LOD measures hundreds of
feet wide, which may happen if LOD is viewed as a single -dash line. A typical inset detail (1" = 10')
should help clarify. Please include a Note that detail is a typical detail, that width may vary (Note:
Engineering maintains it is important that plan clearly indicates trails qualify for review as a linear project.)
12. Provide match lines.
13. C6, C8, C9: Note reading: `Install silt fence parallel to trail when trail is within 100 feet of waterway, or as
directed by the County Erosion and Sediment Control Inspector,' appears reasonable, given additional
limits on land disturbance that apply to linear projects (item 1., SWMP, above). As consequence,
Albemarle requests estimate of quantity of silt fence reasonably anticipated to be required, and whether one
hundred (100) wattles seems a reasonable estimate needed to complete construction (wattle installed unit
price =?). These quantities will help support VSMP /ESC Plan bond. ESC Plan bond is required. (Rev. 1)
Addressed. Note /important: Applicant response: `We estimate (100) straw wattles is a reasonable estimate
for this project. Per discussion with the County on February 20. 2020, we agree to post a bond of $20,000
which will cover (1) working construction entrance at a time and stabilization of up to one acre of linear
disturbance of trail.' Albemarle accepts $20,000 as a reasonable WPO plan bond amount. Please submit
request for VSMP /WPO bond estimate ($250 fee) at earliest convenience. Link to form:
http://www.albemarle.or¢Lupload/images/forms_center/departments/Communiiy Development/forms/bonds/Bon
d Request to Establish a Bond.pdf
C 10 — (Rev. 1) C 10 comments addressed (or withdrawn).
14. Provide a typical section (similar to typical section for a bike or multi -use path) that shows proposed
mountain bike trail width and 3'-5' (vertical?) bench cut described at Note 2, sheet C1, required to
establish the mountain bike trail network.
15. Provide view or image of straw wattle that includes recommended installation steps to guide construction
inspection. Caption this view "x 45 (Typ.)" (or whatever final swale crossing count is). If two wattles are
proposed at each swale, please clarify. Should additional swales require straw wattles, VSMP plan revision
is not required but coordination with ESC inspector is an expectation, necessity, and minimum requirement.
16. Provide ACDSM paved construction entrance detail (ACDSM, p. 8). (Rev. 1) Withdrawn. Also, SWM
Plan item 2., above.
17. Provide VESCH, 3`d Edit., 1992, Std. & Spec. 3.02, Temporary Stone Construction Entrance detail.
D. Pollution Prevention Plan (PPP) — Ref. SWPPP, Sec. A (Rev. 1) Comment persists. PPP Exhibit
required.
The PPP content requirements can be found in County Code section 17-404. This plan is disapproved
The VSMP permit application and all plans may be resubmitted for approval when all comments have been
satisfactorily addressed. For re -submittals please provide 2 copies of the complete permit package with a completed
application form.
Engineering plan review staff are available from 2-4 PM on Thursdays, should you require a meeting to discuss this
review.
Process:
After approval, plans will need to be bonded. The bonding process is begun by submitting a bond estimate request
Engineering Review Comments
Page 5 of 5
form and fee to the Department of Community Development. One of the plan reviewers will prepare estimates and
check parcel and easement information based on the approved plans (Note: Ref. ESCP item 13., above; $20,000
bond is acceptable). The County's Management Analyst will prepare bond agreement forms, which will need to be
completed by the owner and submitted along with cash, certificates or sureties for the amounts specified. The
agreements will need to be approved and signed by the County Attorney and County Engineer. This may take 2-4
weeks to obtain all the correct signatures and forms.
Stofinwater Management Faoilities Maintenance agr-eementswill also need to be completed and reoor-ded. The
County's Management Analyst or- otheF staff will prepare the foftns and eheek for- owner -ship and signatur-e
information. The completed forms will need to be submitted along with ootirt recording fees.
After bonding is and agreements aFe complete, county staff will need to enter project information in a DEQ database
for state application processing. DEQ will review the application information based on local VSMP authority
approval. At this time, the DEQ portion of the application fees will need to be paid directly to the state. For fastest
processing, this is done electronically with the emails provided on the application (SWPPP Registration Statement).
DEQ should notify applicants with instructions on how to pay fees. When DEQ approves the application, they will
issue a permit coverage letter. This should be copied to the county.
Easements must be recorded prior to VSN4P appr-oval. Proof of purehase of nut -fie -at or -edits is r-equired for plan
approval, and to receive a Grading Pemit.
After DEQ coverage is issued, the County can hold a pre -construction conference. Applicants will need to complete
the request using a pre -construction conference form, and pay the remainder of the application fee. The form
identifies the contractor and responsible land disturber, and the fee remaining to be paid. This will be checked by
county staff, and upon approval, a pre -construction conference will be scheduled with the County inspector. At the
pre -construction conference, should everything proceed satisfactorily, a grading permit will be issued by the County
so that work may begin.
County forms can be found on the county website forms center under engineering;
hLtp://www.albemarle.ora/deptforms.asp?department--cdenMo
Ifyou have questions /concerns, please contact me at janderson2galbemarle.oriz or at 434.296-5832 -0069.
Thank you
J. Anderson, Engineering Div.
WP02020-00002 Horseshoe Farm VSMP 041020rev1