HomeMy WebLinkAboutWPO202200024 Review Comments WPO VSMP 2023-02-20County of Albemarle
m COMMUNITY DEVELOPMENT DEPARTMENT
VSMP Permit Plan Review
Project title:
Rivanna Solar
Project file number:
WPO-2022-00024
Plan preparer:
Sierra Overhead Analytics
[mmenezes@sierraoverhead.com]
Owner or rep.:
American Helios - Phil Horwitch
[phorwitch@america nhel ios.com]
Plan received date:
17 June 2022
(Rev. 1)
29 August 2022
(Rev. 2)
26 January 2023
Date of comments:
27 July 2022
(Rev. 1)
12 October 2022
(Rev. 2)
20 February 2023
Reviewer:
Matt Wentland
401 McIntire Road, North Wing
Charlottesville, VA 22902-4579
Telephone: 434-296-5832
WWW.ALBEMARLE.ORG
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. The
rationale is given in the comments below. The VSMP application content requirements can be
found in County Code section 17-401.
A. Stormwater Pollution Prevention Plan (SWPPP)
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.
1. Provide a signed DEQ Registration Form. (Rev. 1) Response noted.
2. The Virginia ESC Handbook can be removed from the SWPPP. (Rev. 1) Comment
addressed.
B. Pollution Prevention Plan (PPP)
The PPP content requirements can be found in County Code section 17-404.
1. The PPP appears acceptable at this time.
C. Stormwater Management Plan (SWMP)
VSMP Regulation 9VAC25-870-108 requires the VSMP authority to approve or disapprove a
SWMP. This plan is disapproved, and the reasons are provided in the comments below. The
stormwater management plan content requirements can be found in County Code section 17-
403.
1. A SWM maintenance agreement will be required. Please contact Ana Kilmer in our office
to begin this process. (Rev. 1) Comment not addressed. Response noted. (Rev. 2)
Comment addressed.
2. Provide the plans as a single set. (Rev. 1) Comment addressed.
3. Include the General Notes on the cover sheet (linked in email). (Rev. 1) Comment
addressed.
Engineering Review Comments
Page 2 of 5
4. If the project does not obtain an interconnection approval by December 31, 2024, it will
need to comply with the attached DEQ memos. (Rev. 1) Response noted.
5. Show and label all required easements on the plans, including access easements to
proposed facilities. Easements will be dedicated to public use and should include all the
measures used for DEQ compliance. See Revision 1 comments below.
6. A plat and deed of dedication for the stormwater facility easements will need to be
recorded prior to approval of the VSMP and site plans. (Rev. 1) Comment not addressed.
Response noted.
7. Include the Albemarle County as -built requirements on the plans (linked in email). (Rev. 1)
Comment addressed.
8. Include the maintenance and inspection schedules from the DEQ BMP specs for the
proposed facilities on the plans. (Rev. 1) Comment addressed.
9. Provide the Army Corps of Engineers permits for the disturbance of the streams and
wetlands. (Rev. 1) Comment not addressed. Response noted.
10. DEQ water quality and water quantity requirements will need to be met. Include all
calculations regarding these requirements (runoff calcs, VRRM spreadsheet, BMP calcs,
etc.). The existing site condition for this project area should be forested and the posts and
beams along with roads and buildings should be included in the impervious. [9VAC25-
870-65, 66] See Revision 1 comments below.
11. Show the dry swales and any additional measures at a larger scale. Any concentrated
flow from the measures that outfall into a natural channel will need to meet energy
balance. See Revision 1 comments below.
12. Will grading be required for the panels or roads? If so, it will need to be shown on the
plans. (Rev. 1) Comment addressed. See Revision 1 comments below.
13. Provide additional information on the mitigation plan, including areas of mitigation and
the species and quantity of plants. Any areas of plantings outside of the buffer (per
Albemarle GIS) will need to be in an easement (link to additional materials in email). (Rev.
1) Comment partly addressed. Include the species and quantities of plants. The table on
SW-101 has the three small shrubs marked, but the entire B section is required. (Rev. 2)
Comment addressed.
Revision 1 Comments
14. The panels and other improvements cannot be located within the BMP footprints. (DEQ
BMP Spec. 2) (Rev. 2) Comment addressed
15. Refer to Table 2.2 in DEQ BMP Spec. 2 for the required widths and slopes of filter strips.
It appears most of the strips shown are too steep. (Rev. 2) Filter strips are no longer
shown.
16. The dry swales are still difficult to see. Consider using different line types and weights for
the existing and proposed contours. Include the drainage areas to the dry swales, the
maximum is 5 acres. They are also concentrating the flow and will need to be released
into an adequate channel. Energy Balance will also be required for concentrated flows
entering a natural channel. (DEQ BMP Spec. 10, 9VAC25-870-66(B)3) (Rev. 2) Swales are
no longer shown.
17. Ditches created by the road grading will also need to be designed and meet the DEQ
requirements. (Rev. 2) Comment not addressed. The road grading is no longer shown on
the plans.
18. The disturbed area in the VRRM appears to be larger than what is actually disturbed.
Also, undisturbed areas (especially in the buffer) can be used as Forest & Open Space for
Engineering Review Comments
Page 3 of 5
additional credits (Forest & Open Space will need to be platted, please contact me for
additional information if this might be something you want to pursue). (Rev. 2) The
VRRM and methods to meeting DEQ quality requirements was not found on the plans.
19. 1 am awaiting a response regarding how to handle the easements and will let you know
when that is finalized. (Rev. 2) The easements will be assessed with the plat submittal.
Revision 2 Comments
20. Pipes will need to be buried to avoid maintenance and erosion issue. All outlets will need
to be into a channel and Energy Balance will need to be met.
21. The tables on SW-102 will need to include the Qa1l.ed/Qdeveloped from the Energy Balance
equation and the Qactua1/Qpmt from the storm routing. Include the routing calculations
with the submittal. The Qio pre and post will also need to be shown to verify DEQ flood
protection.
22. Include the orifice inverts on the profile views of the basins. Also show the top of berm.
23. Diversion Dikes cannot be used as a permanent measure due to their limited life and
maintenance requirements. These should be replaced with ditches and should include the
design calculations for the ditches.
24. Some of the drainage areas appear to be incorrect and should be verified. An example is
on sheet ESC-208 near trap 11 where the line is parallel to a contour.
25. The conservation area shown on the plans that is being used in the VRRM should be
labelled as'SWM Forest and Open Space'.
26. Show all the proposed grading on the plans. There appears to be contours shown on the
roads that do not tie into the existing contours. Label the max slopes of the roads.
27. Use the US Fish and Wildlife link in the email to determine if this project is in a critical
habitat for endangered species.
D. Erosion and Sediment Control Plan (ESCP)
Virginia Code §62.1-44.15:55 requires the VESCP authority to approve or disapprove an ESCP.
This plan is disapproved, and the reasons are provided in the comments below. The erosion
control plan content requirements can be found in County Code section 17-402.
1. Include a note that additional measures may be required at the request of the County
Inspector. (Rev. 1) Comment addressed.
2. Use details from the Virginia Erosion and Sediment Control Handbook. (Rev. 1) Comment
partially addressed, see comment 4 below.
3. Specify that non-native plants and grasses are not to be used for stabilization. (Rev. 1)
Comment addressed.
4. Perimeter controls will be needed around all areas of land disturbance, including tree
removal. (Rev. 1) Comment not addressed. All control measures should be from the
Virginia Erosion and Sediment Control Handbook (VESCH). It is unclear what a sediment
Swale is and it does not appear to be in the VESCH. There is also no measures shown for
the stream crossings and silt fence cannot be used for storage. (Rev. 2) Comment
partially addressed. Some of the diversions do not appear to lead to a channel (such as
on sheet ESC-203). All diversions will need to lead to a stabilized outlet or other
measure (VESCH 3.09). See also comment 5 below.
5. For silt fence, the maximum drainage area is no more than one quarter acre per 100 feet
of silt fence and the maximum slope length behind the barrier is 100 feet. Consider
Engineering Review Comments
Page 4 of 5
diversion dikes to sediment traps or basins for the measures. [VESCH 3.05] (Rev. 1) See
previous comment. (Rev. 2) Comment partially addressed. It appears the silt fence was
removed though it would still be a good option in many areas. Per comment 1 above, it
may be required by the inspector.
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, erosion and sediment control and stormwater management improvements must
be bonded. The bonding process begins when the plan is approved, and the applicant submits a
bond estimate request form and fee to the Department of Community Development. A plan
reviewer will prepare estimates and check parcel and easement information based on the
approved plans. 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.
Stormwater Management Facilities Maintenance agreements will also need to be completed and
recorded. The County's Management Analyst or other staff will prepare the forms and check for
ownership and signature information. The completed forms will need to be submitted to the
County, who will record the agreement.
After bonding and agreements are complete, county staff enters project information in a DEQ
database for state application processing, if a DEQ permit is required. DEQ reviews 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. DEQ should notify applicants with
instructions on how to pay fees. When DEQ approves the application, they will issue a permit
coverage letter, which must be posted at the construction site.
After DEQ coverage is issued, via the coverage letter, the County can hold a pre -construction
conference. Applicants must complete the request for 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 joint VSMP and grading
permit will be issued by the County so that work may begin.
Engineering Review Comments
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County forms can be found on the county website forms center under engineering;
https://www.al bemarle.org/government/com mu nity-development/apply-for/engi neering-applications