I recently requested a document from Department of Conservation and Recreation. This request was based on a comment made by the Christiansburg Town Manager to Town Council at a public meeting, the
Town Council Meeting of December 16, 2008 (written minutes). This statement was to advise Town Council that the Erosion & Sediment Stormwater Ordinance for the Town of Christiansburg (
Chapter 10 of the Town Code) (or a
udio at the 45 minute mark) needed to be modified slightly because there were changes in definitions of the State Code and a few minor changes in design. The Town Council voted to accept this 'document'. Only one problem, the document didn't exist. Or at least when I asked for a copy I was told that it hadn't been written yet. (The updated version of Chapter 10 of the Town Code has recently become available at the town website - see link above). If it had been provided, and if the Town Council members had read it, they would have found that there were a lot of changes and they were significant, not minor. Of particular note was increased enforcement, increased fines for violators, and higher standards in erosion & sediment/stormwater control measures.
Since that time, I did a review of Town Council Meeting Minutes, the Town Code, the State Code, and just about everything else I could find. I did line by line comparisons of the Town Code with the State Code and the various DCR documents that establish guidelines and criteria (more on all of that at a later date).
DCR did a program review for the Town of Christiansburg. The specific dates of that review were October 21 and 22 of 2008. Someone within the Town of Christiansburg received a Corrective Action Statement from DCR based on the results of that study. It mandated that the Town of Christiansburg would sign the Corrective Action Agreement no later than April 18, 2009 and that a written report on progress would be provided to DCR no later than June 17, 2009. It also mandated that the corrective actions would be completed no later than September 15, 2009.
I will be reporting on several aspects of this report but, for now, I want to focus only on the Corrective Actions. Take a look at these and see if it really looks like a few minor changes based upon definitions were needed, or if there are/have been greater issues with the Town's approach to Stormwater management. It is important to realize that once property is rezoned, the Town Council is effectively out of the picture and totally dependent upon the actions of the Town Manager to insure that the health, safety, and well-being of citizens is maintained. The Codes of the Town of Christiansburg give virtually exclusive rights to the Town Manager to enforce criteria, make waivers, accept less than minimum standards, etc.
The program component that is noted for corrective action is "INSPECTION" and 4 specific items were noted.
- Inspections shall be conducted during or immediately following initial installation of E&S controls per 4VAC50-30-60B.
- Inspections shall be conducted at the required frequency per 4VAC50-30-60B.
- Erosion and Sediment control measures shall be repaired and maintained per 4VAC50-30-60A and Virginia Erosion and Sediment Control Handbook, 1992. (VESCH).
- Inspections shall ensure that sites are consistent with the applicable Minimum standards (4VAC50-30-40).
Of course I'm not a professional, but this looks like someone is saying that Inspections for Erosion & Sediment Control/Stormwater Management were not being done in compliance with State Codes and that the Town of Christiansburg has been directed to correct these 'errors/ommissions'.
Note that this document was signed by the Town Manager on 4/3/09 (the document from DCR is dated 3/19/09). There are a total of 35 pages in this document. This is the first page. Additional pages provide more specific information concerning the reviews performed and areas that were scored.
More on the information found on these additional pages tomorrow.