Tag Archives: corrective

Despite the issues noted, page 31 of the pdf document (DCR report./Corrective Action) gives a Local ESC Program Rating that reports the following. While not a perfect score, it clearly shows those areas where opportunities exist for the Town of Christiansburg to improve its performance when it comes to the management of Erosion & Sediment and Stormwater.

CERTIFIED PERSONNEL (Scored 45 of 45 possible points):

1. Locality has a Certified Program Administrator
2. Plans are reviewed by a Certified Plan Reviewer
3. Inspections are conducted by a Certified Inspector

ESC Ordinance (Scored 45 of 45 possible points):

1. All required items are present and correct and all optional items are included.

General Program Administration (Scored 8 out of 10 possible points)

1. 2 points for Locality charges plan review/land disturbance permit fees.
2. 2 points for Locality requires pre-construction conference.
3. 0 points for Locality has developed an ESC application package, including standard forms and instructions
4. 2 points for Locality uses a database or attaches a standard tracking/summary sheet to the project folder
5. 2 points for Locality organizes ESC documents by project.

Plan Reviews (Scored 85 out of 100 possible points)

1. 20 of 20 points: Prior to commencement of land disturbing activity, an approved plan or agreement-in-lieu-of-plan is required for all projects.
2. 5 of 5 points: Where there is a plan or agreement in lieu of plan, designation of a Responsible land Disturber or individual holding a certificate of competence is required prior to commencement of land distrubing activity (UNLESS APPROPRIATELY WAIVED)
3. 5 of 5 points: Plans are reviewed within 45 days of receipt.
4. 5 of 5 points: The plan reviewer states in writing the reasons for disapproval and specifies the needed modifications for approval.
5. 20 of 30 points: 70% of reviewed plans meet the applicable Minimum Standards (should have been 100%)
6. 10 of 15 points: 70% of reviewed plans comply with VESCH guidelines (should have been 100%)
7. 5 of 5 points: Maintenance responsibilities for ESC measures are included in the approved plan
8. 5 of 5 points: Locality maintains a copy of approved plan or agreement in lieu of plan and associated documentation until final stabilization
9. 5 of 5: Variances are requested and responded to in writing
10. 5 of 5: Other considerations: Locality implements two of the items listed below:
    1. No. maintenance agreements for permanent facilities are required for plan approval.
    2. No. Plan preparers and plan reviewers use the minimum standard and plan review checklists and the checklists are maintained in the project file.
    3. YES. Opportunity for inspector review and recommendation is incorporated into the plan review process.
    4. No. When plan review is provided by a SWCD or other outside source, the plan reviewer meets with the inspector(s) prior to commencement of land disturbing activity.
    5. No. Lot by lot grading plans are required for plan approval of subdivision projects.
    6. Yes. All plans are stamped and dated upon approval

Inspections (55 of 100 possible points earned)

1. 5 of 15 poinst for: inspections are conducted during or immediately following initial installation of erosion and sediment controls. Based upon: For at least 50% (but no more than 69%) of reviewed projects, inspections occurred during or immediately following installation
2. 0 of 20 points: Inspection frequency satisfies the requirement of 4VAC50-30-60. Based upon: Inspection frequency averages greater than once in every four week period or the locality has not fully implemented it’s Board approved Alternative Inspection Program.
3. 15 of 20 points: Inspection documentation meets program requirements. Based upon: documentation includes project name, inspection date, violations, changes that are required, and notes on verbal or written communications with responsible party. (Note: the missing component that would have given them all 20 points was – deadlines for correcting violations.)
4. 20 of 30 points: Visited sites meet the VESCR Minimum Standards. Based upon: Each visited site meets all but two of the applicable Minimum Standards (Note: If this had been three instead of two, the score earned would have been zero.)
5. 10 of 10 points: Inspections were conducted at the completion of a project and prior to release of any performance bond. Based upon: At least 70% of the sites were inspected at project completion.
6. 5 of 5 points: Inspection Management. Based upon: Locality implements two or more of the items listed below:
   1. Yes: Procedure in place to coordinate plan changes resulting from inspection activities with the plan approval authority.
   2. NO: The responsible party is required to submit monitoring reports to the plan-approving or permit-issuing authority.
   3. Yes: When variances are requested during land disturbance they are responded to in writing.
   4. Yes: A pre-construction meeting is held on all sites requiring a plan.
   5. Yes. Duplicated copies of inspection reports are left on-site with the responsible party.
   6. NO: As-built documentation is required for all permanent SWM facilities installed to meet Minimum Standard 19.

Enforcement (80 of 100 possible points)

1. 20 of 30 points: When violations noted on written inspection reports remain during subsequent inspection(s), Notices to Comply (or equivalent action) are issued. Based upon: Where violations remained, NTC were issued 70% of the time.
2. 10 of 10 points: Notices to Comply (or equivalent action) contain specific measures that need to be taken and specify deadlines for completion. Based upon: Yes or inspection documents and site visits indicate enforcement was not necessary.
3. 10 of 10 points: Advanced enforcement such as Stop Work Orders (or equivalent action) contain specific measures that need to be taken and specify deadlines for completion. Based upon: Yes or inspection documentation and site visits indicate enforcement was not necessary.
4. 30 of 30 points: Advanced enforcement such as Stop Work orders (or equivalent action) were issued when appropriate. Based upon: Advanced enforcement was issued 100% of the time or inspection documentation and site visits indicate advanced enforcement was not necessary.
5. (4 individual components worth 5 points each for a total of 20 points: 10 of 20 points earned.)
   1. 5 of 5 points: Locality has developed or utilized standard enforcement documents
   2. 0 of 5 points: Locality has disseminated an enforcement policy to the development community.
   3. 0 of 5 points: Locality has developed a schedule of civil charges/administrative fines.
   4. 5 of 5 points: Bond revocation, civil penalties, criminal penalties, etc. are used to secure compliance.

Well, that’s it for my review of the DCR Audit and Corrective Action. Hope you have learned as much as I have. It will be interesting to see what actions the Town has taken to correct these issues. Come to Town Council meetings and bring your questions with you. It is your property, your town, and your government.