It is good to see that VA DEQ has proposed a state permit that is able to acknowledge and observe the new NPDES regulations from the EPA and still address parts of the new regulations that are easily found to be duplicative, costly, and unnecessary. Having the first "run" of this permit be for two years is a good idea. This keeps the commitment time to that permit fairly short while allowing regulators enough time to regroup (if desired) to begin drafting a new general permit. By eliminating registration statements, fee requirements, and minimizing reporting of private records and proprietary information, the proposed permit may prove to be of minimal cost to those involved (agency and applicators) in both time and money.

However, the VA version of the NPDES permit cannot begin to address other issues that will arise once the regulatory wheel is in motion. Just one to consider... the possible future litigations that will arise and now be held to the light of the Clean Water Act.  Companies who are trying to keep our aquatic habitats and resources clean, preserved, and maintained to ensure continuity of those environments, could be greatly impacted by imposed legal costs under that type of legislation. 

The City of Manassas would like to make these following comments:

The earliest precursor of pollution generated by life forms would have been a natural function of their existence. The attendant consequences on viability and population levels fell within the sphere of natural selection. These would have included the demise of a population locally or ultimately, species extinction. Processes that were untenable would have resulted in a new balance brought about by changes and adaptations. At the extremes, for any form of life, consideration of pollution is superseded by that of survival.

For humankind, the factor of technology is a distinguishing and critical consideration, both as an enabler and an additional source of byproducts. Short of survival, human concerns include the range from quality of life to health hazards. Since science holds experimental demonstration to be definitive, modern treatment of toxicity or environmental harm involves defining a level at which an effect is observable. Common examples of fields where practical measurement is crucial include automobile emissions control, industrial exposure (e.g. Occupational Safety and Health Administration (OSHA) PELs), toxicology (e.g. LD₅₀), and medicine (e.g. medication and radiation doses).

"The solution to pollution is dilution", is a dictum which summarizes a traditional approach to pollution management whereby sufficiently diluted pollution is not harmful.^[35][36] It is well-suited to some other modern, locally scoped applications such as laboratory safety procedure and hazardous material release emergency management. But it assumes that the dilutant is in virtually unlimited supply for the application or that resulting dilutions are acceptable in all cases.

Such simple treatment for environmental pollution on a wider scale might have had greater merit in earlier centuries when physical survival was often the highest imperative, human population and densities were lower, technologies were simpler and their byproducts more benign. But these are often no longer the case. Furthermore, advances have enabled measurement of concentrations not possible before. The use of statistical methods in evaluating outcomes has given currency to the principle of probable harm in cases where assessment is warranted but resorting to deterministic models is impractical or unfeasible. In addition, consideration of the environment beyond direct impact on human beings has gained prominence.

Yet in the absence of a superseding principle, this older approach predominates practices throughout the world. It is the basis by which to gauge concentrations of effluent for legal release, exceeding which penalties are assessed or restrictions applied. The regressive cases are those where a controlled level of release is too high or, if enforceable, is neglected. Migration from pollution dilution to elimination in many cases is confronted by challenging economical and technological barriers.http://en.wikipedia.org/wiki/Pollution http://www.private-medical-insurances.co.uk/ http://www.car-tinted.com