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.