The James River Association (JRA) supports the "Procedures for DEQ Staff – Virginia Pollutant Discharge Elimination System (VPDES) Review Reissuances and Issuances." This document demonstrates a collaborative and proactive approach to environmental stewardship and protection. By adhering to the 2006 MOU between DEQ, DCR, DWR, and the USFWS, the procedures establish a structured framework for the review and reissuance of VPDES permits, ensuring that all relevant stakeholders are involved.

The prioritization criteria outlined for VPDES reissuances demonstrate an intelligent allocation of resources, focusing on cases where changes in discharge location, infrastructure maintenance, effluent composition, or 316(a) and 316(b) assessments warrant thorough review. This targeted approach enhances efficiency while maintaining a commitment to water quality standards.

Moreover, the inclusion of recommendations for new issuances, especially those within the vicinity of documented listed species or Threatened and Endangered Species Waters, showcases a forward-thinking strategy to prevent potential environmental harm.

Additionally, it is essential that staff prioritize the reissuance of permits, even when discharge or intake parameters remain constant, in response to changes in information regarding endangered, threatened, or fragile species in receiving waters. Proactively reassessing permits based on updated data, such as alterations in habitat designation or population assessments, ensures a responsive and science-driven approach to protecting vulnerable species and maintaining ecosystem integrity.