It seems that some of the changes make sense, are well worth it and are important. However, there are some items that just don't seem to pass the 'common sense' test.

1. Waiting for a response to the registration statement. There should be a time limit for DCR to review the Notice of intent. For example: If they don't respond within 5 days, it's assumed approved. It is a terrible idea to place this road block into the already bottle-neck process.

2. The public posting of the SWPPP twice a month. This is extremely excessive and a total waste of money and people's time. Please rethink it.

3. Prohibiting coverage of multiple builders within the same construction site. This may solve a problem of responsibility for the particular site, but creates other problems.  There needs to be something addressing this scenario or else, people will be forced to ignore the regulations or be confused as to what to do.  

4. No Grandfathers allowed.  It would be unfair if existing permits/projects were not allowed to be "Grandfathered" by the new regulations. Perhaps a transitional period of a year so the already economically strained builders and subcontractor don't get stuck with these unanticipated costs.