The Virginia Ready-Mixed Concrete Association believes that the current General Virginia Pollutant Discharge Elimination System Permit for Concrete Products Facilities, (9 VAC 25-193) is a useful and effective permitting mechanism that both consolidates relevant regulatory requirements while providing the regulated community an efficient process for permitting its facilities. In general, and as detailed in DEQ’s public notice, we believes that the current regulation “…  i) is necessary for the protection of public health, safety, and welfare …; (ii) minimizes the economic impact on small businesses in a manner consistent with the stated  objectives of applicable law; and (iii) is clearly written and easily understandable.”

We do not see a need to open the permit at this time and feel this regulation should be retained in its current form.