As written, I do not think this document will encourage the use of the streamlined process.  The liability/risk that is being placed on the Developer, PE & DCA may keep it from being utilized.  In addition, if DEQ chooses to review during the “audit period” this will only extend the review timeline as additional time and will already have been spent outside of the DEQ period and part of the concern, whether valid or not, is the type of review we are currently experiencing from DEQ at the moment.  For example, some comments are generic and provide no clarification on what the actual issue is with the plan or for the more specific comments the information requested is already on the plans so it is apparent thorough reviews are not being completed.  This is happening into 2^nd/3^rd submittals. 

My gut reaction when reading this was that I hope plans that I stamp and seal do NOT get submitted as part of this process and that I would not want to put any DCA on our staff into this position.  A third party DCA at least has a choice to be a part of this process.  However, as a PE, I may have no choice if the developer hires a 3^rd party reviewer.  To get reported to DPOR on a subjective “trend of deficiency” if another certified party has reviewed and approved the plans seems over the top.